Ontario Greenhouse Vegetable…

Ontario Greenhouse Vegetable Growers (OGVG) appreciate the opportunity to provide comments on municipal consent requirements for communal drinking water and wastewater systems. OGVG represents 170 greenhouse vegetable farms across Ontario, encompassing over 4,500 acres of tomatoes, cucumbers, and peppers. These operations are significant users of municipal water systems where available. Access to reliable municipal water connections is a key factor driving the concentration of greenhouse production in southwestern Ontario, where over 80 percent of the province’s greenhouse vegetable acreage is located, with a significant cluster in the Leamington and Kingsville area that accounts for more than 50 percent of Canada’s greenhouse tomatoes, cucumbers and peppers.

OGVG supports both the public ownership of drinking water and wastewater systems and the role of nonmunicipal systems in enabling growth. Given that water and wastewater infrastructure is foundational to development, municipal consent requirements for establishing non-municipal systems, also referred to as public utilities, must be carefully structured. There is a risk that such consent authority could be used, intentionally or unintentionally, as leverage to restrict growth.

It is therefore essential that any prescribed criteria or conditions governing municipal consent be narrowly defined, technical, and objective in nature. Historically, investment in water and wastewater systems has not been prioritized in some municipalities, where resources have instead been allocated to new amenities rath an maintaining or expanding core systems. This underinvestment has constrained growth and limited expansion opportunities for businesses including greenhouse farms.

In cases where infrastructure capacity has fallen behind demand, municipalities have relied on measures such as connection moratoria, interim control bylaws, and escalating rate structures to manage demand rather than invest in increased supply. A notable example is the Union Water Supply System (UWSS), jointly owned by the four municipalities which imposed a 12-month moratorium on new water connections in 2021. This system serves Leamington and Kingsville and directly supports greenhouse production. As of 2026, the moratorium remains in
place and is expected to continue until at least 2028, significantly constraining sector growth.

Under section 93 (3) of the Municipal Act, municipalities retain the authority to impose conditions on consent. While the proposed amendments under Bill 98 may limit these conditions to those prescribed in regulations, this
details of such regulations have not yet been established. Without clear limits, broad municipal discretion connection policies risks creating de facto barriers to development, particularly where additional water and wastewater servicing capacity is required.

OGVG strongly recommends that any conditions prescribed under section 93 be strictly technical, objective, and transparent, minimizing the potential for discretionary interpretation. In many municipalities high development
charges for water and wastewater services and long timelines for infrastructure expansion have already rendered new construction economically unviable. In such circumstances, fiscally responsible and environmentally sustainable non-municipal alternatives must be permitted.

Limiting municipal consent authority to clearly defined technical, financial, and operational criteria will help ensure fairness, prevent misuse, and support continued growth. Reliable water and wastewater infrastructure are essential for thriving communities and economic development. It requires sustained investment, proactive planning, and supportive policy frameworks.
OGVG appreciates the opportunity to contribute to this consultation and remains available to provide further information or clarification.