August 3, 2023. Provincial…

August 3, 2023.

Provincial Land Use Plans Branch
13th Floor, 777 Bay Street, Toronto, Ontario M7A 2J3 Canada
growthplanning@ontario.ca

Re: ERO 019-6813 Review of Proposed Policies Adapted From “A Place to Grow To Grow and Provincial Policy Statement to Form a New Provincial Planning Policy Instrument.

Dear Provincial Government,
I am an independent commentator. All the words and ideas herein contained are my own and are not meant to reflect those of any Organization or Committee that I may now or ever have served on.
Of all the laws we are subject to the two most important are the Law of Gravity and the Law of Unintended Consequences. It is important to understand that unintended consequences can plague us in perpetuity.
Agricultural land is a scarce and precious non renewable resource that must be protected for the present and future long time use. The Government should be doing a lot more and should be using the PPS as an instrument to better protect agricultural land.
Farmland is not just empty land that no one is using. It is not under taxed wasteland as some urban politicians have described it. It is vital to maintain our food supply. Agriculture is a major economic engine in Ontario.
Residential encroachment and land fragmentation are major problems in Ontario. The revised PPS will very likely make each of these problems worse. Frequently new non farm people clash with farmers. In our area we have experienced theft, vandalism, and arson.
It is understood that we need more housing. Laying waste to Ontario’s farmland is not an acceptable solution. There is more than enough land set aside already to achieve the Province’s stated goal of 1.5 million residential units so those lands should be developed first. We need more intensive development and increased building heights to house more people in fully serviced areas. The rules must compel municipalities to do that. We also need to vote wisely in the next Federal Election.
Unserviced development and lot creation in rural areas must be discouraged. The boundaries of settlement areas including Cities, Towns, Hamlets, and Villages must be made rigid and permanent. We need to grow up not out.
It is understood that there can now be 3 residential units on all classes of land except Heavy Industrial. First that threatens Employment Lands. Secondly most existing residents will not do that because the cost is prohibitive. Developers who want income properties might do that.
As a farmer I have no interest in building 2 more residential within, attached, or in close proximity to my current dwelling unless I can bring in a manufactured (park) home that can be removed when no longer needed. Most municipalities would not allow that unless the Province amends Legislation to force them. Multiple houses on the same lot could create serious legal issues in the event of a business or personal relationship breakdown. Money would be better spent on more land, machinery, barns, and storage for grain, forage, and machinery.
Many farms contain multiple parcels. Since a dwelling could always be built on an existing lot of record it follows that on each individual parcel anyone could build 3 residential units within, attached, or in close proximity to each other.
The PPS allows a surplus dwelling to be severed provided the remnant lands are rezoned to prevent the erection of a dwelling in perpetuity. The revised PPS allows for up to 3 lots with dwellings to be severed off using the Surplus Dwelling Provision. This is a big problem. Each of the severed lots can now create 3 residential units within, attached or in close proximity to each of the houses for a total of 9 residential units where there was once only one. It is recommended that the Surplus Dwelling Provision should be limited to ONE parcel with the 3 residential units on it. The alternative would be not to allow a surplus dwelling severance on any property with more than one dwelling on it.
Local Planning Authorities usually get around MDS1 using the Committee of Adjustment for a Minor Variance to get dwellings built near livestock facilities. Conversely MDS2 is applied to the nanometer when siting livestock buildings near existing houses.
I want to close on a positive note. A previous Proposal contained provision to sever three residential lots from an agricultural land parcel. It is very much appreciated that the Government responded to our Community’s concerns and removed it. It is good to know that the Government listened. It gives one hope that the Government will once again listen and might fix the imperfections of this Proposal.
Agricultural land is a scarce and precious non renewable resource which must be protected for the present and the future.
Thank you so very much for the opportunity to comment.