Preserve the Escarpment’s…

Preserve the Escarpment’s Response to An application to amend the Niagara Escarpment Planning and Development Act, R.S.O. 1990
Ministry of Natural Resources and Forestry
ERO number: 019-6425

Introduction

Preserve the Escarpment (PTE) is pleased to respond to the proposed application to amend the Niagara Escarpment Planning and Development Act, R.S.O. 1990. In general, PTE supports nearly the all of the amendment, however we strongly oppose a change that would effectively expand on-farm diversified to any land. The specific change we oppose is;

Part 1 Land Use Policies Permitted Use Part 1.4.3 Escarpment Protection Area, Permitted Use 3 is amended as follows:
2. Agriculture-related uses and on-farm diversified uses., (in prime agricultural areas) <- to be deleted

Because it would open developments that prioritize secondary use instead of agriculture first, such as attractions and events. This change in the Niagara Escarpment Commission’s proposal to expand on-farm diversified use (OFDU), risks supporting primary agricultural and rural development. Our position aligns with the Ontario Federation of Agriculture who stated in the NEC staff report;

“The OFA and its member groups have made submissions in support of a proposed amendment to the NEP Escarpment Protection Area Part 1.4.3.2 respecting OFDUs and ARUs being permitted in prime agricultural areas only.”

Preserve the Escarpment and its Role

Preserve the Escarpment is an over 300-member resident group that formed out of concern for the development of an attraction that runs contrary to the Niagara Escarpment Plan. Its objective is rooted in a secondary use of principal agriculture, not supporting a principal agricultural operation. The development, a new lavender attraction, called Fennario, puts forward a business model predicated on selling tickets and attracting tourists, which will not be controllable. This is a prime example of secondary use being prioritized rather than primary farming or agriculture.

Negative Impacts of Expanding OFDUs

While expanding on-farm diversified use to any land may sound like a positive development, there are several potential negative impacts that should be considered.

1) Loss of farmland: On-farm diversified use involves converting land into non-agricultural uses, the proposed amendment seeks to further this by extending OFDU’s to non-prime agricultural land. Overall reducing the amount of land available for food production. This can have long-term consequences for food security and sustainability.

2) Environmental Impacts: Non-agricultural activities on farmland can have negative environmental impacts, such as increased water usage, soil erosion, and pollution. These impacts can affect the health of local ecosystems and wildlife.

3) Traffic and Congestion: On-farm diversified use nearly always involves increased traffic and congestion in rural areas, which can impact rural residents and their businesses. A by-product of this can also lead to increased pollution.

4) Economic Impacts: Expanding on-farm diversified use to any land can have negative economic impacts on traditional farming activities. For example, if farmers start to rely more on secondary non-agricultural activities for income, they may reduce their focus on traditional farming activities. This can have negative consequences for the agricultural sector and Ontario’s food security.

5) Counteract Regulatory Purpose: A qualification for On Farm Diversified Use is that it is secondary to the principal agricultural use of the property. Expanding OFDU’s to non-prime agricultural land risks proponents bringing forward proposals that prioritize secondary use, like creating an attraction or event, then performing some periphery agriculture to achieve it. Rather than the regulations intent of encouraging the development of primary agriculture and giving those proponents the option to develop something secondary to diversify the property.

Conclusion

While expanding on-farm diversified use to non-prime agricultural land may seem like a positive development for rural areas in Ontario, there are several negative impacts that must be considered. This proposed expansion of OFDU’s goes against their initial intent, does not encourage primary agriculture, resulting in a loss of farmland, negative environmental impacts, increased traffic and congestion, and negative sectoral economic impacts. As such, on-farm diversified use, like the OFA states, should only be on prime agricultural land and this change to remove that language should be rejected.