A newly released 135-page report is renewing scrutiny of the Region of Waterloo’s efforts to assemble roughly 770 acres of farmland in Wilmot Township for a proposed mega industrial site, a project that has remained largely opaque for more than two years and has sparked widespread opposition across the rural community.
The report, published in January by the Wilmot Civic Action Network (WCAN), argues the land assembly violates long-standing planning rules, threatens prime farmland and groundwater resources, and has advanced with little public transparency or consultation. The group is calling for the process to be stopped entirely.
While regional officials have not publicly confirmed next steps, residents say key decision points may be approaching, with purchase options on some properties reportedly nearing expiry and speculation growing that the matter could return to council as early as February.
At the centre of the controversy is land classified as prime agricultural territory – part of what the report describes as a vanishingly small portion of Ontario capable of reliably producing food.
According to the document, only about five per cent of Ontario’s landmass is suitable for agriculture, with less than one per cent considered prime farmland. Once paved over, the report argues, such land is permanently lost.
The Wilmot Civic Action Network contends the proposed industrial site would cross the region’s so-called countryside line, a long-standing boundary intended to limit sprawl and protect rural lands, and would bypass the official planning framework Waterloo Region has relied on for more than 50 years.
“The Wilmot Land Assembly completely ignores and bypasses the region’s planning process, our official plans, and proper consultation,” the report states, adding that the proposal contradicts the Regional Official Plan by extending development beyond established limits.
Water and infrastructure concerns
Beyond farmland loss, the report raises serious questions about water availability, sewage capacity, and environmental risk.
Waterloo Region relies heavily on groundwater, and the land identified for the industrial site overlaps areas tied to groundwater recharge and watershed protection.
No comprehensive studies outlining industrial water demand, sewage capacity, or environmental impacts have been publicly released.
“We are already experiencing a water shortage and functioning beyond sustainability,” the report states. “If this mega site proceeds, our groundwater is further threatened.”
The document also argues that the area’s sewage infrastructure is already near capacity and that expanding it could impose high costs on taxpayers, noting that development charges typically cover only about 80 per cent of growth-related capital expenses.
A central theme of the report is an unusually secretive process.
According to WCAN, landowners and residents were left in the dark for nearly two years, with non-disclosure agreements preventing elected officials from sharing information with constituents. The group says it filed numerous freedom-of-information requests, many of which were denied or returned with heavy redactions.
“For two years, farmers, landowners, and neighbours have been left in the dark about their future in Wilmot and are frustrated by the secrecy imposed by the region,” the report states.
The report also alleges that some farmers were pressured to sell their land under the threat of expropriation, despite the absence of a confirmed industrial tenant.
It questions the rationale of assembling land without a clearly identified end user and describes the process as speculative.
“The threatened expropriation of the 770 acres is land speculation,” according to the report
Kevin Thomason, a spokesperson with the Wilmot Civic Action Network, said the scale of the proposed site is almost unprecedented.
“You’re talking about roughly 770 acres – about an eight-and-a-half-kilometre drive just to go around the perimeter,” Thomason told The Observer. “There are almost no factories in the world that require an industrial footprint that big. Only the largest gigafactories even come close.”
Thomason pointed to the region’s purchase of a 160-acre farm as a flashpoint for community anger, saying the standing corn crop on the land was destroyed shortly before harvest.
“That was hundreds of thousands of dollars’ worth of food,” he said. “Enough corn to make roughly two-and-a-half million boxes of cornflakes, shredded and ploughed under at taxpayers’ expense.”
Opposition to the land assembly quickly spread beyond directly affected landowners, Thomason said, with residents across Wilmot and neighbouring communities expressing concern about traffic, water use, taxation, and the broader precedent being set.
More than 4,500 lawn signs opposing the project appeared across the region, according to the group, alongside petitions that gathered tens of thousands of signatures. Farmers from across Ontario voiced support, arguing that if land protections could be overridden in Wilmot, similar actions could occur elsewhere.
Frustration peaked last summer when farmers and residents said they were repeatedly denied the opportunity to address council.
In August, a tractor protest brought traffic to a standstill as a kilometre-long convoy travelled down the expressway and parked outside regional council chambers. Hundreds of people packed the building, with speakers given just four minutes to address council, Thomason said.
“How absurd that this is what citizens have to do to be heard by their own elected officials,” he added.
The report also challenges economic projections cited by officials, including claims that the site could generate tens of thousands of jobs.
“Claims from elected officials of the creation of as many as 30,000 new jobs appear to be exaggerated with no supporting evidence or study,” the report finds.
It argues that Waterloo Region already has designated employment lands available and that infrastructure costs associated with a project of this scale could outweigh projected benefits.
According to Thomason, some landowners granted the region 12-month options to study and potentially purchase their properties, options that are expected to expire in the coming weeks.
While no public agenda or staff report has confirmed when council may revisit the issue, Thomason said residents believe decisions could come as early as this month, based on information shared confidentially by individuals familiar with the process.
“We’re not even supposed to know that February is a possibility,” he said, citing ongoing confidentiality agreements. “But thankfully, there are still people willing to speak up for the public good.”
The Wilmot Civic Action Network is urging the regional council and the province to walk away from the land assembly altogether.
“There is no confirmed customer, no water, no sewage capacity, no transportation plan, and no housing to support this,” Thomason said. “Millions of taxpayer dollars have already been spent. Don’t exercise these options. Walk away.”
The report frames the situation as a broader choice about the region’s future.
“Today, we are essentially at a fork in the road,” it states. “Do we give in to sprawl, or do we continue a planning process that protects rural lands, water, and long-term sustainability?”
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