Re: Record of Site Condition…

Re: Record of Site Condition Regulations

Toronto Urban Growers (TUG) is a member based network of urban farmers, gardeners, businesses, organizations, institutions and networks that aims to increase availability of healthy, organic and sustainable food grown, processed and sold in Toronto. We have worked in conjunction with the City of Toronto to develop new sites for urban agriculture in Toronto, and have unfortunately seen some projects fail due to the onerous approvals processes that are beyond the resource capacity of both the City and community organizations.

Given that urban food production is a critical tool for offsetting the impact of poverty on urban communities, increasing local food security and building the green infrastructure needed to combat climate change, TUG supports the Toronto Public Health call for a process to streamline approvals for urban gardens as below.

The Importance of this Initiative The Ministry's site assessment processes currently present a barrier to initiating community food projects, particularly in low-income communities where the need for fresh produce is greatest. This initiative could not only help to reduce a significant, if not, insurmountable barrier to urban food growing projects, and could also help the Province meet two of its keystone policy directives: poverty reduction and climate change mitigation.

The Barrier There is increasing interest in community-led urban food growing projects. These types of projects are often in priority neighbourhoods where access to food and green space are limited and incomes are typically low. For these projects a Record of Site Condition (RSC) would be required. This requirement is based on shift from a less to more sensitive land use (i.e., from commercial or parkland to agricultural land use) triggering an expensive and time consuming site assessment and regulatory approval processes. The resources required to meet this regulatory hurdle exhaust the resources available for getting these projects started and significantly impair the creation of critically needed community food initiatives. Proposed Solution 1.Streamlined and Tailored Approach for Urban Community-Led Food Growing Projects As part of initiatives to innovate, the Ministry developed a Tier II site assessment approach to streamline RSC assessments for low risk, standardized sites. Unfortunately, this process does not include key risk assessment and risk management assumptions that are specific to urban food growing projects, for instance, non-permanent structures (i.e., no indoor air inhalation pathway), no groundwater consumption, no livestock production and above-grade container gardening as a risk management approach. The Ministry could consider a streamlined and tailored approach to assessing sites for the purposes of small scale, community-based urban food growing projects, analogous to the Tier II streamlined site specific risk assessment approach. Assumptions that are tailored and standardized to urban food growing projects could be built into the approach, significantly simplifying the process to assess and manage potential risks while maintaining health objectives. 2.Expedited Review Process An expedited Environmental Approval Site Registry (EASR) process is already in place for other low risk sites. In these cases, site assessments are conducted and signed off by a QPRA and filed on a transparent environmental approval site registry for automatic approval. The Ministry could create an analogous provision for urban food growing projects. This provision would allow for an expedited review process facilitated by the local district Ministry offices. 3.Finding a Solution in Time for the 2018 Growing Season Given the urgency for improving access to good nutritious food, communities cannot wait another growing season for access to food grown in their own food growing projects. The Ministry could initiate a working group to quickly identify how to leverage existing Ministry processes to develop an approach that could be ready by January of 2018. Under this timeline projects will be able to go through the site assessment and approvals process in time to break ground in the spring 2018.

[Original Comment ID: 209846]