I strongly object to the…

I strongly object to the proposed residential lot creation policies for prime agricultural areas provided in section 4.3.3 of the revised Provincial Policy Statement. These lot creation policies offend all good planning principles.

Prime agricultural land is a finite resource in Ontario. Already, much of our most productive prime agricultural land has been lost to development. Further opening up prime agricultural areas to development will diminish the already limited supply of prime agricultural land, resulting in negative repercussions for our agricultural industry, food supply and food sovereignty. Once this resource is gone, we cannot get it back. You cannot grow food on concrete.

Moreover, most of our prime agricultural lands are in rural areas, which have limited employment options and limited health and social services. By increasing potential for residential development in prime agricultural areas, you are increasing the reliance on personal vehicles, as the owners of these new lots would most likely need to drive to work, to school and to access services. Not only does this contribute to CO2 emissions and climate change, it also puts increased pressure on rural roadways. Rural municipalities already struggle to maintain rural roads to an appropriate quality. Increasing residential development will only further deteriorate these roads and pass financial pressure and burden onto the municipality.

Increased lot creation in prime agricultural areas will no doubt also lead to increased farm and non-farm conflict. Meeting MDS setbacks is not enough to negate the complaints from the non-farm community about normal farm practices such as operating equipment, using chemical herbicides, and spreading manure. Drive any road during harvest season, and you will already see vehicles attempting unsafe passes, or expressing frustration with slow moving farm vehicles. Increased non-farm residency of prime agricultural areas enhances the risk of these complaints and conflicts, which threatens the longevity of the primary agricultural operation.

Further, not allowing municipalities to create more restrictive policies is an offense to local autonomy.

While I strongly object to any residential lot creation in prime agricultural areas, save and except for surplus farm residences under the existing policy, if the government MUST open up prime agricultural areas to residential lot creation I suggest the following amendments:

A maximum of ONE new residential lot may be created from an parcel of land as it existed as of January 1, 2023 where the existing parcel is AT LEAST 40 ha in area
The new proposed lot shall be limited to a MAXIMUM size of 1 acre. I note that the existing language regarding “minimum size required to accommodate the use” is not strict enough. You are guaranteed to receive requests for estate lots of 2-5 acres, where the rationale for the minimum size is based on the size of a house, pool, etc.
It must be demonstrated through an Agricultural Impact Study completed by a qualified professional that the lands proposed to be severed have not and cannot feasibly be used for agriculture due to site-specific constraints (i.e., presence of natural features), subject to the natural heritage policies of the PPS (which I note are still outstanding).

I would note that studies have been completed which demonstrate that the solution to our housing crisis is NOT opening up more land for development. We have enough land already designated for development and do not need to further attack our prime agricultural areas. It is a simple concept - we need to build UP not OUT. We need to build housing which is affordable (guaranteed that single detached lots in prime agricultural areas will not be - this will be “prime” real estate). We need to build housing that is within walking distance of employment, recreational and health, or where public transit can be used - so that households of all incomes can access all services. Again, opening up prime agricultural land is certainly NOT required to build more homes, and does not make sense if we want properly planned communities. Lets not repeat the planning failures of our past.