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Environmental assessments must measure impact on ag

July 3, 2019  By Brent Royce Director Ontario Federation of Agriculture

The provincial government recently released a discussion paper – Modernizing Ontario’s Environmental Assessment Program – as they consider changes to the Environmental Assessment Act. The government has asked for public input on the proposed vision for the environmental assessment program based on the discussion paper.

The Ontario Federation of Agriculture (OFA) has provided a formal submission with an overriding message – agriculture must be consulted and considered in any public sector project that could impact our farms and businesses.

We support the overall need to review legislation to remove duplication and find efficiencies. But we must also be sure that in the process, we don’t lose sight of the purpose of the legislation. One of the core principles of the environmental assessment process is that it considers all aspects of the environment including natural, social, economic, cultural and build conditions. OFA believes any changes to the Environmental Assessment Act must retain this core principal.


We are concerned about the government’s proposal to exempt “lowest-risk” categories from needing an environmental assessment. The greatest concern with this “exemption” is that some of these projects could have an impact on agricultural lands and businesses. It’s also unclear what activities are considered “low risk”.

That’s why OFA believes that when potential impacts on our agri-food sector and agricultural communities are identified, a higher level of environmental assessment should be required.

Also, any public sector project must include an Agricultural Impact Assessment if the project has the potential to impact agriculture. OFA is pushing for this requirement to be incorporated in the environmental assessment process. We have also recommended to government that any and all Agricultural Impact Assessment consulting teams include an agricultural specialist. The Ontario Ministry of Agriculture, Food and Rural Affairs outlines the qualifications of an agricultural specialist to conduct an Agricultural Impact Assessment.

The involvement of the local agricultural community is also key to conducting a thorough Agricultural Impact Assessment. For example, when the Ministry of Transportation studied provincial highway expansion options between New Hamburg and Sebringville in 2007, the farm community got involved. Farmers identified the location and activities conducted on surrounding farmland connected with their farm businesses. This enabled mapping of not only the farmland impacted but also the associated movement of agricultural inputs, farm machinery and agricultural products.

OFA takes the process of environmental assessments very seriously. Agriculture must be considered, consulted and included in assessments because our farm businesses touch so many aspects of our environment – impacting natural, social, economic and cultural conditions of the environment.

We know how important it is for agriculture’s voice to be included in decisions to amend legislation and regulations. And we are strongly urging the government to include our recommendations for Agricultural Impact Assessments as it makes changes to the Environmental Assessment Act. You can read our full submission at – under Resources, click on Submissions and Correspondence.

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