From: the Peterborough…

From: the Peterborough Alliance for Food and Farming (localfoodptbo.ca)
Date: June 6, 2023
PROPOSED PROVINCIAL PLANNING STATEMENT
https://ero.ontario.ca/notice/019-6813
The Ministry of Municipal Affairs and Housing (MMAH) is seeking input from all interested residents, as well as organizational leaders, on proposed policies for an integrated province-wide land use planning policy document. This proposed Provincial Planning Statement takes policies from both A Place to Grow: Growth Plan for the Greater Golden Horseshoe and the Provincial Policy Statement, 2020 to support the achievement of housing objectives across Ontario.
Specific to rural communities and our food-producing lands, this direction proposes more flexibility in the development of rural areas, allows increased residential development and promotes residential lot creation in prime agricultural areas. However, it is not supportive of a strong and healthy rural community in terms of adding needed infrastructural services to support the new residences nor does this policy ensure protection of our agricultural sector/lands.
Over the past decade Peterborough City and County have worked collaboratively to build and maintain a strong food system and thus a sustainable Peterborough for future generations. Specifically, the intent of the Peterborough Alliance for Food and Farming (PAFF) is to collaborate to strengthen community food security and sustainable, resilient local food systems in the context of the global food and climate crises.
PAFF aims to facilitate connections to benefit those living and working within Peterborough City, County and First Nations, through education, research, planning, consultation, coordination, and communication. It has documented the need for a sustainable Peterborough and it has had input from local residents through a variety of research reports and community summits over the last thirteen years.
We are writing to voice extreme concern over the proposed provincial directions the Province of Ontario that will:
• undermine good planning,
• allow for inappropriate development of food producing lands and agricultural practices,
• result in the degradation of rural communities and uncontrolled rural sprawl without providing resources to develop appropriate services

Our comments have their basis in our work to date. Our questions are being posed because we are not confident that consideration has been given to the needs of our rural communities and the requirements to maintain our ability to feed Ontario in the future.
Here are some things to consider as the province attempts to reduce appropriate planning policies.
Some statistics and implications for decision makers to consider:
• Stats Canada (2022) reported 48,346 farms in Ontario in 2021
The proposed directions could result 145,038 acres taken out of agricultural production (in 48,346 x 3acres and this does not include all those non-farm agricultural parcels (2+ acre lots)
• Stats Canada (2022) reported 11,766,071 acres of farmland in Ontario in 2021. This policy could remove approximately 1.25% of Ontario's farmland (again this does not include all those non-farm agricultural parcels (2+ acre lots)
• Less than 5% of Ontario’s land base is prime agricultural lands (OMAFRA, 2016) and these proposed changes allow development on those lands
• According to Ontario Farmland Trust, Ontario is already losing 319 acres of farmland every day (farmland transitioned to other uses)
• Ontario has the largest percentage of livestock farms in Canada at the present time. This new lot creation policy will ultimately reduce opportunities to create and expand livestock in Ontario. Again this will result in land-use conflicts and an increased reliance on other geographic areas for our food.
• It is estimated that on a typical concession block the proposed planning changes will allow approximately 30 new residential lots. With Minimum Distance Separations (MDS) between lots and farm use, this will result in no space for growth in our food production re livestock sector. This will result in even more reliance on other countries to meet our needs for animal agriculture in Ontario.
• Given MDS restrictions, many farmers and farmland owners may be forced to choose between selling lots and maintaining barns for future use. If they choose to decommission currently unused barns in order to sell lots, this is a permanent action that will restrict any future possibility of livestock agriculture on the farm.

Questions to consider about this direction to allow sprawl:

• The proposed Provincial Policy Statement re agricultural severance policy will allow/encourage hundreds of thousands of new residential lots and more residences to be scattered amongst farms. How will that support good farming practices and our need for more local food production? How will municipalities and community agencies deal with the population increases and an erratic social infrastructure requiring increased services (hospitals, health care, schools)?

The impact of sprawl on our water system:

• Conventional strip development of residences has been concentrated along farm boundaries and a road. Because they are individually developed, they are not on municipal water and sewer. This generally means that each dwelling lot has to have a well and a septic system.
• Because the septic will seep into the ground water and the potable water is drawn from the ground water there is a possibility of contamination of the potable water supply. This possibility increases with the density of strip development. Any septic discharge into a nearby watercourse could impact source water in other areas beyond the strip development. This possibility would have a negative impact on downstream source water areas (places where individuals or municipalities drawn potable water).
• Because strip development is generally taken from agricultural land, normal farming practices may impact the strip development potable water supply.
• By imposing separation distances between the agricultural lands and the strip development, land available for agricultural will be further reduced.

The impact of sprawl on the social infrastructure of our rural communities:

• Given that good planning, environmental responsibility and community consensus states that affordable housing must be located in an area with adequate transportation corridors, how will the province accommodate these additional transportation needs? This proposed policy promotes development that is reliant on cars.
• How will municipal and provincial governments deal with the land use conflicts between farmers and non-farmers that these policy changes will engender?
• How can a community be built sustainably if municipalities are not permitted to decide what is best for their own area? (ie if the county/townships locally want to do things differently and more restrictively, they are not permitted to do so by the Province).
• It is proposed that language about healthy communities be removed. However, land use planning is an important health promotion tool to support reducing the burden on the healthcare system. Removing language about built boundary lines has implications for community connectedness specifically connections to physical and mental health. What are plans to ensure that the link between health and land use planning, is acknowledged?

The limitations for community consultation:

• With the new proposed changes, the Minister of Municipal Affairs and Housing will have the ability to over-ride municipal decision-making processes without consultation. Are there plans to ensure that decisions made reflect the needs and voices of local communities with consideration given to the needs of Indigenous communities?

Finally, sustainable communities can only be built upon good planning values and principles. Decisions made today will impact the next generations. How will these proposed planning policies:
• ensure safe and adequate water systems?
• Support community resiliency in the face of climate-impacted weather extremes such as droughts and high rain events?
• Preserve our natural heritage?
• Commit to the development of social, health and education services that support rural communities?

We understand that the province is under great pressure to allow development. However, the development of a sustainable community requires strong and insightful planning principles. We hope that our comments will provide you with information that will result in a return to appropriate planning policy and the values of sustainable communities.

Addendum:
This letter was prepared with extensive consultation and reflection on the issues cited above.
As of June 1st, the government has indicated that it is reconsidering its position on the issues to which we are providing comment. We have chosen to continue to provide comment because of the importance and concern for our rural communities, our commitment to protecting farmland and building sustainable communities.
We hope that the government has taken to heart the need to plan a strong rural Ontario. We will continue to monitor and engage with the Province as the process unfolds.