RE: Intensification,…

RE: Intensification, Municipal Comprehensive Review, and Settlement Area Expansion, ERO #019-6813 for review of proposed policies adapted from A Place to Grow and Provincial Policy Statement to form a new provincial planning policy instrument

Dear Minister Clark,

I am writing to express my concerns regarding the proposed changes found in the proposed Provincial Policy Statement, 2023 (PPS 2023). Specifically, I am concerned about the impact the proposed policies will have on agricultural lands in the province.

Ontario’s prime agricultural land is a finite, non-renewable resource that comprises less than 5% of Ontario’s land base1. With the growing rate of farmland loss in the province, currently at a rate of 319 acres per day2, it is more important than ever before that the province protects our prime agricultural areas. Ontario’s farmland directly supports the agri-food sector, which is the largest economic sector in the province, employing more than 750,000 Ontarians along the supply chain and annually contributing over $47 billion to the province’s GDP3.

While I recognizes the need to address issues of housing availability and affordability, I am concerned that several of the policies in the proposed PPS 2023 will not adequately contribute to the housing issues and instead will create significant issues for the long-term viability of Ontario’s agri-food sector. This submission will focus primarily on sections of the proposed PPS 2023 dealing with intensification, municipal comprehensive reviews, and settlement area expansion.

Comments regarding proposed changes to intensification, municipal comprehensive reviews, and settlement area expansion

I have significant concerns regarding the proposed policy changes found in the PPS 2023 regarding intensification targets, municipal comprehensive reviews, and settlement area expansion. These policies should ensure strategic growth for communities while protecting highly valuable farmland. However, while the proposed PPS 2023 generally states support for intensification, it does not require targets for municipalities across Ontario and provides many permissions that would undermine attempts at intensification. Additionally, the intensification targets for many municipalities in the Growth Plan have been reduced or removed altogether, which will use up lands in municipal boundaries faster and lead to increased rates of urban boundary expansion. Without the requirement to complete municipal comprehensive reviews, this poses a significant threat to farmland. As noted below, reducing and eliminating density targets is contrary to encouraging complete communities found within the proposed PPS. This will lead to fragmented patterns of development, including when settlement boundary expansion occurs.

I have noted concerns under s.2.3, Settlement Areas and Settlement Area Boundary Expansions. The policy in s.2.3.2 now states that “land use patterns within settlement areas should be based on densities and a mix of land uses”. The province opted to change the language from “shall” to “should”, which weakens the policies that are meant to support intensification. Additionally, the language that states land use patterns should “minimize negative impacts to air quality and climate change, promote energy efficiency” and “prepare for the impacts of a changing climate” has been removed. This is concerning given the climate crisis we are facing and that agriculture relies on healthy and stable ecosystems to produce a consistent supply of quality local food. By removing this language, the province is undermining the future viability of the agricultural sector, the largest sector of the Ontario economy.

Recommendation 1: The province should use stronger language in s.2.3.2 that will require municipalities to adopt land use patterns that support density targets and also minimize negative environmental impacts.

Furthermore, s.2.3.3 states that “planning authorities should support general intensification and redevelopment to support the achievement of complete communities, including by planning for a range and mix of housing options and prioritizing planning and investment in the necessary infrastructure and public service facilities.” Once again, the use of “should” is not strong enough to ensure the deliverables of complete communities. Furthermore, the policy no longer requires planning authorities to identify appropriate locations or take stock of suitable existing sites, eroding the possibility of efficient land use. While I encourage the use of complete communities in the planning framework, the removal of intensification targets will not only have sever impact to farmland but it will undermine the existing urban planning framework to achieve complete communities.

Recommendation 2: The province should use stronger language in s.2.3.3 that will require municipalities to identify appropriate locations for intensification.

The policy on settlement area expansion has also been weakened, which will further threaten Ontario’s prime agricultural land. A major concern is removing the requirement of a municipal comprehensive review that demonstrates the need for expansion. Additionally, the language in s.2.3.4 has been changed from “shall” to “should” which weaken the policy, making it possible for development to occur on prime agricultural lands. While proposed s.2.3.4.b states that applicable lands do not comprise specialty crop areas, this is a subsection under s.2.3.4 which states planning authorities “should” consider this. Since the language does require planning authorities to consider this, there is the likelihood of it still occurring. This is also the case for s.2.3.4d regarding impacts on agricultural lands and operations that are adjacent or close to the settlement.

Recommendation 3: The province should require municipal comprehensive reviews prior to settlement boundary expansion and require the planning authority to demonstrate the need. Furthermore, the province needs to adopt stronger language in s.2.3.4 that ensures the applicable lands do not comprise specialty crop areas and that prime agricultural areas are avoided to the greatest extent possible as determined through an agricultural impact assessment.

I have also noted the removal of policies from s.2.6 Rural Lands in Municipalities, in particular, “when directing development on rural lands, a planning authority shall apply the relevant policies of Section 1: Building Strong Healthy Communities, as well as the policies of Section 2: Wise Use and Management of Resources and Section 3: Protecting Public Health and Safety.” I suggest that the removal of this policy will undermine the future resiliency of rural communities.

Recommendation 4: The province should reinstate the policies pertaining to directing development on rural lands that require planning authorities to apply relevant policies that support strong and resilient communities as found in the Provincial Policy Statement, 2020.

Finally, there is concern pertaining to the language in s.2.1.1 that states, “sufficient land shall be made available to accommodate an appropriate range and mix of land uses to meet projected needs for a time horizon of at least 25 years.” As noted above, without improving language and goals pertaining to density targets, it will be increasingly difficult for municipalities to plan accurately for beyond 25 years. This will likely lead to further settlement area expansion to accommodate the likelihood of urban sprawl, which will reduce investments in agricultural operations surrounding urban boundaries.

Recommendation 5: The province should maintain the current requirement for planning authorities to plan for up to 25 years in order to minimize unnecessary and premature settlement area expansion.

In conclusion, the proposed changes to intensification targets, municipal comprehensive reviews, and settlement area expansion weaken policies that would ensure strategic growth for communities while protecting highly valuable farmland. The use of weaker language and the removal of requirements will lead to increased rates of settlement boundary expansion and further threaten farmland and the agricultural sector. It is essential that the policies are strengthened to ensure efficient land use and protect Ontario’s agricultural operations and communities.

References:

[1] Ontario Ministry of Agriculture, Food and Rural Affairs. 2016. Guidelines on Permitted Uses in Ontario’s Prime Agricultural Areas. Retrieved from http://www.omafra.gov.on.ca/english/landuse/facts/permitteduseguide.pdf
[2] Statistics Canada. 2021. Census of Agriculture. Retrieved from https://www150.statcan.gc.ca/t1/tbl1/en/tv.action?pid=3210015301&pickMe…
[3] Ontario Federation of Agriculture. 2020. Agriculture Matters – A Guide for Municipal Councillors and Staff. Retrieved from https://ofa.on.ca/resources/guide-for-municipal-councillors-and-staff/