August 4, 2023 Ontario…

August 4, 2023
Ontario Ministry of Municipal Affairs and Housing
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.

Please accept this submission in response to the proposed Provincial Planning Statement (PPS) on behalf of the Northumberland County Food Policy Council (NCFPC). Our Council has been operating since April 2011, together with over twenty community partners to develop the Northumberland County Food Charter. In the summer of 2013, the Food Charter was endorsed by all seven local municipal governments. On World Food Day (October 16, 2013), Northumberland County also endorsed the Food Charter. The primary goal of the Food Charter is for individuals, agencies and local governments to work together to build a vibrant, sustainable, food-secure community.

Building on the Food Charter, a diverse group of local citizens founded the Northumberland County Food Policy Council, and created our Mission: To bring individuals, agencies, and local government together to examine the operation of the local food system, stimulate and lead a dialogue on food, promote projects in the community, and provide policy ideas and recommendations that enhance a sustainable local food system.

We are in the process of updating our strategic plan, and currently, we have four focus areas:
1. Community Gardens
2. Decrease Food Waste
3. Incentives for franchises/institutions to purchase local foods
4. Land Use Planning

A strong local and regional food supply in Ontario is a critical component for economic development and prosperity in our rural and urban communities. Supporting a local food system also supports the health and well-being of Ontarians, and protects precious farmland, water sources, forests, wetlands and wildlife habitat. The proposed PPS plays a direct role in the development of a sustainable food system, climate change adaptation and mitigation, and the future health of Ontarians.

In order to prioritize local and regional food systems in a new province-wide planning policy instrument that combines the current PPS and A Place to Grow: Growth Plan for the Greater Golden Horseshoe (APTG), it is essential to retain and/or incorporate the following core components:
• Creating communities that are compact, comprehensive, environmentally friendly, and food secure;
• Enhancing climate resilience through adaptation and mitigation strategies;
• Engaging meaningfully with Indigenous communities;
• Ensuring public health and safety;
• Protecting the environment, and our diminishing agricultural land;
• Supporting democratic input on a local and regional level through active citizen engagement.

Sustainable Local Food Systems

A sustainable local food system delivers community food security and nutrition to ensure that economic, social, and environmental bases for future generations are not compromised. The way food is produced, distributed, processed, and sold within a region impacts food choices and nutrition related health outcomes. Communities that have access to a sustainable supply of healthy, and locally grown and processed food are less susceptible to external factors that can influence the cost, and the nutritional quality and/or quantity of available foods.

Ensuring community food security, a key outcome of sustainable food systems, requires that a variety of elements be addressed. Some of these elements are outlined below with respect to how the proposed PPS will negatively impact a sustainable food system in Ontario.

• Availability means that a diverse food supply and adequate food infrastructure is in place. As per section 4.3.3 of the proposed PPS, residential lots will be created on prime agricultural land. This impacts Ontario’s food system and the ability of the province to meet this demand. Ontario’s agricultural lands are a finite and shrinking resource, making up less than five percent of all provincial land, and is currently being lost at a rate of 319 acres per day. Policies must be in place to encourage local farmers to grow local food. Instead, the proposed policy will make it difficult for farmers, as they will be competing with developers. However, recent media stories state that the PPS will remove the creation of residential lots on prime agricultural land. The Northumberland County Food Policy Council (NCFPC) supports this change.

• Accessibility ensures that everyone has physical access to adequate and acceptable food. Evidence indicates that compact, complete communities facilitate economic growth, sufficient land use, opportunities for recreation, and access to food. The proposed policy will encourage sprawled development that will fragment and isolate farm communities, reducing access to food.

• Affordability means everyone has adequate income to purchase foods that meet cultural and personal preferences. The proposed policy will remove measures that require developers to build diverse housing types that Ontarians can afford. Inflation, supply-chain disruption, and climate-related events in recent years have highlighted the urgent need for both affordable housing and the protection of farmlands. Reducing the availability of affordable housing will add to the growing problem of food insecurity: the inability to afford food due to inadequate or insecure income. The proportion of Ontarians living in food insecure households in 2021 was 19.2% or 2.8 million people.

• Acceptability ensures that the food system meets cultural preferences and needs. To ensure a sustainable food system, the unique role and inherent rights of Indigenous peoples must be recognized, which includes access to traditional lands.

Climate Change

The NCFPC recognizes the strong connection between food and climate change. As noted in Ontario Dietitians in Public Health (ODPH) Food Systems Workgroup response to Bill 23, “food is grown, harvested, and processed in our communities and the lands and waters that surround them — our continued [community] food security relies on us doing so in a sustainable manner. In the face of a rapidly changing climate and uncertain seasonal weather patterns, the disruption of complex wetland systems can have massive impacts on above- and below-ground waterways, and the production potential of adjacent agricultural lands. Further, disruptions to long food supply-chains, increased transportation expenses, crop failure in other parts of the world, and the need to limit our use of carbon-based fuels, require us to increase [community] food security by deepening our access to sustainably produced, [and] locally grown food.”

From a food systems perspective, to ensure community food security, climate change must be recognized across many aspects of land-use planning. Like the ODPH, Northumberland County Food Policy Council recommends that climate change mitigation and adaptation policies be integrated into agriculture and food policies, infrastructure and facilities, transportation, water, and stormwater management.

Health and Well-being of Ontarians

Previous iterations of the PPS and Growth Plans explicitly recognized the health and well-being of Ontarians, and how healthy communities and natural environments are interconnected. The merging of the PPS and APTG disintegrates the original intentions of these documents, and many essential, health-promoting components to support climate resiliency and a sustainable food system in Ontario. In consideration of a new provincial planning policy instrument, we urge the Province to consider the inclusion of the following policies as proposed by the Ontario Public Health Association:
1. Prevent unsustainable urban expansion and fragmentation of agricultural lands.
2. Integrate affordability targets for low- and moderate-income households to support equity and promote housing affordability for all.
3. Strengthen policies that will help communities mitigate greenhouse gas emissions and adapt to climate change.
4. Mitigate exposure to incompatible land uses and harmful levels of pollution.
5. Re-integrate health and well-being concepts in the Vision and in Chapter 2 “Building Homes, Sustaining Strong and Competitive Communities”, with the goal of creating healthy communities that enable people to thrive.

Sincerely,

Russ Christianson, Chair
Northumberland County Food Policy Council