*Original paper copy of…

*Original paper copy of letter has been mailed to Helma Gerts at 1 Stone Road West, Floor 2, Guelph Ontario.

Dear Ms. Gerts:

Re: EBR Registry Number: 013-0968

Draft Agricultural System Mapping and Implementation Procedures

Ministry of Agriculture, Food and Rural Affairs

On behalf of Mattamy Homes we thank you for the opportunity to comment on this latest initiative by the Ministry of Agriculture, Food and Rural Affairs. As a land owner in many areas throughout the GGH we offer the following for your consideration.

The purpose of this initiative is to provide policy direction and guidance on an Agricultural System across the GGH and to support the implementation of the Agricultural System policies in the updated provincial land use plans. Supporting the agricultural sector is important. It is one part of the broader equation for growth management. The various requirements of planning for the growth targets set out within the Places to Grow Plan, protecting natural heritage systems, managing urban boundary expansions as well as protecting the agricultural land base and industry create the need to balance priorities and a framework for making choices. It is a reality that over the next planning period that growth will occur on prime agricultural land. It is critical that the policy context for these tools and the directions from the Ministry as to how these tools are to be implemented are clear that these initiatives are not a growth management tool and not a basis to establish a permanent agricultural reserve but are considerations within a complex decision-making process as to where urban growth is to occur. The scope of the application of these initiatives must be clear from the outset.

The agricultural sector occurs in a balance between land base quality and availability and the markets trends in the industry. The viability of an area for agriculture depends not only on land quality and availability but on the supporting resources within that immediate area and constraints to agriculture such as poor ability to move machinery on the road network. The changing demographics and cultures of the GGH also impact the demand for various agricultural products. The proposed implementation tools do not reflect nor incorporate the full reality of this sector and the challenges and opportunities for an area to be considered a long term viable part of the agricultural land base.

It is hoped that the upcoming Agricultural Impact Guidelines will address these concerns however these guidelines are not yet available. It is our opinion that it is premature to finalize these three implementation tools until the Guidelines are released as they will be critical in understanding the full implementation of this initiative.

Regarding the Agricultural Systems Portal Mapping, it is not clear why an agricultural designation is being maintained under both the natural heritage designation and within settlement areas. It is our request that the mapping of this designation be removed where natural heritage and settlement area designations already exist and have existing permitted uses that may be jeopardized by applying an agricultural designation.

There are a significant number of technical questions that have been raised regarding these documents. These comments have been prepared by Coville Consulting Inc. and are attached to this letter for your review and consideration.

We look forward to speaking with you about these concerns.

Your truly,

Ruth Victor, MRTPI, MCIP RPP

________________________________________

Date: October 3, 2017

Technical Comments/Queries -­‐‑ Draft Greater Golden Horseshoe Implementation Procedures

Prepared by: Sean Colville, P.Ag. in association with Mr. Jerry Hagarty, P.Ag.

The province has posted the Draft Greater Golden Horseshoe Implementation Procedures on the EBR’s Environmental Registry and has asked for public input by October 4, 2017. At the request of Mattamy Homes, Mr. Jerry Hagarty (P.Ag.) and I have reviewed the Draft Greater Golden Horseshow Implementation Procedures together have prepared the following list of technical comments and associated queries.

1. Near-­‐‑urban locations provide opportunities for smaller, more intensive and specialized forms of agriculture that take advantage of the nearby urban market. As shown in Halton’s Regional Agricultural Strategy background document (2016), examples include greenhouses, mushrooms facilities, small equestrian, agri-­‐‑tourism and home occupation and added value operations. These smaller land base operations generally lack a total reliance on prime agricultural land. They’re quite different from the increasingly large scale field crop and intensive livestock production (including swine, beef and poultry), that rely on the availability of large areas of prime agricultural land and often prefer to be away from urban areas in order to reduce conflict potential and take advantage of lower land costs. The Growth Plan for the GGH provides for a full range of agricultural uses in Natural Heritage Systems, outside of natural heritage features such as Provincially Significant Areas and key hydrologic features;

o Has the Province undertaken any analysis of area needs for these smaller parcel agricultural pursuits in the GGH?

o In addition, has there been any assessment of whether existing areas set aside in the Greenbelt and Niagara Escarpment Plan might represent existing opportunities for accommodating a good portion of these land uses?

o Are there areas within the GGH Agricultural System that are better suited to traditional, large scale, field crop and livestock production and other areas better suited to these smaller, specialized forms of agriculture and agricultural related uses described above?

o Will areas within the GGH Agricultural System be prioritized (or zoned) for the different types of agriculture and agricultural related uses? For example, locating an intensive livestock operation may not be appropriate in some portions of the GGH Agricultural System due to the presence of adjacent, incompatible land uses. However, other areas within the GGH Agricultural System may be better suited for such uses due to the lack of surrounding conflicting land uses.

2. The draft implementation procedures recognize that there is a process through the PPS and Growth Plan for the GGH that allows for justified Settlement Area expansion provided that there is proper consideration of alternatives that minimize the impact of such expansion on agricultural land and it’s supporting agri-­‐‑food components. OMAFRA’s own Guidelines on Permitted Uses on Prime Agricultural Areas (Publication 851) also set out these considerations.

o In this regard, we recognize that the Ministry is striving for long-­‐‑term protection of Prime Agricultural Areas rather than attempting to create permanent agricultural reserves. Beyond circumstances involving settlement areas surrounded by specialty crop areas (as defined in the PPS), is this still the case?

o Has the agricultural systems approach to protecting agriculture been demonstrated to be effective in other jurisdictions and has the level of success been measured and documented? If so, within these examples, how has urban growth, employment and infrastructure needs been balanced with the need to provide long-­‐‑term protection for agriculture?

3. The decline in the number and area of large scale farm operations and the retreat of livestock production in the GGH has been influenced by broad agricultural industry trends including farm enlargement to achieve economies of scale; increasing land values; and conflict potential related to the larger nonfarm population. These industry factors could potentially be more influential in the evolution of agriculture in the GGH than planning policy. The smaller, more intensive and specialized forms of agriculture mentioned above may still dominate agriculture in the GGH. Planning policy can be supportive but market forces are likely to be the primary driver.

o In that regard, are there any examples, within other jurisdictions, where agricultural systems planning policy has resulted in reduced land costs and related evidence of the return of major capital investment in agriculture including that directed at livestock production?;

4. The OMAFRA prime agricultural area permitted uses guidelines (Publication 851) points out that LEAR studies that are to form the basis for the identification of agricultural systems for Official Plan delineation ‘broadly characterize the landscape and are not intended to be used for site-­‐‑ specific purposes’. The Ministry also clearly states that their agricultural land base mapping will need updating and is regional in scale and not detailed in terms of site specifics. Field inspection and surveys at a site level would be valuable for refining inaccurate, missing or unrefined data thereby improving the completeness and accuracy of the information.

o How do possible changes derived from field level refinement and updating activity get considered, particularly if there is no effort to check or update the information at the Municipal or Regional Official Plan level?

o Will land owners be able to assess their lands and if found to be non-­‐‑prime agricultural lands, will municipalities be able to refine their prime agricultural areas?

5. With proper agricultural stewardship guidelines, government-­‐‑held or administered lands could be made available on a long-­‐‑term lease, thereby enhancing and expanding the agricultural land base while recognizing the overlapping synergies between natural heritage, water resource and agricultural systems.

o Does the agricultural systems identification process include the possible agricultural use of government held or administered lands (for example Conservation Authority lands)?

6. As set out in the implementation procedures, protecting agriculture involves a focus on reducing land-­‐‑use conflicts and increasing economic support for the Agri-­‐‑food network.

o Collaterally, are there plans to strengthen Right-­‐‑to-­‐‑Farm legislation that might protect normal farm practices while minimizing the need for the possible assignment of buffer areas between agricultural and nonagricultural uses?

o Are there plans to lessen the MDS II setbacks for farmers wanting to establish a new or expand and existing livestock operation if they are within the GGH Agricultural Systems area?

7. The draft procedures (Section 2.1) indicate that the Ministry’s agricultural land base mapping and procedures will provide a consistent, rigorous and transparent methodology across the entire GGH.

o Please provide an example of how a stakeholder might trace specific data from the Ministry’s Agricultural Systems Portal through the LEAR analyses into the Agricultural Land Base Map and its component layers;

8. The agricultural systems approach to delineating areas of long term agricultural protection may contain peripheral buffers and corridor/linkage considerations in a fashion possibly similar to NHS. There seems to be little guidance for defining such plan elements.

o Is there any clear basis for establishing buffers beyond those already available in planning tools, such as Minimum Distance Separation?

o On the basis of what criteria will decisions regarding the need for linkages and/or buffers be made and how precisely and on the basis of what data are these areas to be identified, mapped and documented?

o How will their location and extent be determined?

9. It is understood that there may be flexibility for the inclusion of candidate areas identified for the agricultural land base and that this should occur at the time of Official Plan comprehensive review with documentation of the rationale for inclusion or non-­‐‑inclusion of these areas.

o What would be some appropriate example considerations for making these decisions?

10. The draft implementation procedures speak to the inclusion of rural lands that are located outside of prime agricultural areas but are included in the agricultural land base mapping because they are used for farming; link prime agricultural areas; or may support elements of the agri-­‐‑food network. Presumably these rural areas have lesser quality agricultural land.

o Will these rural areas, represent a lesser priority area for agriculture than prime agricultural areas when considering alternative locations for Settlement Area expansion?

o Do the LEAR score results utilized for identifying agricultural land system components form a basis for assigning greater or lesser agricultural priority when examining alternative directions for Settlement Area expansion, where urban boundaries are surrounded by prime agricultural lands?

11. We support the idea of policy and government initiatives directed at enhancing the economic viability of the agricultural sector in appropriate locations within the GGH including initiatives involving tax structure and assessment; availability of government-­‐‑held or administered lands for long-­‐‑term farm leasing; strengthening Right-­‐‑to-­‐‑Farm legislation; promotion of agricultural products; technical support through OMAFRA; and funding of agri-­‐‑food innovation and believe that there is also a role for the private sector to play in enhancing the long-­‐‑term economic viability of the agri-­‐‑food industry.

Prepared by:

Sean Colville, B.Sc., P.Ag. Colville Consulting Inc.

[Original Comment ID: 211067]