The Municipality of South…

The Municipality of South Huron has the following comments with respect to:
1. Agricultural Lot Severances:
Residential lot creation in prime agricultural areas has been discouraged since the Countryside Planning/Foodland Guidelines were issued by the Province of Ontario in the 1970s. The purpose of this provincial-wide planning document was to ensure the protection of prime agricultural land for food production.
South Huron is a prime agricultural area and agriculture is extremely important to the economy and the production of food. For over 40 years, South Huron and its former municipalities have had strong Official Plan policies protecting this agricultural resource and directing non-agricultural related development to settlement areas. Staff and Council recognize the need for housing in the agricultural area and have allowed for on-farm housing for farm labour. The Province’s proposal to allow for scattered residential development through lot creation does not further the interests of the agricultural industry.
The opening up of scattered residential lot creation in our prime agricultural area may:
• increase conflict with modern farming practices,
• increase MDS restrictions on the placement of new barns;
• reduce the number of units being built in settlement areas where municipalities have invested substantial funds on services (hard and soft),
• result in lost opportunities for infrastructure efficiency in settlement areas;
• increase the demand on municipalities to provide enhanced rural services (e.g. more frequent snow plowing, road maintenance, garbage collection, emergency services, etc.); and
• ring serviced settlement areas with unserviced residential development making it more difficult and costly for future settlement area expansions and extension of services.
It is requested the Province provide clarification on the criteria in the policies for creating new residential lots; for example: what is considered to be adjacent to a non-agricultural use and what are lower-priority agricultural lands. It is unclear if this is limited to adjacent to Settlement Areas, Recreational uses and Institutional uses, or does it open it up for new residential lots next to all existing residences including farm residences and those that have been severed as surplus. And further, does this also allow residential lot creation on any area that a farm considers lower priority or inconvenient to farm rather than just areas with lower capability soils. Clarification is also requested on the criteria that requires an existing access on a public road and whether that access must exist or can it be obtained as part of the severance process. This clarification would help to determine the number of new residential lots that could be eligible to be severed in South Huron (and across Huron County) and the effect of the policy on the agricultural industry.
If the Province’s intention is to permit 3 residential lots from every farm parcel, this has the potential to result in thousands of non-farm related lots in the agricultural area across the County. The Province should reconsider this substantial policy direction change and the long term effects it will have on the protection of prime agricultural lands and on maintaining the ability for farmers to farm. In addition, there may be other unintended consequences such as the effect of additional residences on the potential for future aggregate extraction.
Understanding that some agricultural land may be needed to address the demand for housing, the municipality is supportive of eliminating this requirement for expansions and directing development to settlement areas which is a more efficient use of agricultural land than scattered residential development throughout the countryside. Rather than the creation of non-farm related residential lots to increase the potential for housing in the agricultural area, the Province could consider amending the policy for surplus farm residence severances that requires the retained farmlands to be rezoned to prohibit a residence. The current limitation on the retained land could be removed, allowing a residence on these farm parcels where the severance was completed a certain number of years ago – perhaps 10-15 years or longer to avoid speculation. This would allow for additional housing related to agriculture and would not result in additional severances.
2. Settlement Area Expansions:
The municipality is supportive of the change to streamline the process for expanding settlement areas where required based on adequate servicing (provided priority is given to expansion in fully serviced areas), logical extensions and addressing agricultural impacts. This is a more efficient use of land than scattered residential lots in the prime agricultural area. The Province only encourages municipalities to set density targets for these expanded areas, but should give consideration to stronger language to ensure efficient use of these additional development lands.
3. Employment Areas and Employment Land Conversions
No concerns with this proposed change as the South Huron Official Plan already limits employment areas to Industrial designations and does not include Commercial or Community Facility designated lands as employment areas.
4. Growth Targets
No concerns.