Hi there, I am a young…

Hi there, I am a young farmer submitting comments on the 'A place to Grow' act and the new proposed Provincial Planning Statement. I am happy to see some things in the proposal that should make for better urban areas, more housing and reduce pressure on farmland. These things would include establishing and meeting density targets around transit lines (assuming these density targets are set reasonably high), creating better transit systems and corridors in new areas, providing a greater mix of housing options, density and types, and requiring intensification policies for communities. Much to my dismay however, are policies in the proposal that seem to run counter to both improving our communities and reducing impact on the environment such as; allowing for more development in rural areas (which increases infrastructure cost, reliance on car transportation, consumes farmland and disturbs wildlife) and allowing urban boundary expansions without demonstrating prior need. Given our increasing loss of farmland in Ontario, we should be using urban boundary expansions as a last resort to providing sources of housing. There is much infilling that we can do in our communities that would help to reduce development pressure on farmland and improve our communities through lessening car dependency and increasing active transport and accessibility to amenities. It is absolutely foolish to encourage rural settlement, when we know that it creates low population density, inefficiencies in providing services, creates car dependency, and increases emissions. We must put our resources towards, be encouraging, more, and better, denser urban settlement. We are seeing a weakening of our rural communities, in part due to our poor urban planning. We must have strong, vibrant urban communities so we can have strong, vibrant rural communities, instead of a mix of low density country estates across the country side. There must be a clear definition between what is protected as farmland and habitat, and what is consumed for urban area. We must have hard urban boundaries that are not easily expanded, and tough agricultural zoning that is not changed at the drop of a hat. We must have better sustainable planning than what is being presented.

I am also confused why municipalities must map their prime agricultural areas and specialty crop areas. While it is always good to know where these areas are, presumably the provincial mapping system should already know where these areas are. Does the wording surrounding this weaken the protection around these lands?

Ontario’s prime agricultural land is a finite, non-renewable resource that comprises less than 5% of Ontario’s land base1. With the growing rate of farmland loss in the province, currently at a rate of 319 acres per day2, it is more important than ever before that the province protects our prime areas. Ontario’s farmland directly supports the agri-food sector, which is the largest economic sector in the province, employing more than 750,000 Ontarians along the supply chain and annually contributing over $47 billion to the province’s GDP3.

While I recognize the need to address issues of housing availability and affordability, I am concerned that several of the policies in the proposed PPS 2023 will not adequately contribute to the housing issues and instead will create significant issues for the long-term viability of Ontario’s agri-food sector. This submission will focus primarily on the proposed PPS 2023 impacts on the agricultural system.

Comments regarding Agricultural Systems and the proposed PPS 2023

While I appreciate the attempt to adapt the Growth Plan policies pertaining to agricultural system mapping into the PPS 2023, the language undermines the previous requirement for municipalities in the Greater Golden Horseshoe from requiring them to use agricultural systems. S4.3.1 states, “planning authorities are encouraged to use an agricultural system approach.” The use of the word ‘encouraged’ is not strong enough and will not require municipalities to use the provincial agricultural system mapping. Given that this is now optional for municipalities, it will decrease the likelihood of adopting agricultural systems mapping and create fragmented agricultural systems between municipalities. This is partly due to the added responsibility on rural municipalities that tend to have more limited resources to complete agricultural system mapping that the province would otherwise support. The use of a provincial agricultural systems approach to planning is crucial to protect agricultural land given its importance as an economic driver and in recognition of the natural heritage and hydrological features and functions that farmland plays4.

Recommendation 1: The province should amend the language in the proposed PPS 2023 that requires agricultural system mapping for all municipalities.

I note the removal of the policy language which stated, “planning authorities shall designate prime agricultural areas and specialty crop areas in accordance with guidelines developed by the Province.” Instead, the proposed s.4.3.1.2 states, “as part of the agricultural land base, prime agricultural areas, including specialty crop areas, shall be designated and protected for long-term use for agriculture.” There is concern as to the various approaches that municipalities may choose to take on designating prime agricultural areas. Provincial guidelines should remain the standard by which municipalities designate prime agricultural areas, in order to ensure a consistent approach across municipalities. By removing this policy, the province is risking inconsistent approaches to designating prime agricultural areas which can lead to further farmland fragmentation, particularly between municipal boundaries. It is important to note that farmland fragmentation makes farming practices significantly more challenging and creates and assortment of land-use conflicts. While the policy states that prime agricultural areas and specialty crop areas shall be designated and protected for long-term use for agriculture, s.4.3.3 permits up to three lot severances per farm parcel, which undermines the protection s.4.3.1.2 states it is intended to provide. It is important to highlight here the contradictory nature of these sections: S.4.3.3 needs to be removed in order to protect the agricultural system that the PPS 2023 proposes needs to be protected.

Recommendation 2: The PPS 2023 should include the requirement for municipalities to use the guidelines developed by the province to designate prime agricultural areas and specialty crop areas.

Recommendation 3: S.4.3.3 should be removed in its entirety as it undermines and contradicts the notion of a contiguous agricultural system.

I acknowledge that the policy provides opportunities for housing for new and young farmers during succession planning and transitioning the farm to new operators. However, municipalities should be permitted to allow for additional restrictions to help protect prime agricultural areas and mitigate the likelihood of conflict arising. The proposed s.4.3.3.2 prevents municipalities from being able to be more restrictive and prevent these types of conflicts, as well as utilize their own local knowledge and context for their communities needs, such as rural communities whose economies are heavily based on agricultural production. The weakened policies on utilizing provincial frameworks for designating prime agricultural areas as well as agricultural system mapping will put these rural and agricultural communities at risk.

Recommendation 4: S.4.3.3.2 should be removed in order to allow rural and agricultural communities the ability to properly protect their agricultural system, rural character, and implement local context into their official plans and zoning by-laws.

I urge the province to reconsider the proposed policy changes that have weakened the requirements for municipalities to implement an agricultural system and limit their ability to include more restrictive provisions to protect their rich agricultural land base and economies. This will help ensure the long-term viability of agriculture in Ontario and protect the agri-food sector’s significant contributions to the province’s GDP and employment numbers.

Comments regarding section 4.3.3 Lot Creation and Lot Adjustments

I am concerned about proposed s.4.3.3 which permits the severance of three residential lots from parcels in prime agricultural areas. This poses a significant threat to the long-term viability of the agricultural sector. As it currently reads, this policy could apply to any parcel of agricultural land, regardless of its size or whether it was previously severed before January 2023. Given that there are 48,346 farms4 and as many as 170,000 farmland properties in Ontario5, the province could see anywhere from 145,038 to 510,000 lots severed from agricultural properties. Therefore, if each lot is approximately 1-acre in size, this policy alone would be responsible for removing anywhere from 1.25% to 4.3% of Ontario’s finite agricultural land base.

The use of a provincial agricultural systems approach to planning is crucial to protect agricultural land, given its importance as an economic driver and in recognition of the natural heritage and hydrological features and functions that farmland plays6. While I appreciate that proposed s.4.3.1 states “Planning authorities are encouraged to use an agricultural system approach,” this policy does not provide the strength needed to require agricultural systems, and appears to be in contradiction to the permissions of s.4.3.3. When you factor in s.4.3.2.5, which permits up to two additional dwellings in prime agricultural areas, this could result in as many as 1.5 million dwellings on newly severed lots in agricultural areas. This will lead to significant farmland fragmentation, which is contradictory to the purpose of an agricultural system, and will cause significant disruptions to surrounding agricultural operations.

Moving to rural areas often means embracing the realities of agricultural living, such as noise, dust, odors, and farm equipment on the roads. Unfortunately, this leads to land-use compatibility conflicts that are difficult to mitigate once residential units are developed in agricultural areas. This poses significant challenges for farmers, especially when Minimum Distance Separation (MDS) is not properly followed during development approvals. This is concerning given that Bill 23 prevents third-party appeals at the Ontario Land Tribunal, making it difficult for nearby farmers to address MDS concerns. Additionally, constructing residential units up to the MDS line will limit any future growth of the agricultural operation, threatening the future viability of animal agriculture in Ontario.

Furthermore, additional residential units on prime agricultural areas will result in an increase in water usage from underground aquifers. Three additional lots, including three additional residential units would put a significant strain on the water usage and increase the likelihood of water source issues for both the residents and the agricultural operation. Agriculture uses significant amounts of water to irrigate crops and provide water to livestock. Although a large percentage of water is returned to the source, often it has been changed and carrying soil and dissolved compounds7. With less water available in the aquifer, any contaminants will be more concentrated. Therefore, permitting three lot severances in prime agricultural areas will have significant implications for water availability and safety.

By permitting lot severances, the province will be impacting the financial accessibility of farmland for the next generation of farmers, making farming less financially viable. Each farm property will likely increase in price relative to the value of three vacant lots in the respective region. Ontario experienced a 19.4% increase in property values in 20228, making it unattainable or financially unfeasible for many young farmers to buy land. The proposed severance policies will incentivize developers, who can outbid young farmers, to purchase farmland or provide cash incentives for farmers to sever lots, contributing to the increase in farmland prices. This will result in the next generation experiencing a fragmented agricultural system and keeping ownership of farmland out of their reach. This is concerning because if the next generation of farmers cannot afford to farm, and experience it as increasingly difficult to farm, the province will not have a viable agricultural sector for much longer.

I have noticed that the new proposed PPS 2023 states in policy 4.3.1.2, “As part of the agricultural land base, prime agricultural areas, including specialty crop areas, shall be designated and protected for long-term use for agriculture.” However, permitting lot severances for residential use contradicts lands being designated for the long-term protection for agriculture.

I believe that the proposed s. 4.3.2.5, which would allow two additional units on existing farm properties, could be significant in providing housing opportunities for new and young farmers during succession planning and transitioning the farm to new operators. Similarly, the proposed s. 2.2.1.b.2 allows more land for housing by converting existing commercial and institutional buildings for residential use. Given these other proposed policies permitting additional housing and the significant concerns over the proposed lot creation policies, I question why there is a need to permit such a significant allowance for severances.

Furthermore, permitting these severances is in contradiction to proposed s. 2.2.1.c, “promoting densities for new housing which efficiently use land, resources, infrastructure and public service facilities, and support the use of active transportation.” S.4.3.3 will not promote efficiency in these areas and will detract from the intentions to support intensification.

I believe that municipalities should be permitted to allow for additional restrictions to help protect agriculture and mitigate the likelihood of conflict arising between non-farming residents and the agricultural community. However, proposed s.4.3.3.2 prevents municipalities from being more restrictive, which could be vital for preventing these types of conflicts. For rural communities whose economies and culture are intricately associated with agriculture, s.4.3.3.2 will prevent municipalities from protecting a key component of their communities and is contradictory to the content on page 3 that states the PPS 2023 recognizes the diversity of Ontario and that local context is important. S.4.3.3.2 restricts rural municipalities from ensuring the local context of their agricultural system is protected from farmland fragmentation.

I, therefore, urge the province to consider these concerns and remove s.4.3.3 in its entirety so that the proposed changes do not harm the province’s agricultural lands and the farmers who depend on them. The province should require municipalities to use the provincial agricultural system mapping and allow municipalities to implement additional restrictions to help protect agriculture and prevent conflicts with non-farming residents.

Comments regarding proposed changes to intensification, municipal comprehensive reviews, and settlement area expansion

I have significant concerns regarding the proposed policy changes found in the PPS 2023 regarding intensification targets, municipal comprehensive reviews, and settlement area expansion. These policies should ensure strategic growth for communities while protecting highly valuable farmland. However, while the proposed PPS 2023 generally states support for intensification, it does not require targets for municipalities across Ontario and provides many permissions that would undermine attempts at intensification. Additionally, the intensification targets for many municipalities in the Growth Plan have been reduced or removed altogether, which will use up lands in municipal boundaries faster and lead to increased rates of urban boundary expansion. Without the requirement to complete municipal comprehensive reviews, this poses a significant threat to farmland. As noted below, reducing and eliminating density targets is contrary to encouraging complete communities found within the proposed PPS. This will lead to fragmented patterns of development, including when settlement boundary expansion occurs.

I have noted concerns under s.2.3, Settlement Areas and Settlement Area Boundary Expansions. The policy in s.2.3.2 now states that “land use patterns within settlement areas should be based on densities and a mix of land uses”. The province opted to change the language from “shall” to “should”, which weakens the policies that are meant to support intensification. Additionally, the language that states land use patterns should “minimize negative impacts to air quality and climate change, promote energy efficiency” and “prepare for the impacts of a changing climate” has been removed. This is concerning given the climate crisis we are facing and that agriculture relies on healthy and stable ecosystems to produce a consistent supply of quality local food. By removing this language, the province is undermining the future viability of the agricultural sector, the largest sector of the Ontario economy.

Recommendation 1: The province should use stronger language in s.2.3.2 that will require municipalities to adopt land use patterns that support density targets and also minimize negative environmental impacts.

Furthermore, s.2.3.3 states that “planning authorities should support general intensification and redevelopment to support the achievement of complete communities, including by planning for a range and mix of housing options and prioritizing planning and investment in the necessary infrastructure and public service facilities.” Once again, the use of “should” is not strong enough to ensure the deliverables of complete communities. Furthermore, the policy no longer requires planning authorities to identify appropriate locations or take stock of suitable existing sites, eroding the possibility of efficient land use. While I encourage the use of complete communities in the planning framework, the removal of intensification targets will not only have sever impact to farmland but it will undermine the existing urban planning framework to achieve complete communities.

Recommendation 2: The province should use stronger language in s.2.3.3 that will require municipalities to identify appropriate locations for intensification.

The policy on settlement area expansion has also been weakened, which will further threaten Ontario’s prime agricultural land. A major concern is removing the requirement of a municipal comprehensive review that demonstrates the need for expansion. Additionally, the language in s.2.3.4 has been changed from “shall” to “should” which weaken the policy, making it possible for development to occur on prime agricultural lands. While proposed s.2.3.4.b states that applicable lands do not comprise specialty crop areas, this is a subsection under s.2.3.4 which states planning authorities “should” consider this. Since the language does require planning authorities to consider this, there is the likelihood of it still occurring. This is also the case for s.2.3.4d regarding impacts on agricultural lands and operations that are adjacent or close to the settlement.

Recommendation 3: The province should require municipal comprehensive reviews prior to settlement boundary expansion and require the planning authority to demonstrate the need. Furthermore, the province needs to adopt stronger language in s.2.3.4 that ensures the applicable lands do not comprise specialty crop areas and that prime agricultural areas are avoided to the greatest extent possible as determined through an agricultural impact assessment.

I have also noted the removal of policies from s.2.6 Rural Lands in Municipalities, in particular, “when directing development on rural lands, a planning authority shall apply the relevant policies of Section 1: Building Strong Healthy Communities, as well as the policies of Section 2: Wise Use and Management of Resources and Section 3: Protecting Public Health and Safety.” I suggest that the removal of this policy will undermine the future resiliency of rural communities.

Recommendation 4: The province should reinstate the policies pertaining to directing development on rural lands that require planning authorities to apply relevant policies that support strong and resilient communities as found in the Provincial Policy Statement, 2020.

Finally, there is concern pertaining to the language in s.2.1.1 that states, “sufficient land shall be made available to accommodate an appropriate range and mix of land uses to meet projected needs for a time horizon of at least 25 years.” As noted above, without improving language and goals pertaining to density targets, it will be increasingly difficult for municipalities to plan accurately for beyond 25 years. This will likely lead to further settlement area expansion to accommodate the likelihood of urban sprawl, which will reduce investments in agricultural operations surrounding urban boundaries.

Recommendation 5: The province should maintain the current requirement for planning authorities to plan for up to 25 years in order to minimize unnecessary and premature settlement area expansion.

In conclusion, the proposed changes to intensification targets, municipal comprehensive reviews, and settlement area expansion weaken policies that would ensure strategic growth for communities while protecting highly valuable farmland. The use of weaker language and the removal of requirements will lead to increased rates of settlement boundary expansion and further threaten farmland and the agricultural sector. It is essential that the policies are strengthened to ensure efficient land use and protect Ontario’s agricultural operations and communities.\

Thanks for taking the time to read my comment, and I hope that we can find a better balance between preserving our natural heritage, our farmland and agri-food system, and improving our communities while providing housing.

References:

1] Ontario Ministry of Agriculture, Food and Rural Affairs. 2016. Guidelines on Permitted Uses in Ontario’s Prime Agricultural Areas. Retrieved from http://www.omafra.gov.on.ca/english/landuse/facts/permitteduseguide.pdf
[2] Statistics Canada. 2021. Census of Agriculture. Retrieved from https://www150.statcan.gc.ca/t1/tbl1/en/tv.action?pid=3210015301&pickMe…
[3] Ontario Federation of Agriculture. 2020. Agriculture Matters – A Guide for Municipal Councillors and Staff. Retrieved from https://ofa.on.ca/resources/guide-for-municipal-councillors-and-staff/
[4] Statistics Canada. 2021. Census of Agriculture. Retrieved from https://www150.statcan.gc.ca/t1/tbl1/en/tv.action?pid=3210015601&pickMe…
[5] Agricorp. 2022. 2021-22 Annual Report. Retrieved from https://www.agricorp.com/SiteCollectionDocuments/Agricorp-AnnualReport-…
[6] Ontario Ministry of Agriculture, Food and Rural Affairs. 2020. Implementation Procedures for the Agricultural System in Ontario’s Greater Golden Horseshoe. Retrieved from http://www.omafra.gov.on.ca/english/landuse/imp2019.pdf
[7] Government of Canada. 2020. Agriculture and water quality. Retrieved from https://agriculture.canada.ca/en/environment/watershed-protection/agric…
[8] Farm Credit Canada. 2023. FCC Farmland Values Report. Retrieved from https://www.fcc-fac.ca/en/knowledge/economics/farmland-values-report.ht…