July 13, 2018 Michele…

July 13, 2018

Michele Doncaster
Environmental and Land Use Policy Unit
Ontario Ministry of Agriculture, Food and Rural Affairs
1 Stone Road, 3rd Floor, NW
Guelph, ON N1G 4Y2
Dear Ms. Doncaster,
Re: Draft Agricultural Impact Assessment Guidance Document
1. AIA Guidance Document – Overall Layout of the document
a) Comment
The AIA Guidance Document provides good information regarding the policies that need to be addressed, when an AIA is required and what it is to include for developments proposed in prime agricultural areas or potentially impacting farm operations within the agricultural land.
However, in my opinion, the document is too long. It could be substantially shortened by separating the different types of land use applications into standalone appendices. For example, the document could be reduced to 15-20 pages in which there is an introduction that includes the purpose of the document, a general statement about what an AIA is and discussion on why it is needed, where and under what circumstances an AIA is required (reference Provincial land use policies and types of development subject to the AIA). It should also include a discussion of when the AIA should be completed and by whom (Qualified Person).
There are four main types of development for which an AIA is required. These include:
• Settlement boundary expansion proposals;
• Aggregate extraction proposals;
• Infrastructure projects; and
• Proposals for Non-agricultural land uses within prime agricultural areas.
The requirements for an AIA differ for each of these land use proposals and rather than including within the body of the document, the methods used to complete an AIA for each type of development application should be included within an appendix. This way the proponent of a development and/or the qualified person preparing the AIA can go directly to the relevant appendix to understand what is required to be included in the AIA. This saves the reader from having to read the entire document to determine what needs to be in the AIA and what doesn’t need to be included.
For example, for settlement area expansion, the need to complete a detailed soil survey which includes a soil sampling procedure designed to restore lands to an agricultural condition is not required as it would be for an above water table aggregate extraction proposal. The current layout of the guidance document requires the reader to go through the entire document to understand what the AIA is to include. The current format has the potential to add confusion as to what is required and potentially adding to the cost of completing an AIA for unnecessary work.
There also should be a Definitions section included within the guidance document.
2. AIA Guidance Document - Table of Contents (pg. 2)
a) Suggestion
A Definitions section for terms used within the Guidance Document should be included to ensure user is able to properly interpret and understand the document and its requirements.
3. AIA Guidance Document - Section: 1.0 Overview
Section 1.8 Qualified Professional(s)/Practitioner(s)(QPs) (pg. 10)
“Qualified Professionals’ qualifications should include knowledge in:”
a) Suggestion
When referring to Qualified Professionals’ qualifications, replace “should include” with “must have”.
4. AIA Guidance Document - Section: 1.0 Overview
Section 1.8 Qualified Professional(s)/Practitioner(s)(QPs) (pg. 10)
Third Bullet - “Canada Land Inventory (CLI) classifications of capability for agriculture assessment and, where relevant a practical understanding of soil science, including the ability to review technical information from non-agricultural disciplines and assess”
a) Suggestion
Replace wording with the following:
“Canada Land Inventory (CLI) classification system for assessing agricultural land3 and, soil science and soil mapping procedures4, and the ability to review technical information from non-agricultural disciplines (e.g., hydrology, hydrogeology, geotechnical, transportation, etc.) and assess its relevance and utility in identifying potential agricultural impacts”.
Insert Footnotes at bottom of Page 10:
3Classifying Prime and Marginal Agricultural Soils and Landscapes: Guidelines for Application of the Canada Land Inventory in Ontario; Ontario Ministry of of Agriculture and Food, 2004
4The Canadian System of Soil Classification; Agriculture and Agri-Food Canada, 1998 Field Manual for Describing Soils in Ontario; Ontario Centre for Soil Resources Evaluation, 1993

b) Suggestion
Consider also referencing:
A Soil Mapping System for Canada; Revised; Agriculture Canada, 1981
Agricultural Drainage Systems Mapping, OMAF, 1993
c) Suggestion
Insert bullet (fourth bullet) with the following:
“An ability to understand and recognize potential impacts to farm operations, agricultural resources, infrastructure and investments, and many of the components of the agri-food network, and”.
5. AIA Guidance Document - Section: 1.0 Overview
Section 1.8 Qualified Professional(s)/Practitioner(s)(QPs) (pg. 10)
Second Paragraph – “The QP(s) should have demonstrable experience evaluating and assessing agricultural impacts and university or college degree(s) in one or more of the following: agriculture, soil science, geoscience, landscape architecture, resource management-related disciplines, environmental-related disciplines, agricultural engineering, or land use planning.”
a) Suggestion
If OMAFRA is to include disciplines such as Landscape Architecture as a Qualified Professional then the wording should be:
“The QP’s must have demonstrable experience evaluating and assessing agricultural impacts and evaluating soil agricultural capability of soils; and a university degree or college diploma/degree in one or more of the following:
• Agriculture;
• Soil science;
• Geoscience;
• Landscape architecture;
• Resource management-related disciplines.”
b) Suggestion
I question whether landscape architecture should be included on this list.

6. AIA Guidance Document – Section: 1.0 Overview
Section 1.8 Qualified Professional(s)/Practitioner(s)(QPs) (pg. 10)
First sentence, last paragraph on page 10 – Depending on the nature and potential impacts of the proposed development, it may also be useful to involve professionals with expertise in other areas (e.g. micro-climatology, hydrogeology, ecology, agricultural engineering, accounting and economics) to obtain an appropriate breadth of relevant skills and experience.

a) Suggestion
Should consider including land use planning as another profession which could provide support for the AIA (for example, to assist in identifying secondary study areas, suitable alternative site locations and edge planning techniques and their long-term consequences for community planning).
7. AIA Guidance Document – Section: 1.0 Overview
Section 1.8 Qualified Professional(s)/Practitioner(s)(QPs) (pgs. 10-11)
Second sentence, last paragraph on page 10 – “All professionals contributing to the AIA should have a relevant academic base, Ontario experience, and preferably membership in a professional organization with a code of ethics and ongoing professional development requirements (e.g. a professional agrologist (P.Ag.) registered with the Ontario Institute of Agrologists, a registered professional planner (RPP) who is a full member of the Ontario Professional Planners Institute, a professional geoscientist (P. Geo) who is a practicing member of the Association of Professional Geoscientists of Ontario, a professional engineer (P.Eng.) licensed by Professional Engineers Ontario in a discipline relevant to work completed for the AIA, or a landscape architect who is a full member of the Ontario Association of Landscape Architects.”
a) Suggestion
Again, I’m not sure the inclusion of the Landscape Architect profession is appropriate.
8. AIA Guidance Document - Section: 2.0 Technical AIA Guidelines
2.2 AIA Study Components - 1. Introduction – Description and Location (pg. 13)
“For a settlement area boundary expansion, include the following:
A description of the proposed settlement area boundary expansion and details on how and why alternative location(s) have been evaluated, the rationale for the selected location(s) and its extent and include maps. In the GGH, locations are to be evaluated across upper- and single-tier municipalities. Once alternative location(s) have been selected, maps of appropriate scale and detail for each of these areas i.e. study area(s), should be provided. Evaluating alternative locations should include information on applicable land use designations and zoning, and a description of the prime agricultural area designations or, if applicable, the agricultural land base, being considered for redesignation.”
a) Suggestion
It is relatively simple to identify alternative sites for settlement boundary expansion projects. Municipalities typically identify the study area(s) for settlement boundary expansion and alternative sites are identified and assessed based on a range of agricultural and non-agricultural criteria.
However, the identification of alternative sites can be somewhat subjective for other types of developments (e.g., limited non-agricultural development within a prime agricultural area).
Pre-consultation with municipalities and/or the Ministry should take place to approve the proposed alternative sites before study begins. This will ensure that delays in the completion of the AIA are minimized.
Further guidance on how to identify alternative locations, the appropriate scale (e.g., regional vs site specific) of evaluation, and examples of rationale for inclusion or discounting of alternative sites should be included.
9. AIA Guidance Document - Section: Acknowledgements (pg. 110)
The AIA Guidance Document acknowledges the contributions of MacNaughton Hermsen Britton Clarkson Planning Limited (MHBC) for their work for the ministry which helped inform various components of the document.
a) Suggestion
Colville Consulting Inc. should also be included in the acknowledgments as the work completed by MHBC for the Province was done in association with Colville Consulting Inc.