Hon. Steve Clark Minister of…

Hon. Steve Clark
Minister of Municipal Affairs and Housing
17th Floor, 777 Bay Street
Toronto ON M5G 2E5

RE: ERO 019-6813, the 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,

The Township of Ramara has reviewed the proposed draft Provincial Planning Statement and offer the following comments for consideration:
Agricultural Changes

1. Additional Residential Units – The Township has no concerns with the explicit allowance of additional residential units on agricultural properties. Current policies in the Township allow for additional residential units, however there would be difficulties in allowing these structures to be severed.

2. Lot Creation – The Township of Ramara has great concern with proposed lot creation in the agricultural zone. Our Agricultural land should be protected and promoted, allowing for lot creation will remove lands from farm production. Lot creation in the agricultural designation would impact the viability of our existing and potential future agricultural industry.
4.3.3.1.v is subjective. There is no method for measuring “lower-priority” agricultural lands.

Land Parcels for farming purposes in Ramara are generally at most 40 hectares in land area. As measured in the Township records, an 8 km2 area contains 28 separate agricultural parcels as of January 1, 2023 (which does not include smaller residential lots created in the past). Based on the new PPS legislation, there would be a potential for 84 new residential lots within this area.
With the average size of a lot created in the rural zone for residential purposes being between 1 and 2 acres to accommodate a well and septic, there is an estimated 84 to 168 acres of agricultural land that could be removed for residential purposes in this area alone.

An increase in lot creation in the Agricultural areas is not necessary in Ramara. The Township contains several settlement areas with development potential, and rural areas that could accommodate this Rural Residential need. In order to assist the municipality in achieving more houses as the province promotes, more support is needed in equipping these areas for development as opposed to allowing for severances on wells and septic spread throughout agricultural lands.

It should be noted no direction has been given for lands that had a surplus farm dwelling severed off for farm consolidations. Will these properties also then be entitled to 3 severances since the zoning has had residential development restricted on the lands?

If the Province deems it necessary to allow for lot creation in the Agricultural zone, municipalities should have the ability to restrict the number of lots to be created allowing for the review of the impact of the agricultural sector and the justification behind requiring more than one residential lot. There should also be a clear definition on how to prioritize agricultural uses to allow municipalities to identify areas where lot creation in agricultural areas is appropriate.

Rural Changes

1. Residential development, including lot creation and multi-lot residential development. The Township of Ramara is pleased to see more flexibility with multi-lot residential development in rural areas where site conditions are suitable, and there is provision for appropriate services and infrastructure. This allows for flexibility for the municipality to identify areas where appropriate residential growth can be established, opportunities for infilling or a rounding out of existing built up areas where there is land parcels that are not viable for farming.

Controls from a municipal perspective would be important to ensure that the municipality can identify areas in their Official Plan in consultation with applicable agencies regarding waste collection, infrastructure, Ministry of Environment and school boards etc.

2. Recreational Dwellings. The Township has endured the difficulty with “recreational dwellings” not intended as permanent residences. This stipulation can make it difficult for prospective home owners to obtain financing for projects. This is also very difficult from an enforcement perspective. Now that Residential development, including lot creation and multi-lot residential development is permitted in the rural zone, more direction should be provided on how to differentiate between the two development types would be identified and implemented.

In closing we appreciate the opportunity to provide comments on the ERO and draft Provincial Planning Statement. While lot creation outside of settlement areas is desirable, protecting agricultural land and the pressures put on the Settlement Areas in our municipality are the key to striking a balance between our farming and residential communities.

Walied Zekry,
Director of Building and Planning, CBO
Ramara Township