October 2, 2017…

October 2, 2017

Helma Geerts

Policy Advisor

Ontario Ministry of Agriculture, Food

And Rural Affairs

Policy Division, Food Safety and Environmental Policy Branch

1 Stone Road West, Floor 2

Guelph, Ontario

N1G 4Y2

Re:EBR Posting 013-0968

The Golden Horseshoe Food and Farming Alliance appreciates the opportunity to make comment on the Draft Implementation Procedures for the Agriculture System in Ontario’s Greater Golden Horseshoe. The Alliance has worked with the municipalities to collect foundational data used to create the System through the Asset Mapping project. In addition, the Working Group of the Alliance have been closely involved with the design of the Agriculture System since the conclusion of the Coordinated Land Use Planning Review in May 2017. We have found this involvement to be a positive experience and believe that the Agriculture System will be a key factor to strengthen the protection of agricultural land, rural communities and the viability of farms.

The GHFFA supports the Province’s process to implement mapping and Implementation procedures for the draft Agricultural System agricultural land base map and agri-food network. However, we have several concerns, the primary one being the flexibility municipalities will have in refining the agricultural land base and in particular, the Prime Agricultural Area, especially in cases where municipalities have completed a local Land Evaluation and Area Review (LEAR) study.

Overview of the Provincial Agricultural System and Proposed Implementation Procedures

The agricultural policies in the provincial land use plans have been updated to be more consistent across each of the Plans and with the new permitted uses identified in the Provincial Policy Statement. The Plans include policies that guide the protection of a Provincial Agricultural System for the GGH and enhancement of the economic viability of the sector.

The Province has identified two components that make up the Agricultural System for the GGH: •the land base comprised of Prime Agricultural Areas and Rural Lands; and,

•the agri-food network of business and services that supports the agri-food sector.

The proposed “Implementation Procedures for the Agricultural System in Ontario’s Greater Golden Horseshoe” released by OMAFRA identifies principles, criteria and methods that the Province used to identify the draft Provincial Agricultural System and direct how municipalities are to designate and map the Prime Agricultural Area.

Analysis of the draft Agricultural System

The following provides the GHFFA summary and analysis of the proposed Agricultural System.

Over Designation of Prime Agricultural Areas

Upon initial review of the draft agricultural land base map, we are not fully supportive of the choice of LEAR factors or weighting used by the Provincial LEAR as it has led to the over designation of the Prime Agricultural Area in some municipalities.

Re-designating Rural Lands and lands designated Open Space, to Prime Agricultural Area can unduly restrict non-agricultural rural economic development that support rural communities. These areas can be used for additional agricultural-related, resource based commercial/industrial, existing commercial/industrial and other uses supportive of rural communities (i.e., institutional). By over designating the Prime Agricultural Area and capturing lower LEAR scoring agricultural lands, it removes lands that can be used to support the entirety of the agri-food network and rural communities.

The draft mapping contains inaccuracies and should be corrected or the proposed Implementation Procedures should recognize the issues and recommend how municipalities should move to correct inaccuracies.

Recognition of Municipalities with LEAR Studies

The Regions of Halton, Peel and York and the City of Hamilton have each completed local LEAR studies. These studies methodology were developed in consultation with the local agricultural community and are based on local influencing factors. Therefore, there are differences between the Provincial and local LEAR studies with the amount and location of the Prime Agricultural Areas identified. It also means that the continuity of the Prime Agricultural Area and the agricultural land base at municipal boundaries do not align as identified in the draft Provincial mapping.

The draft Implementation Procedures direct that local LEAR studies can be used to refine provincial mapping during municipal conformity however, the criteria and process to undertake this refinement is not clear. The Implementation Procedures also direct municipalities to edge match the agricultural land base where municipal boundaries abut. Again, the criteria for this edge matching is not included.

Recognition of Prior Land Use Planning Approvals

As provincial agricultural land base mapping is broad scale and not refined, it extends into approved, non-agricultural designations that may not be appropriate candidates for PAA or Rural Land designations and conversely excluding lands that could be candidates for inclusion within a PAA or Rural Land designation. This includes lands with previous approvals by the Province or Ontario Municipal Board (OMB), or municipal site-specific land use planning approvals that re-designated the Prime Agricultural Area or Rural Lands to a non-agricultural use.

Some areas proposed as prime agricultural by the Province are already identified for other uses, including an ecological preserve, quarry, golf courses, rural industrial parks.  

Consultation

Consultation by the Province has been at the municipal level and with stakeholders such as the GHFFA and Federations of Agriculture. Consultation happened throughout the summer, during a busy agricultural time. Three public open houses were also held. However, more direct landowner engagement by the Province has not been undertaken.

Agri-Food Network

The agri-food network policies in the Provincial Plans encourage municipalities to plan for and protect the economic viability of the agri-food sector. The proposed Implementation Procedures provide options that municipalities can consider to support and grow the sector, many of which are occurring within the Golden Horseshoe. For example, local Agricultural Advisory Working Groups, local farm and farm market guides and partnerships such as the Golden Horseshoe Food & Farming Alliance.

The components of the agri-food network have been identified through a proposed online portal. This portal was developed using the GHFFA’s Agri-Food Asset Map as a foundational piece.

Recommendations

The GHFFA request that the following recommendations be considered:

Draft Agricultural Land Base Mapping and Implementation Procedures

•Proposed Provincial Implementation Procedures need to be clarified to permit greater flexibility for municipalities to identify land use designations for the agricultural land base, based on local influencing factors. This includes:

oClear support for use of local LEAR studies to refine the Provincial agricultural land base mapping in municipal conformity exercises.

oGreater weight and consideration to local LEAR studies provided they have followed provincial guidelines.

•That the Province provides flexibility to municipalities when making decisions on how agricultural designations align at municipal boundaries. Criteria should take into consideration the impact on farmers who farm in many jurisdictions. The province should establish a proactive approach to consulting with landowners directly impacted by the proposed Agricultural System agricultural land base map.

•The Provincial Implementation Procedures need to identify that there are inaccuracies in the draft agricultural land base mapping and acknowledge that data correction may also be part of the municipal conformity process.

•The Provincial Implementation Procedures for prior approved land use designations need to be more flexible and acknowledge that re-designation to a Prime Agricultural Area or Rural Lands may not be suitable in all cases.

•It is not clear what will happen when existing uses on farms change use. This could occur with rural businesses, solar farms, wedding barns etc. Clarity is required and education for planners at the municipal level must be provided for all elements of the Agricultural System.

•The Provincial Implementation Procedures should permit flexibility in the nomenclature to reflect the structure of municipal official plans.

•That the Province establish a proactive approach to consulting with landowners directly impacted by the proposed Agricultural System agricultural land base map.

•That the Province maintain the agricultural land base mapping as interim until all municipal refinements and conformity through Official Plan amendment has been completed. This will enable municipalities to further address discrepancies in the mapping due to the differences between the Provincial and local LEAR studies.

•The Greenbelt Plan says agricultural land base is made up of Specialty Crop, Prime Agricultural land and rural lands. In Hamilton, the provincial LEAR has removed almost 8,000 ha of rural, open space and utility designated lands (excluding natural heritage features -3,800 ha which may be designated Rural in the RHOP and zoned natural heritage). These rural lands function as support for the rural communities by accommodating non-ag uses, resource base industrial /commercial uses and larger aggregated uses. Some of these uses cannot be put in rural settlement areas as they or not compatible or are already fully developed.

Draft Agri-Food Network

•Overall, agri-food network portal needs to be more user-friendly. Including:

oDouble-click to zoom in on the map instead of relying on the + and – buttons.

oIncrease response time to commands.

oLayers list should be further broken down into categories (i.e. Spatial Mapping, Livestock, Crop etc.) with + arrows to expand layers.

•It is critical that data sets remain up-to-date. The Province should establish a process that: oEstablishes data refresh periods.

oEnables stakeholders to submit new data sets for the portal.

oIdentifies the last modification date to the portal.

oIdentifies the date and source of the data layers.

The Golden Horseshoe Food and Farming Alliance would be willing to assist the Ministry to keep

the data current but this would require financial resourcing to accomplish.

•

•Data sets need to be expanded to :

oBe arranged by group layers using NAICS codes and land use designations.

oProvide more specific sub-sectors of main listings (e.g., “Vegetable” or “Fruit” should have the sub-sectors of the types grown listed and identified).

oInclude data sets for non-food agricultural commodities (e.g., nursery, equine, etc.) and niche crops (e.g., hops, ginseng).

oAddition of Agricultural Institutions and Research facilities to the Agriculture System

oFurther detail on the gradation of the concentration of assets in the spatial density (e.g., how many assets create a high, medium or low spatial concentration of an asset?).

oInclude dates and source of the data layer and base maps.

•Information in the portal should be available for download and use by municipalities in their GIS software.

•As the agri-food network portal is anticipated to be a tool in the use of Agricultural Impact Assessments, the “Details” section should include a disclaimer on how the portal information is to be used to inform Agricultural Impact Assessments.

Thank you for your consideration of our points. Should you require further clarification, please do not hesitate to contact our Executive Director, Janet Horner at janet@whitfieldfarms.com. The Golden Horseshoe Food and Farming Alliance appreciate the opportunity to comment and further assist the development of the Agriculture System

Sincerely,

Bill Hodgson

Chair

Golden Horseshoe Food and Farming Alliance

[Original Comment ID: 211099]