July 31, 2023 The…

July 31, 2023

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

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.

Thank you for the opportunity to participate in the consultation process for planned policy changes
to the PPS. Our topline feedback is summarized below:

• Settlement Area Boundary Expansions: MFA strongly opposes changes to settlement
area boundary expansion policies, we believe that higher-density development is needed
to limit agricultural land loss.

• Additional Residential Units (ARUs): MFA supports ARUs on existing farm parcels and
rural hubs, but we have concerns about lack of criteria and specificity.

• Minimum Distance Separation (MDS): Ontario farmers value the MDS formulae as a
proven means of separating livestock facilities and permanent manure storages from
neighbouring land uses.

• Employment Lands: MFA would like to caution against changing Employment Lands
policies, as it may impact agricultural land use.

• Municipal Flexibility: MFA believes that the PPS should be a baseline that allows for
some flexibility. Municipalities should be allowed to be more restrictive within the local
policy so long as it is in accordance with provincial policy.

• Agricultural Impact Assessment (AIA): MFA supports AIA inclusion for land use
proposals and has some concerns about the granting of exceptions.

• Natural Heritage & Water: MFA believes that the Provincial Planning Statements should
not remove the words “all municipal” from section 4.2.1(e)(1). MFA is a strong advocate
of protecting water supplies and wetlands, in a way that prioritizes Normal Farm Practices.

Protecting the Future of Farming

The Middlesex Federation of Agriculture (MFA) was formed in 1939 to work on a local level to represent the voice of the farmer in Ontario. We work on behalf of more than 1,950 members in Middlesex County. We work to advance agriculture and the rural community through partnerships, education and advocacy. MFA has a strong voice for our members and the agri-food industry on issues, legislation and regulations administered by all levels of government. We are passionate and dedicated to ensuring that the agri-food sector and rural communities are considered and consulted with for any new or changing legislation that would impact the sustainability and growth of our farm businesses.

Ontario’s agri-food sector is an economic powerhouse – producing more than 200 farm and food
products, fueling rural communities, generating nearly 750,000 jobs and contributing more than
$47 billion to Ontario’s annual GDP. The province’s agri-food strategy, Grow Ontario, aims to
strengthen the agri-food sector, support economic growth and ensure an efficient, reliable and
responsible food supply. By removing barriers, unnecessary costs and red tape, Ontario farmers
will be positioned to seize opportunities and rise to the challenge of an ambitious growth strategy,
allowing the agri-food sector to continue to drive the economy forward.

We appreciate the reconsideration of the lot creation issue on agriculturally zoned properties. The
original direction would have had significant potential impacts on agricultural operations across
this province, and we thank you, Minister, for the change. We have reviewed the remaining
policies originally proposed within the statement using an agricultural lens, and provide the
following comments.

Agricultural System Mapping and Agricultural Land Protections

MFA is a strong advocate for the protection of Ontario’s farmlands for their long-term ability to
produce food, fibre, fuel, flowers and nursery stock, not only for Ontario’s growing population, but
also for consumers beyond our borders.

MFA believes that farming to produce food, fibre, fuel, flowers and nursery stock is the best use
for farmland. Ontario’s limited supply of farmland is a scarce resource, making up less than five
per cent of all the land in the province. It’s vital that Ontario has a strong, viable and sustainable
supply of food products grown, harvested and processed right here at home. Ontario’s shrinking
agricultural land base is alarming. The current rate of loss is measured at 319 acres per day in
our province, according to the 2021 Census of Agriculture. These losses are not sustainable.

We also wish to emphasize that there is only one Ontario landscape. The full range of urban,
rural, agricultural, natural heritage, cultural heritage and mineral extraction land uses must coexist
across this landscape.

Provincially, the protection of Ontario’s prime agricultural areas for their long-term agricultural use
must be a key objective. It is one thing to think about housing the anticipated additional two million
people that will reside in Ontario over the next 10 years, but it is another to think seriously about
how we will feed this increasing population. Ontario's agricultural lands are a finite and shrinking
resource. We cannot sustain continuing losses of agricultural land while maintaining our ability to
produce food, fibre, fuel, flowers and nursery stock from this limited and declining agricultural land
base. Therefore, any proposals looking at increasing housing supply must be done with
consideration to the needs and support of the agricultural community.

MFA endorses the 2020 Provincial Policy Statement (PPS 2020)’s Agriculture policies [Section
2.3] that require municipalities protect their prime agricultural areas for their long-term agricultural
use. We further support the flexibility afforded to farmers to engage in on-farm value adding of
primary farm products, as well as agriculture-related, on-farm diversified and agri-tourism uses.
We believe that prime agriculture lands should be defined as Class 1-6 plus speciality crop lands.
Classes 4-6 support agricultural activities such as grazing livestock, growing crops for biofuels,
and the agriculture sector has demonstrated that the productivity of this land can be improved
through activities such as tile drainage, stone picking and addition of lime. Provincial policy must
continue to protect specialty crop areas because they are scarce and unique; if lost, they cannot
be recreated. They are important economically and represent some of Ontario's highest-earning
agricultural lands. In addition, they provide many value-added and agri-tourism opportunities.

Not all agricultural land in Ontario is zoned as prime agricultural land, and there are many farms
and agricultural lands that municipalities have zoned as rural land. The proposed change to add
multi-lot residential development as a permitted use on rural lands within section 2.6.1 is very
concerning. We believe unrestricted growth in rural areas will have negative consequences,
especially for the preservation of agricultural lands. Land use planning in Ontario must balance
opportunities for growth with the need to preserve our agricultural lands, regardless of whether it
is zoned rural or agricultural. Focusing growth in existing settlement areas will support local
economies, reduce farmland loss and reduce land use conflicts.

We believe strongly in the PPS 2020 Agriculture policies that govern farmland and rural areas,
protecting the right to farm and the Agriculture System in Ontario. In addition to this, MFA believes
strongly that the fragmentation of farmland in rural areas is counterproductive for the agricultural
business structure in Ontario’s rural areas.

MFA is against the removal of the requirement to use the provincially mapped agricultural system
as it would allow for agricultural fragmentation, inconsistent classification of agricultural lands and
specialty crop areas and disconnect in agricultural land mapping and classifications across
municipal boundaries.

Settlement Area Boundary Expansions

MFA is strongly against the proposed changes to settlement area boundary expansion policies.
Specifically, changes in functional policy language have removed both the requirement to justify
need and to conduct a comprehensive review, as such could result in uncertainty and ambiguity
for the process, expectations, and requirements for these expansions. MFA believes that these
changes could lead to inconsistent implementation across municipalities, agricultural land
fragmentation and inconsistent protections and considerations for agricultural land across
municipal boundaries.

MFA supports fixed, permanent urban boundaries to limit the loss of agricultural land, thereby
focusing future urban growth within existing urban boundaries. This means urban growth primarily
through redevelopment of vacant and underused lands, and higher density development.

We further believe that in urban areas, higher density development should be mandated
provincewide to take full advantage of existing infrastructure. MFA supports urban intensification/densification as one way to protect agricultural land and create complete
communities.

MFA believes that urban areas should only be allowed to expand onto abutting agricultural lands
only after exhausting redevelopment of underused or vacant areas within their existing urban
boundaries. This would include the rehabilitation and redevelopment of both “greyfield” and
“brownfield” sites. Lastly, urban expansion onto abutting agricultural land must be directed onto
lower class agricultural land adjacent to the existing urban boundaries.

MFA does not support scattered or strip development within prime agricultural areas. This form of
development not only limits the ability of new and existing agricultural operations to function but
fails to contribute financially to municipalities. MFA believes that urban expansion should only be
permitted onto abutting agricultural lands where municipal sewer and water services are available.

MFA wants to see PPS policies in Section 1.1.3.8 remain as is. Keeping these policies intact (and
holding municipalities and MMAH accountable to following these policies) is critical for meeting
joint goals of balancing farmland protection with urban development. Further, MFA wants to see
Agricultural Impact Assessment (AIA) policies from APTG incorporated directly into the proposed
PPS policies on settlement area boundary expansions (APTG Policy 2.2.8.3 h). Specifically
referencing AIAs as the current policy outlines:

“Where the need for a settlement area boundary expansion has been justified in
accordance with policy 2.2.8.2, the feasibility of the proposed expansion will be
determined and the most appropriate location for the proposed expansion will be
identified based on the comprehensive application of all of the policies in this
Plan, including the following: ... h) any adverse impacts on the agri-food network,
including agricultural operations, from expanding settlement areas would be
avoided, or if avoidance is not possible, minimized and mitigated as determined
through an agricultural impact assessment;” (APTG Policy 2.2.8.3 h).

As Ontario becomes more urbanized, municipal councils and staff may not apply an agricultural
lens to their plan-, policy- and decision-making. This is critical as we need to plan for 'farm-friendly'
urban development that promotes compatibility at the urban-agricultural interface. For example,
parcel size, configuration, building setbacks, road patterns, institutional locations, drainage
patterns and location of municipal servicing will all have implications for agriculture.

MFA firmly believes in the widespread use of AIAs, as it ensures that agricultural uses continue,
and normal farm practices are protected. AIAs identify opportunities to increase compatibility
between agricultural and non-agricultural uses by looking for ways to avoid, minimize, then
mitigate adverse impacts on agricultural operations and the Agricultural System.

Lot Creation and Additional Residential Units

MFA is optimistic about the reconsideration of the proposed lot severance policies and are eager
to work with the government to balance the need for housing with the protection of agricultural
land without severances.

While MFA does not support further lot creation and severances, we do support Additional
Residential Units (ARUs) on existing farm parcels, and in rural hubs, hamlets and communities to
support our agricultural system. MFA would like to establish our support for additional dwelling
units subordinate to the principle dwelling on an agricultural parcel but do not support the
establishment of additional lot severances on these parcels.

In our previous submissions to the government regarding the PPS 2020, we have commented
that the PPS 2020 does not go far enough in protecting our finite agricultural lands. We have
recommended strengthening PPS 2020 in order to require fixed urban settlement boundaries and
policies requiring mandatory intensification within the existing built urban areas as well as
mandatory “greenfield” density requirements to better utilize infrastructure, improve the financial
viability of public transit and protect our prime agricultural lands from sprawl.

While MFA is supportive of additional residential units, we do feel there needs to be further
specificity in the policy. Our concerns include a lack of criteria for ARUs, insufficient consideration
for onsite infrastructure and servicing, inconsistency between policies on provincial guidance, a
lack of consideration for the distinctiveness of municipalities, and the exclusion of specificity
surrounding whether these policies apply to both farm and rural lots.

MFA believes that there should be additional consideration of a set of criteria for ARUs as well as
clarification on the extent of this policy. There is a distinct lack of inclusion for the type, size, scale,
and location of these proposed ARUs that needs to be addressed as well as the clarification on
whether this policy is exclusive to farm lots or includes rural lots as well.

Further, we are concerned that inconsistencies between policies on permitted uses in agricultural
lands could lead to the misinterpretation or unpredictable development and approval of ARUs.
Specifically, under section 4.3.2 Permitted Uses, 4.3.2.4 (principal dwellings) states that the policy
must be in accordance with provincial guidelines, however, 4.3.2.5, does not include this
provision. MFA believes that this exclusion in conjunction with the lack of criteria for ARUs could
result in development that does not align with our position that farming to produce food, fibre, fuel,
flowers and nursery stock is the best use for farmland.

Additionally, we must highlight the distinctiveness of municipalities across Ontario, both in their
landscape as well as their governance ability and priorities. No two municipalities are alike,
therefore flexibility within provincial level policies allows municipalities to address their local
concerns in accordance with provincial policy. MFA believes the Ontario government needs to
clarify the extent of provincial-level direction and as well as outline considerations and guidance
for onsite infrastructure and servicing.

MFA sees that opportunities to build more rural housing should be concentrated within, and
directed to, rural settlements and settlement areas as identified in APTG Policy and PPS (2020)
Policies 1.1 “Managing and Directing Land Use to Achieve Efficient and Resilient Development
and Land Use Patterns,” 1.1.3 “Settlement Areas,” 1.1.4 “Rural Areas in Municipalities.” Density
and intensification targets should be analyzed and identified in accordance with APTG
methodology and appropriately applied to rural settlements and settlement areas.

Within rural lands, MFA recommends that agricultural uses, agriculture-related uses, on-farm
diversified uses and normal farm practices should be protected and given higher priority as permitted uses under PPS (2020) Policy 1.1.5.2 and throughout Policy 1.1.5 “Rural Lands in
Municipalities.”

MFA previously requested that this proposal be applied to rural and smaller-town municipalities
within designated rural settlements and settlement areas. We acknowledge the servicing capacity
limits many rural communities in Ontario face, such as that with private water and wastewater
services. However, rural communities also need additional housing. There are opportunities within
existing smaller villages, hamlets and towns to increase density on parcels of land in the
settlement area that are adequate for servicing and more efficiently contribute to the rural tax
base. This would serve to eliminate the need for lot severances on agricultural lands while
providing increased housing options across Ontario.

MFA welcomes the opportunity to be a part of a potential group to establish best management
practices (BMPs) or regulations surrounding ARUs to effectively develop

Minimum Distance Separation

Ontario farmers value the MDS formulae as a proven means of separating livestock facilities and
permanent manure storages from neighbouring land uses, thereby reducing health and safety
risks and/or complaints from these neighbouring land uses arising from livestock/manure odours
and practices. MFA wholeheartedly supports the use of the MDS formulae and guidelines to bring
about adequate separation.

The MFA supports MDS, its rationale being to prevent encroachment by neighbouring non-
agricultural uses on livestock farms by providing sufficient separation between livestock uses and buildings and neighbouring non-agricultural uses and buildings to lessen the likelihood of odour
complaints as well as any health and safety risks or concerns.

The MFA also endorses the use of the MDS formulae to provide sufficient separation between
new or expanding agricultural livestock buildings and uses and neighbouring non-agricultural
buildings and uses, again to lessen the likelihood of odour complaints or health and safety risks
or concerns.

Employment Lands

In our submission to the Standing Committee for Bill 97, MFA cautioned against changing the
definition and policies for Employment Lands proposed in the Planning Act amendment in
Schedule 6 of Bill 97. We would like to maintain that the resulting impacts of reduced protections
for Employment Lands could result in increased pressure to utilize agricultural lands such as
Prime Agricultural Lands and Specialty Crop Areas for employment uses in the future as well as
put agricultural processing operations at risk.

Municipal Flexibility

MFA believes that the PPS should be used as a baseline and remove the provisions that limit the
flexibility of municipalities. As we have highlighted, municipalities vary across the province, and it
is MFA’s belief that municipalities should be allowed to be more restrictive within the local policy
so long as it is in accordance with provincial policy.

Agricultural Impact Assessment

While we are very happy to see that Agricultural Impact Assessment (AIA) is included in the
definitions, we do believe that an AIA must (not should) be completed under section 2.3
Settlement Areas and Settlement Area Boundary Expansions. We are pleased to see the
requirement for “avoiding, or where avoidance is not possible, minimized and mitigated as
determined through an agricultural impact assessment...” in section 4.3.5 Non-Agricultural Uses
in Prime Agricultural Areas. We are also very pleased to see the application of 4.3.5.2 applied to
Mineral Aggregate Extraction in Prime Agricultural Areas under 4.5.4.1.a. Avoiding impacts to
agricultural areas from mineral extraction is an important protection of Ontario’s limited agricultural
lands.

MFA is very pleased to see the requirement for an AIA or equivalent analysis for mineral extraction
in prime agricultural areas, yet we remain concerned there are circumstances in which “complete
rehabilitation to an agricultural condition is not required....” As established in 4.5.4.2. It is our
belief that an application to extract minerals in prime agricultural areas that cannot be rehabilitated
to an agricultural condition should not be approved on the basis that it does not meet the
conditions of that application.

Natural Heritage & Water

MFA believes that the Provincial Planning Statements should not remove the words “all municipal”
from section 4.2.1(e)(1). We believe that this section should remain: “Implementing necessary
restrictions on development and site alteration to: 1. Protect all municipal drinking water supplies
and designated vulnerable areas; ...”

MFA is pleased to see that the definition of “Wetlands,” as it currently exists in the Provincial Policy
Statement, 2020, has been retained.

MFA is pleased to see that the statement in Section 4.1.9 has remained across the versions of
the Proposed Provincial Planning Statement. However, to address potential conflicts between
Natural Heritage and Agricultural landscapes MFA recommends the inclusion of a provision that
gives priority to Normal Farm Practices.

We look forward to further engaging in future Natural Heritage policy discussions.

MFA notes the legend in Figure 1 requires updating to reflect the changes in section numbers.

We are concerned that combining A Place to Grow: Growth Plan for the Greater Golden
Horseshoe and the Provincial Policy Statement, 2020 would diminish the protections and support
for agricultural lands and community and therefore open the floodgates for a rash of developments
that run counter to our overarching philosophy of farmland preservation which is paramount to
our mission of “Farms and Food Forever.”

We request including greater specificity and guidance on these proposed policies as well as
greater consideration for agricultural land, operations and community.

MFA appreciates the opportunity to provide our feedback and agricultural perspectives on the
proposed Provincial Planning Statement. We look forward to working with the provincial
government and our municipal counterparts to protect Ontario’s farmlands as well as sustain
Ontario’s housing supply and communities.

Sincerely,

Jason O'Neil
President
Middlesex Federation of Agriculture