COMMENTS ON PROPOSAL OF PPS…

COMMENTS ON PROPOSAL OF PPS TO REPLACE EXISTING PPS
AND A PLACE TO GROW: GROWTH PLAN FOR GREATER GOLDEN HORSESHOE

RESPONSE TO SPECIFIC QUESTIONS LISTED:
Policies included from PPS and A Place To Grow Including Planned Implementation
4.3.Agriculture
As farmers trying to farm in a ‘prime agricultural area’, there are MANY CONCERNS WITH THE
PROPOSED CHANGES TO THE PROVINCIAL POLICY STATEMENT:
4.3.1 General Policies for Agriculture
1-3 ‘Encouraging’ municipalities to use an agricultural systems approach based on provincial
guidance to maintain and enhance a geographically continuous agricultural land base, eliminating the
requirement to use the provincially-mapped Agricultural Systems Approach is A MISTAKE for many
reasons:

a. The intent of the Growth Plan was to refocus on balancing growth with agriculture and
OMAFRA has spent significant time and resources (at our expense as taxpayers!!) to
determine which areas have the Prime Agricultural Lands (Class 1-3 for specialty crops)
AND for the first time there is recognition for the need for Classes 4-7 to farm effectively
(these lands are still used for crops AND for pasture for cattle – ALL of which is
necessary to farm!) REQUIRING MUNCIPALITIES TO PROTECT SPECIALTY CROP AREAS IS
NOT SUFFICIENT AS CLASS 4-7 FARMLAND ESSENTIAL FOR FARMING!!!!!!!!!!!! This was
FINALLY understood in the Provincially-Mapped Agricultural Systems Approach.
Removing this requirement places agriculture at risk in municipalities where the
protection of agriculture is not valued.
b.

4.3.2.Permitted Uses
1. On-Farm Diversified Uses (OFDUs) should have more strict criteria, and should ‘benefit from
being on a farm’. The province’s attempt with On-Farm Diversified Use allows businesses to be run on
farms that DO NOT BENEFIT FROM BEING ON FARMS with disastrous results as follows:
 Results in more traffic on narrow rural roads which decreases safety for farmers on roads,
interferes with timely access to crops (which is time-sensitive due to weather) – resulting in Loss
of crops A VISCIOUS CIRCLE WHICH WILL RESULT IN FARMERS OUT OF BUSINESS AND ONTARIO
NO LONGER ABLE TO PRODUCE ADEQUATE FOOD
 Businessmen purchase farms that ‘farmers who farm for a living’ can no longer afford. The ‘real
farmer’ rents the land – creates ‘farming income’ for the owner/businessman to qualify as a
farmer – essentially allowing ‘businessmen to create a farm on which to run a business!!” This is
identified as a loophole in University of Guelph professor Dr. Wayne Caldwell’s “Guidelines on

Permitted Uses as a Tool to Achieve Farmland Protection, Farm Diversification and Economic
Benefits: Assessing effectiveness and identifying best practices”.
 Businessmen who come out to the country to run their business off a farm are building
‘agricultural buildings’ in which to house these businesses prior to making application for On
Farm Diversified Use – they get breaks on taxation, permits etc when the intent is not
agricultural (in hindsight)
 Businessmen running OFDU businesses on farms are not paying the same taxes and do not have
the overhead of their competitors in commercial areas – puts these people out of business and
does not make sense in terms of employment opportunities.
 The government needs to reassess ‘who is a farmer’ ; the current $7,000 gross income
(established in the 1970s) has not kept up with inflation (which now would equal approximately
$58,000) and is too easy to achieve. As a result, municipalities are not getting the same tax
payments (as these ‘farmers’ are not actually farming for a living, but they get the same tax
breaks as the farmer who does farm for a living). Consequently, municipalities cannot maintain
our roads and other infrastructure as they do not have sufficient money!
 Results in customers driving to the country for businesses that should be in urban or settlement
areas – causing more emissions which affect climate – which then affect ability to grow crops –
VISCIOUS CYCLE!!! AND more cars on these roads, who meet the farmer at the top of a hill –
farmer killed as no protection while on a tractor (THIS IS HAPPENING EVERY DAY!!) When we
lose another farmer, we lose the farm production!!
 OFDUs need to be analyzed in terms of intent! The province allows almost any ‘business’ to be
an OFDU – not recognizing that a business NOT relating to AGRICULTURE will bring in more
income than farming! FARMING IS HARD WORK – LONG HOURS, LARGE EXPENSE FOR NO
GUARANTEE OF GOOD CROPS DUE TO CLIMATE CHANGE! When an OFDU is making money,
why would a farmer continue to farm?? IT is ACTUALLY PULLS FARMERS AWAY FROM FARM
INCOME GENERATION – TOO MANY RISKS COMPARED TO A NON-AGRICULTURAL BUSINESS!
 OFDUs should support the agriculture and/or agri-tourism industry and BENEFIT FROM BEING
ON A FARM!
4.3.3 Lot Creation and Lot Adjustments
More residential lots should NOT be allowed in prime agricultural areas:
 Promoting an agricultural systems approach is not possible if houses are scattered in among
farmland. Farmers can no longer afford farms! They have to rent land and consequently are
consistently on our rural roads with large equipment (This is a MAJOR CHANGE since the days
when farmers could make a living on their ‘home farm’). These roads are narrow and not safe
for additional residential traffic. THE ABILITY TO FARM NEEDS TO BE PROTECTED AND
MINIMUM SEPARATION DISTANCES BETWEEN LIVESTOCK OPERATIONS AND HOUSING IS ONLY A
SMALL PART OF THE WIDER CONSIDERATIONS WHICH MUST BE IN PLACE FOR FARMERS TO
CONTINUE TO FARM IN THESE PRIME AGRICULTURAL AREAS!
 The current Agricultural Impact Assessment DOES NOT FULLY COVER ALL IMPACTS TO
SURROUNDING AGRICULTURAL OPERATIONS!!!!
 Protecting specialty crop areas (Class 1-3 land) is not sufficient, as classes 4-7 also required for
farming. There are many crops that can be harvested on Class 4-5, while Class 6-7 land is good
for pasture. All of this needs to be balanced.

 Reference to the need for Agricultural Impact Assessment is NOT SUFFICIENT! Analysis of
minimum distance separation does NOT take into account the impact on road use, increased
density where people are not familiar with cattle – go into fields and disturb cattle (and could be
hurt!), ride ATVs and noise/backfiring scares cattle and they run through fences, to name just a
few!
 Our rural road currently has 62 residential homes in a 2.6 km stretch of the road. There is still
space for more as some farmers did not sever lots when this was allowed years ago. HOWEVER,
with the lack of farm income, this is TOO TEMPTING AS A MEANS FOR A FARMER TO PAY DOWN
DEBT!! We actively farm for a living and could benefit from the sale of lots off our farms – BUT
THIS IS WRONG! We cannot get the land back and this will become more of an issue in future
years when our current agricultural land will not support crop growth due to the
disappearnance of the carbon in the soil. AND THIS GOVERNENT IS DOING NOTHING TO
SUPPORT SUSTAINABLE FARMING (rotational, no-till crops for example – to stop erosion and
enrich soil - and with decreased fertilizers and weed spraying) – the farmer doing this gets the
same price for his crops as those who do not, but this typically results in less crops and there is
NO FINANCIAL INCENTIVE FOR FARMERS TO FARM IN THIS WAY TO SAVE THE LAND!
 These additional houses also increase the risk of climate change to farm practices, due to
greenhouse gas emissions with people driving out to the country and then having to drive into a
town for all of their personal, shopping and business needs. Houses should be congregated in
settlement areas!!
 Specifying that agriculture should be the ‘principal use of the existing lot’ is a MISTAKE. This is
taking up good farmland! Lots should only be allowed on farms IF THEY ARE NATURALLY
SEPARATED FROM THE REST OF THE FARM AND NOT BEING USED TO PRODUCE CROPS, GRAZE
CATTLE ETC. (Eg. A piece of property that is separated by a stream or wetland, and CANNOT BE
ACCESSED FOR FARMING! And – even under these conditions – NO MORE THAN ONE LOT – and
ONLY IF CANNOT BE USED FOR AGRICULTURE!!

Policy Direction for Large and Fast-Growing Municipalities and Other Municipalities
Balance housing with resources:
1. Require municipalities to prepare for the impacts of a changing climate and develop approaches
to reduce greenhouse gas emissions and improve air quality.

i. Putting subdivisions outside of towns means driving is required for ALL
excursions
ii. Many people want the downtown experience, yet municipalities are building
OUT instead of UP.
iii. Building OUT means increased use of vehicles for transportation as
residents cannot walk or take public transportation to town
activities/entertainment
iv. More emphasis should be placed on 15-minute communities - where
jobs, retail and other amenities are within a 15-minute excursion of one’s
residence (preferably by walking or biking) – to reduce urban sprawl, cluster
neighbourhoods (instead of lots spread out all over agricultural areas) – and

ensure living, working and day-to-day needs such as groceries, drug stores and
restaurants are all within this area
v. The impact of this on climate results in weather conditions which mean farmers
LOSE money every year – insufficient rain for crops to grow; too much rain and
crops rot in field, extreme winds which damage crops – every year the farmer
has more debt because the money they spend on seed, fertilizers, etc is lost
when those crops do not come to fruition!
2. 2.9 Energy Conservation, Air Quality and Climate Change
a. Climate change is a very small portion of this new PPS (Section 2.9.1 ONLY) to cover
these 3 VERY IMPORTANT CONCEPTS!! This is especially true, given that the A Place To
Grow Document was very serious about saving energy, improving air quality and
addressing climate change.
b. MZOs have been executed in communities where people will work over an hour away –
with no transit options – HUGE impact on greenhouse gas emissions with all of this
driving!! Transit should be available BEFORE houses are constructed!!
c. This very small section looks like a ‘token offering’ in the midst of a PPS that proposes
taking more land from agriculture

Proposed Policies to Generate Housing Supply (including range and mix of housing options)
Generate An Appropriate Housing Supply
1. Identify fast-growing municipalities with specific direction to plan strategically for growth:
a. MZOs are mandating which communities should be ‘fast-growing’ without taking into
account the lack of infrastructure which includes:
i. Insufficient day care spots (we had over 800 children on a list for Day Care
before the province mandated that 7000 houses would be built here)
ii. Inability of current hospital to accommodate more people; our hospital is small
and will not accommodate this growth, especially with vacant positions
iii. Regional Health Centre is almost an hour away and dealing with the
same issues of expansion; built 10 years ago and already can’t accommodate
patient needs
iv. Schools not available where housing occurring (on the outskirts), yet
older schools available in downtown area
v. AGREE – with residential intensification (Section 2.2.1), in downtown areas
(where schools are also sitting empty!), ESPECIALLY in repurposing existing
commercial and institutional buildings for residential use; ensure transit
availability and PREVENT URBAN SPRAWL to decrease greenhouse gas emissions

2. Provide a range of housing
a. There is opportunity to put new housing in current ‘downtown’ area – where homes are
run down – and schools are available; yet building all occurring on outskirts
b. Majority of housing is single- family homes, all requiring vehicles to access (how does
that take into account the aim in A Place To Grow to decrease greenhouse gas
emissions?)

3. Provide/allow for more residential development in rural settlements and multi-lot residential
development on rural lands defined in PPS as “lands which are located outside settlement areas
and which are outside prime agricultural areas”
a. Without the implementation of the provincial mapping developed by OMAFRA, rural
lands are in the middle of agricultural areas and this impacts farming practices
4. Require municipalities to permit more housing on farms, including residential lot creation
a. HUGE MISTAKE - as this brings housing into the middle of farm areas which creates
more problems for farmers – farms need to be enveloped in ‘active farming
communities’ and bringing in more traffic and complaints will be the final straw for
farmers already struggling – they will toss in the towel!

Proposed Policies on Conservation of Agriculture, Aggregates, Natural and Cultural Heritage Resources
This proposed PPS is DETRIMENTAL to ALL of these areas:
 More land proposed to be taken from agriculture
o Lot creation on farms is a problem, given the extent to which this was allowed back in
the 1970-s. Our road has 62 houses in 2.6 km – on a narrow road, with no sidewalks.
People walk on road – unsafe! It’s a farming community and farming is hampered by
traffic; unsafe at top of hills where farm equipment is wide and cars travel too fast
 Wetlands have NOT been protected under this current government – MZOs have reduced our
wetlands, especially in the areas surrounding Toronto
Proposed Policies on Planning for Employment
 Our area’s PRIME EMPLOYER IS AGRICULTURE, yet this PPS takes more land from agriculture to
bring in housing for people FOR WHOM WE HAVE NO JOBS!!! And this was dictated by a MZO –
which shows no respect for our local Council or City employees decisions (or those citizens who
elected them!!)

Other Barriers/Opportunities for accelerating development and construction
Page 13 – notes “Housing must be built in the right places so that Ontario’s vibrant agricultural sector
and sensitive areas will continue to form part of the Province’s economic prosperity and overall identity.
Growth and development will be focused within urban and rural settlements that will, in turn, support
and protect the long-term viability of rural areas, local food production and the agri-food network.”
This sounds good – but is NOT THE REALITY and this PPS has too many loopholes for this to happen!
 Taking up 200 acres of prime farmland in a community that does not have jobs, schools, day
care spaces or hospital beds to support 7000 new homes shows a lack of foresight which does
NOT protect agriculture NOR protect the planet when residents will drive over an hour to jobs in
larger cities

 All of this driving, and the resulting greenhouse gas emissions will further drive climate change –
AND NOT SUPPORT THE LONG-TERM VIABILITY of local food production and the agri-food
network.
 Sensitive areas have NOT been protected – wetlands have been forced into housing through
MZOs with no foresight!
 Housing should be intensified in URBAN settlement areas – NOT RURAL for many reasons
identified earlier!
 We are at a CRITICAL JUNCTURE with climate change – farmers are NOT making a living on farms
and the government is not supporting them with financial assistance to change farming
practices to protect the land!
 Allowing ANYTHING on a farm, as an On-Farm Diversified Use screams “You cannot make a living
farming” – we should be providing assistance to farmers which will then help to reverse climate
change AND encourage young people to get into the business. It is currently VERY HARD WORK
WITH DISCOURAGING RESULTS – this will not attract young farmers!
 PC government focus on constantly increasing production of food (as that’s the only way
farmers can make money – so everything has to be produced faster and in larger quantities,
which means more pesticides and fertilizers) contradicts the need to protect the land and
conserve the carbon in the soil – FARMING IS MORE THAN A BUSINESS! IT’s A RESPONSIBILITY
TO PROTECT THE LAND AND NURTURE FUTURE FARMING GENERATIONS – See “Tackling the
Farm Crisis and the Climate Crisis: A Transformative Strategy for Canadian Farms and Food
Systems. Tackling the Farm Crisis and the Climate Crisis | National Farmers Union (nfu.ca)
 The Implementation Procedures for the Agricultural System in Ontario’s Greater Golder
Horseshoe Implementation Procedures for the Agricultural System in Ontario’s Greater Golden
Horseshoe was designed to support A Place to Grow in developing Agricultural Stability –
ESSENTIAL FOR FUTURE GENERATIONS!!! The focus of this PPS is on business and construction –
and CAN NEVER BE UNDONE! We need to BRING THIS BACK!!!!!!!!!!!!!!!!!!!
 2015-11-18-Farmland_at_Risk-highres_WEB_(1).pdf (d3n8a8pro7vhmx.cloudfront.net)
Farmland has been identified as ‘at risk’. This document (Farmland at Risk: Why land-use
planning needs improvements for a healthy agricultural future in the Greater Golden Horseshoe)
was prepared by the OFA indicating the key to a robust agricultural industry is the protection of
the land base on which to farm and carry out farm-related activities. This was done at a time
when our Ontario Government believed in “taking important steps to preserve farmland and
environmentally significant areas in the GGH! It followed the Greenbelt Plan (2005) designed to
help preserve agriculture – WHY IS ALL OF THIS IMPORTANT RESEARCH BEING IGNORED????