OFVGA Submission: Environmental Registry of Ontario posting 019-1187 Drainage Act Discussion Paper


 February 18, 2020 

Ms. Sara Peckford 

Food Safety and Environmental Policy Branch 

Ministry of Agriculture, Food and Rural Affairs 

1 Stone Road West, Guelph, Ontario 

N1G 4Y2 

RE: Environmental Registry of Ontario posting 019-1187 Drainage Act Discussion Paper 

Dear Ms. Peckford, 

The Ontario Fruit and Vegetable Growers’ Association (OFVGA) is the voice for over 3,500 farms that grow fruits and vegetables on almost 250,000 acres of land in Ontario. The OFVGA welcomes this opportunity to provide comments on the Drainage Act Discussion Paper. 

Ontario’s municipal drains contribute to the efficient production of fruits and vegetables on a wide variety of land types across the province. Initiatives that streamline Drainage Act processes, which will lead to reduced costs, more timely drainage projects and maintenance, are welcomed by OFVGA’s members. 

As a member of the Ontario Federation of Agriculture, we have reviewed their submission to this consultation and through this letter, would like to offer our support to OFA’s comments on the discussion paper. The OFVGA would like to reinforce the following positions. 

1. There is value in implementing a simplified process to update the engineer’s report to account for changes to drain design made during construction. This would simplify future maintenance and repairs of the drainage system. 


2. Update the current DART protocol considering recent amendments to the Conservation Authorities Act related to the forthcoming definitions of terms such as “development activity”, “watercourse” and “wetland”. Defining these terms will have a bearing on the current DART protocol, as well as on potential future protocols. 


3. Province-wide adoption of the DART protocol, rather than its current voluntary usage, would benefit all stakeholders and ensure that decisions are made in a consistent and fair manner across the province. 


4. Broaden the definition for what would be considered a minor improvement. The OFVGA is especially supportive of improvements that would enhance the environmental performance of the drain. 


5. Allow the use of a simplified process to update the engineer’s report to address the changes to the lot fabric in a portion of a drainage area arising from urban settlements expanding onto neighbouring agricultural lands. Adjusting the assessment schedule to reflect these changes would be a substantial improvement. 

The OFVGA would like to thank the Ontario Ministry of Agriculture, Food and Rural Affairs for allowing this opportunity to comment on its Drainage Act Discussion Paper. We would like to be engaged as the ministry proceeds with the consultation and possible legislative amendments. 


Bill George Brian Gilroy 

Chair, OFVGA Board Chair, Energy, Property and Infrastructure Section Chair 


The Honourable Ernie Hardeman, Minister of Agriculture, Food and Rural Affairs