Please be advised that the…

ERO number

019-6813

Comment ID

90790

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

Please be advised that the Council of the County of Frontenac, at its regular meeting held May 17, 2023, passed the following resolution, being Recommend Reports from the Chief Administrative Officer, clause b):
Recommend Reports from the Chief Administrative Officer

b) 2023-065
Planning and Economic Development
Summary of Proposed Changes to the Provincial Policy Statement and Planning Act (Bill 97)

Motion #: 106-23 Moved By: Councillor Lichty
Seconded By: Councillor Greenwood-Speers

Be It Resolved That Council receives for information the Administrative Report entitled “Summary of Proposed Changes to the Provincial Policy Statement and Planning Act (Bill 97)”; and,
That Council direct the Clerk to submit comments about the proposed changes as outlined in Appendix A of this report to the Province through the Environmental Registry of Ontario.
Carried

The County of Frontenac respectfully submits the following response to Changes to the Provincial Policy Statement (ERO 019-6813):

Lot Creation in Prime Agricultural Areas
Agriculture is a prime component of the County’s economy as extensive areas of both prime agricultural lands and rural areas are used for farming. Agriculture is not only important for the economy of the County, but it is also deeply rooted in the identity of our residents. We take pride in ensuring that agricultural land is managed and protected to ensure long-term provision of local food and our way of life.
The County of Frontenac is generally in support of policies that will make it easier to build more housing in the province. However, the policies presented by the Provincial Planning Statement have the potential to create scattered development within prime agricultural areas that may:
• Result in the physical loss and/or fragmentation of good quality but underutilized agricultural land,
• Impact the location of new livestock facilities or the expansion potential of existing livestock facilities as a result of minimum distance separation requirements,
• Place additional burdens on existing public infrastructure and service provision such as school bussing, snow plowing, and road maintenance, and
• Result in conflict between new residential uses and modern farm practices that include ingress and egress of large agricultural equipment and transportation, spreading of manure, bird and rodent mitigation devices (e.g., air cannons), and instances of early morning and late-night harvest or crop management.
In addition, the proposed lot creation policies in prime agricultural areas are not clear or easy to implement.
The County requests additional information and clarification regarding the criteria presented for lot creation in prime agricultural areas. Clarification is requested specifically on the following matters:
• What constitutes agriculture? The Provincial Planning Statement does not define agriculture.
• What is considered adjacent to a non-agricultural use? Does this constitute other uses such as institutional, farm-related commercial, residential, etc.?
• What are lower-priority agricultural lands and how should they be determined? The general definition of lower-priority agricultural land within the Guidelines for Permitted Uses in Ontario’s Prime Agricultural Area, prepared by the Ontario Ministry of Agriculture, Food and Rural Affairs suggest that lands that are not currently under agricultural production, have fewer drainage or irrigation upgrades, and those that constitute of good quality farmland could meet the definition of lower priority agriculture lands. Applying this definition could result in good agricultural land that has not been utilized to its maximum potential to be taken out of production, simply because it has not been subject to irrigation upgrades.
The County would welcome an enhanced municipal consultation process that could include establishing a technical working group with municipalities, Indigenous communities, and other agricultural groups to ensure that the proposed agricultural lot creation policies will not impact the long-term provision of agriculture and local food within our province.
Employment Lands
Economic development is important to rural communities, and it continues to be challenging to support and establish local businesses. The restrictions placed on what can constitute employment lands as currently proposed should not apply to rural lands and rural settlement areas. Rural municipalities that can or wish to establish small business parks need to have as much flexibility as possible in terms of the range of uses that can be permitted in order to make such development viable.
Additional Dwelling Units and Natural Heritage
While Frontenac County supports the ability to utilize additional residential units to support additional housing, the inclusion of such units in the rural area, particularly on waterfront properties, needs to ensure appropriate on-site servicing for private water and sewage services. Increased density on waterfront properties has the potential to negatively impact the quality of waterbodies and therefore needs to be carefully monitored and managed.
The County of Frontenac Official Plan generally defines Waterfront Areas as all lands extending inland 150 metres (500 feet) from the ordinary high water mark of any lake, river, or waterway. This is a general boundary intended to recognize that development within this area may have an impact on lake quality and those impacts may need to be considered for any development within the boundary. The purpose of these provisions is to ensure that the quality of waterbodies and character of the waterfront is protected for the long term. County staff have worked with Ministry of Environment staff over the years to develop policies in local Official Plans that prioritize water quality protection and lake health as the overarching priority for all of the lakes in the region. The County continues to support policies that will ensure that waterfront lots have an appropriate density and that there is not a cumulative increase in density over the long term.
I trust you will find this in order; however should you have any questions or concerns, please do not hesitate to contact me at 613-548-9400, ext. 302 or via email at jamini@frontenaccounty.ca.
Yours Truly,
Jannette Amini, Dipl.M.M., M.A. CMO
Manager of Legislative Services/Clerk