The Honourable Steven Clark…

The Honourable Steven Clark
Minister of Municipal Affairs and Housing
17th Floor, 777 Bay Street
Toronto, Ontario M7A 2J3

Submitted via email to Minister.mah@ontario.ca. Growthplanning@ontario.ca and via the Environmental Registry of Ontario (ERO)

Dear Minister Clark.

RE: ERO 019-6813 Review of proposed policies adapted from A Place to Grow and Provincial Policy Statement to form a new provincial planning policy instrument.

The Waterloo Federation of Agriculture has endeavored to represent the interests of its farmer members for over 80 years. We focus our lobbying activities on ensuring that Waterloo Region continues to be a leader in both urban and rural planning thus ensuring a vibrant and productive rural agricultural countryside as well as an innovative world class urban community. We continue to support upper tier planning as it is best able to employ visionary planning ideas that have contributed to Waterloo’s status as a world class centre for innovation, education, and manufacturing. We have also collectively and intentionally planned a community that can provide places for people to live and work and at the same time protected valuable and productive farmland. We firmly believe that the solution to the housing shortage in Ontario lies within the planning policies employed by the Region of Waterloo, the current PPS and Places to Grow.

Southern Ontario is a unique place in North America in that its climate, its soils and its proximity to the moderating influence of the Great Lakes allow it to grow a longer list of field crops, fruits, vegetables and livestock than any other locality on the continent other than the Central Valley in California. Unfortunately this farmland is in peril if we do not intentionally plan to protect it. The Ontario Federation of Agriculture calculates that if proposed planning policy changes are enacted, the current rate of farmland loss of 319 acres per day will increase to such an extent that we will lose half ( 6 million acres) of our existing farmland by 2051. This is a wholly preventable tragedy.

We suggest the following solutions to the housing shortage in Ontario and the concurrent need to protect farmland.

● We strongly oppose new residential lot creation on the agricultural landscape. The detrimental impacts of lot creation are well documented. They include the fragmentation of the agricultural land base, increased conflicts between neighbouring land uses and the inflation of farmland values which makes the purchase of farmland by new entrants unattainable. Agriculture flourishes in Waterloo Region where we have not allowed rural non-farm severences since 1973. We attribute our province leading income per farm and income per acre to the fact that we recognize the need to support an agricultural landscape system that prioritizes agriculture in rural Ontario.
● We strongly oppose changes to land designated as “Rural” that will allow scattered rural development, unconnected suburbs and low density urbanization of the landscape. The vast majority of land zoned “Rural” is also farmland and needs to be protected from residential lot creation.
● We support hard settlement boundary policies. They are an essential part of a long term planning process that ensures that farmland is protected and that urban growth occurs in a fashion that is sustainable.
● We support mandated intensification requirements for all urban centres. Waterloo has a current intensification rate of over 70%. Intensification saves farmland and we believe that it can be accomplished in a way that provides people with liveable, walkable communities that are desirable by the vast majority of inhabitants. Waterloo is a living example. We are one of the most desirable places to live and work in the province.
● We support mandatory densities in all new residential developments. Higher densities, if designed well, are desirable places to live and are less costly to service with water, sewer and public transit etc than low density sprawl. High density developments in Waterloo Region’s cities are fully subscribed before a shovel is placed in the ground.
● We strongly support visionary planning regimes in urban municipalities that eliminate farmland loss by building complete, liveable communities in a denser form that reduces servicing costs, promotes affordability, and provides people with a highly desirable place to live, work and play.
● We support the ability of Municipalities to enact land use policies that are more restrictive than the provincial planning documents including the proposed Provincial Planning Statement. Municipalities are generally the innovators when it comes to new and innovative plans and policies and an allowance to be more restrictive recognizes their ability to advance innovation that may become a template for others in the future.

Humans have cultivated the land and grown food here in Southern Ontario for over 2000 years and yet farmland is a non-renewable natural resource. If we pave it over, it is gone forever. However if we plan well and look after the land it is a perpetual resource that has the potential to feed us for another 2000 years. We have the ability and the knowledge to both protect farmland and provide people with a place to live and work. Intensification, compact form and visionary long term planning are the tools that will save our natural landscape and our ability to feed ourselves.

Finally, remember that we only have one landscape and people, the natural environment and agriculture all have to share it.

Sincerely, Waterloo Federation of Agriculture