Re: ERO 019-6813 - Review of…

Re: ERO 019-6813 - Review of proposed policies adapted from A Place to Grow and
Provincial Policy Statement to form a new provincial planning policy instrument.

The Perth County Federation of Agriculture (PCFA) represents the unique farming interests of Perth County farmers. After 75 years, we are proud to represent over 1,800 farming families in Perth County. PCFA believes the protection of prime agricultural land for agricultural use is of paramount importance.

Agriculture is the main economic driver in Perth County with 1.2 billion in farm cash receipts in 2021. The top 3 products we produce are hogs, dairy and grains and oilseeds but we also have diverse production of many other agricultural products. Perth County has many innovative and ambitious producers and we are well positioned to rise to the challenge of the province’s agri-food strategy, Grow Ontario.

We would like to take this opportunity to express our concerns with the proposed Provincial
Planning Statement. We appreciate the reconsideration of the lot creation policies originally
proposed within the statement but must again emphasize our position against creation of lot severances on farm and rural properties and ask that it be changed in the proposed PPS. We also must address the inconsistent, vague, and destabilizing policies that remain.

Agricultural System Mapping and Agricultural Land Protections

PCFA believes that farming to produce food, fibre, fuel, flowers, and nursery stock is the best use for farmland. Ontario’s limited supply of farmland is a scarce resource, making up less than five percent of all the land in the province. It’s vital that Ontario has a strong, viable and sustainable supply of food products grown, harvested, and processed right here at home. Ontario’s shrinking agricultural land base is alarming. The current rate of loss is measured at 319 acres per day in our province, according to the 2021 Census of Agriculture. These losses are not sustainable. Therefore, any proposals looking at increasing housing supply must be done with consideration to the needs and support of the agricultural community.
PCFA endorses the 2020 Provincial Policy Statement (PPS 2020)’s Agriculture policies [Section
2.3] that require municipalities protect their prime agricultural areas for their long-term agricultural use. We further support the flexibility afforded to farmers to engage in on-farm value adding of primary farm products, as well as agriculture-related, on-farm diversified, and agri-tourism uses. Although the PPS 2020 defines prime agricultural land as Canada Land Inventory (CLI) Class 1- 3 soils plus specialty crop areas, the PCFA believes that prime agricultural lands should be defined as Class 1 to 4 soils plus specialty crop lands. Class 5-6 soils that are part of an ongoing agricultural operation deserve protection too. These soils can support agricultural activities such as grazing livestock or growing crops for biofuels, and their productivity can be improved through activities such as tile drainage, stone picking, and the addition of lime. Where Class 1-4 soils are not present in a county or region, the best agricultural lands in that county or region should be recognized and protected for their agricultural use.

PCFA is a strong supporter of the preservation of Prime Farmland classes 1, 2, 3 & 4 plus specialty crop lands across rural Ontario. We believe strongly in the PPS 2020 Agriculture policies that governs farmland and rural areas protecting the right to farm and the Agriculture System in Ontario. In addition to this, PCFA believes strongly that the fragmentation of farmland in the rural area is counterproductive for the agricultural business structure in Ontario’s rural areas.

PCFA is against the removal of the requirement to use the provincially mapped agricultural system as it would allow for agricultural fragmentation, inconsistent classification of agricultural lands and specialty crop areas and disconnect in agricultural land mapping and classifications across municipal boundaries.

Settlement Area Boundary Expansions

PCFA is strongly against the proposed changes to settlement area boundary expansion policies.
Specifically, changes in functional policy language have removed both the requirement to justify
need and to conduct a comprehensive review, as such could result in uncertainty and ambiguity
for the process, expectations, and requirements for these expansions. PCFA believes that these
changes could lead to inconsistent implementation across municipalities, agricultural land
fragmentation, and inconsistent protections and considerations for agricultural land across
municipal boundaries.

PCFA supports fixed, permanent urban boundaries to limit the loss of agricultural land, thereby
focusing future urban growth within existing urban boundaries. This means urban growth primarily through redevelopment of vacant and underused lands, and higher density development.

We further believe that in urban areas, higher density development should be mandated
provincewide to take full advantage of existing infrastructure. PCFA supports urban
intensification/densification as one way to protect agricultural land and create complete
communities.

PCFA believes that urban areas should only be allowed to expand onto abutting agricultural lands only after exhausting redevelopment of underused or vacant areas within their existing urban boundaries. This would include the rehabilitation and redevelopment of both “greyfield” and “brownfield” sites. Lastly, urban expansion onto abutting agricultural land must be directed onto lower class agricultural land adjacent to the existing urban boundaries.

PCFA does not support scattered or strip development within prime agricultural areas.This form of development not only limits the ability of new and existing agricultural operations to function but fails to contribute financially to municipalities.

PCFA wants to see PPS policies in Section 1.1.3.8 remain as is. Keeping these policies intact (and holding municipalities and MMAH accountable to following these policies) is critical for meeting joint goals of balancing farmland protection with urban development. Further, OFA wants to see Agricultural Impact Assessment (AIA) policies from APTG incorporated directly into the proposed PPS policies on settlement area boundary expansions (APTG Policy 2.2.8.3 h). Specifically referencing AIAs as the current policy outlines:

“Where the need for a settlement area boundary expansion has been justified in
accordance with policy 2.2.8.2, the feasibility of the proposed expansion will be
determined and the most appropriate location for the proposed expansion will be
identified based on the comprehensive application of all of the policies in this
Plan, including the following: ... h) any adverse impacts on the agri-food network,
including agricultural operations, from expanding settlement areas would be
avoided, or if avoidance is not possible, minimized and mitigated as determined
through an agricultural impact assessment;” (APTG Policy 2.2.8.3 h).

As Ontario becomes more urbanized, councils and staff may not apply an agricultural lens to their plan-, policy-, and decision-making. This is critical as we need to plan for 'farm-friendly' urban development that promotes compatibility at the urban-agricultural interface. For example, parcel size, configuration, building setbacks, road patterns, institutional locations, drainage patterns and location of municipal servicing will all have implications for agriculture.

PCFA firmly believes in the widespread use of AIAs, as it ensures that agricultural uses continue, and normal farm practices are protected. AIAs identify opportunities to increase compatibility between agricultural and non-agricultural uses by looking for ways to avoid, minimize, then mitigate adverse impacts on agricultural operations and the Agricultural System.

Lot Creation and Additional Residential Units (ARU)

PCFA is optimistic about the reconsideration of the proposed lot severance policies and look forward to seeing this changed in the PPS.

While PCFA does not support further lot creation and severances, we do support additional
residential units on existing farm parcels, and in rural hubs, hamlets, and communities to support our agricultural system. PCFA would like to establish our support for additional dwelling units subordinate to the principal dwelling on an agricultural parcel but do not support the establishment of additional lot severances on these parcels.

In our previous submissions to the government regarding the PPS 2020, we have commented
that the PPS 2020 does not go far enough in protecting our finite agricultural lands. We have
recommended strengthening of the PPS 2020 in order to require fixed urban settlement
boundaries and policies requiring mandatory intensification within the existing built urban areas.

While PCFA is supportive of additional residential units, we do feel there needs to be further
specificity in the policy. Our concerns include a lack of criteria for ARUs, insufficient consideration for onsite infrastructure and servicing, inconsistency between policies on provincial guidance, a lack of consideration for the distinctiveness of municipalities, and the exclusion of specificity surrounding whether these policies apply to both farm and rural lots.
PCFA believes that there should be additional consideration of a set of criteria for ARUs as well as clarification on the extent of this policy. There is a distinct lack of inclusion for the type, size, scale, and location of these proposed ARUs that needs to be addressed as well as the clarification on whether this policy is exclusive to farm lots or includes rural lots as well.

Further, we are concerned that inconsistencies between policies on permitted uses in agricultural lands could lead to the misinterpretation or unpredictable development and approval of ARUs. Specifically, under section 4.3.2 Permitted Uses, 4.3.2.4 (principal dwellings) states that the policy must be in accordance with provincial guidelines, however, 4.3.2.5, does not include this provision. PCFA believes that this exclusion in conjunction with the lack of criteria for ARUs could result in development that does not align with our position that farming to produce food, fibre, fuel,flowers, and nursery stock is the best use for farmland.

Additionally, we must highlight the distinctiveness of municipalities across Ontario, both in their
landscape as well as their governance ability and priorities. No two municipalities are alike,
therefore flexibility within the PPS for municipalities to be more restrictive to meet their goals should be included.

PCFA sees that opportunities to build more rural housing should be concentrated within, and
directed to, rural settlements and settlement areas as identified in APTG Policy and PPS (2020)
Policies 1.1 “Managing and Directing Land Use to Achieve Efficient and Resilient Development
and Land Use Patterns,” 1.1.3 “Settlement Areas,” 1.1.4 “Rural Areas in Municipalities.” Density
and intensification targets should be analyzed and identified in accordance with APTG
methodology and appropriately applied to rural settlements and settlement areas.

Within rural lands, PCFA recommends that agricultural uses, agriculture-related uses, on-farm
diversified uses, and normal farm practices should be protected and given higher priority as
permitted uses under PPS (2020) Policy 1.1.5.2 and throughout Policy 1.1.5 “Rural Lands in
Municipalities.”

We acknowledge the servicing capacity limits many rural communities in Ontario face, such as that with private water and wastewater services. However, rural communities also need additional housing. There are opportunities within existing smaller villages, hamlets, and towns to increase density on parcels of land in the settlement area that are adequate for servicing and more efficiently contribute to the rural tax base. This would serve to eliminate the need for lot severances on agricultural lands while providing increased housing options across Ontario.

Employment Lands

In Bill 97, PCFA is concerned about the alterations to the definition and policies for Employment Lands proposed in the Planning Act amendment in Schedule 6 of Bill 97. We would like to maintain that the resulting impacts of reduced protections for Employment Lands could result in increased pressure to utilize agricultural lands such as Prime Agricultural Lands and Specialty Crop Areas for employment uses in the future as well as put agricultural processing operations at risk.

Municipal Flexibility

PCFA believes that the PPS should be used as a baseline and remove the provisions that limit the flexibility of municipalities. As we have highlighted, municipalities vary across the province and it is PCFA’s belief that municipalities should be allowed to be more restrictive within the local policy so long as it is in accordance with provincial policy.

Agricultural Impact Assessment

While we are very happy to see that Agricultural Impact Assessment (AIA) is included in the
definitions, we do believe that an AIA must (not should) be completed under section 2.3 Settlement Areas and Settlement Area Boundary Expansions. We are pleased to see the
requirement for “avoiding, or where avoidance is not possible, minimized and mitigated as
determined through an agricultural impact assessment...” in section 4.3.5 Non-Agricultural Uses
in Prime Agricultural Areas. We are also very pleased to see the application of 4.3.5.2 applied to
Mineral Aggregate Extraction in Prime Agricultural Areas under 4.5.4.1.a. Avoiding impacts to
agricultural areas from mineral extraction is an important protection of Ontario’s limited agricultural lands.

PCFA is very pleased to see the requirement for an AIA or equivalent analysis for mineral extraction in prime agricultural areas, yet we remain concerned there are circumstances in which “complete rehabilitation to an agricultural condition is not required....” As established in 4.5.4.2. It is our belief that an application to extract minerals in prime agricultural areas that cannot be rehabilitated to an agricultural condition should not be approved on the basis that it does not meet the conditions of that application.

Natural Heritage & Water

PCFA believes that the Provincial Planning Statements should not remove the words “all municipal” from section 4.2.1(e)(1). We believe that this section should remain “Implementing necessary restrictions on development and site alteration to: 1. Protect all municipal drinking water supplies and designated vulnerable areas; …”

PCFA believes that the definition of “Wetlands”, as it currently exists in the Provincial Policy Statement, 2020 should remain.
Wetlands: means lands that are seasonally or permanently covered by shallow water, as well as lands where the water table is close to or at the surface. In either case the presence of abundant water has caused the formation of hydric soils and has favoured the dominance of either hydrophytic plants or water tolerant plants. The four major types of wetlands are swamps, marshes, bogs and fens.
Periodically soaked or wetlands being used for agricultural purposes which no longer exhibit wetland characteristics are not considered to be wetlands for the purposes of this definition.

We look forward to reviewing the proposed natural heritage policies when they are released.

We are concerned that combining A Place to Grow: Growth Plan for the Greater Golden Horseshoe and the Provincial Policy Statement, 2020 would diminish the protections and support for agricultural lands and community and therefore open the floodgates for a rash of developments that run counter to our overarching philosophy of farmland preservation which is paramount to OFA’s mission of “Farms and Food Forever.”

PCFA appreciates the opportunity to provide our feedback and agricultural perspectives on the proposed Provincial Planning Statement. We look forward to working with the provincial government and our municipal counterparts to protect Ontario’s farmlands as well as sustain Ontario’s housing supply and communities.

Sincerely,
Perth County Federation of Agriculture