Submission Text: This…

Submission Text:

This submission is regarding the proposed Provincial Planning Statement (2024). This submission is related to the Agricultural and Rural policies, definitions, and text. The submission is regarding our property in the City of Burlington, Region of Halton.

Background of our property

This property is an 18.48 ha sized parcel outside of the settlement areas in the City of Burlington. The property includes natural heritage features, a residence, and an agricultural building, as well as fields.

The Region of Halton and the City of Burlington have implemented the policies of the current Provincial Policy Statement (2020) and A Place to Grow relative to the Agricultural system using provincial mapping and guidance. The implementation is through the Halton Official Plan and the City of Burlington Official Plan. The work completed by Halton Region will be the responsibility of the City of Burlington to implement after July 1, 2024 when Halton Region ceases to have an upper tier planning role.

Our property is designated as part of the Agricultural System in the Halton Official Plan and more specifically “Agricultural System Outside Prime Agricultural Areas”. A portion of the property is within the Niagara Escarpment Plan Area and is primarily designated Escarpment Rural Area with a small portion being Escarpment Natural Area. Similar designations are included in the Burlington Official Plan (2020).

The Halton and Burlington Official Plan designations were implemented because of the policies in A Place to Grow for an agricultural system; the provincial guidance on the agricultural system; and provincial mapping of agricultural areas and prime agricultural lands.

The mapping in the Halton and Burlington Official Plans is incorrect. An independent analysis of this property was completed by a very well known consulting company to assess the agricultural capability of the property. This review was completed by a qualified professional agrologist. This analysis reviewed land use, soil capability through a soil survey, a planning review, property fabric in lands surrounding the Milburough property, and OMAFRA information including mapping and data.

The independent analysis concluded:

The lands are not specialty crop.
The lands have low capability soils.
The lands have limited cultivable land which limits the agricultural viability. The lands in the surrounding area are in similar circumstances.
There are a significant number of non-agricultural uses in proximity to the lands.
The lands surrounding our property are highly fragmented.
The lands are in close proximity to the Kilbride Rural Settlement Area.
There is no agrifood network nor agricultural infrastructure such as a road network or tile drains for the property or the general area.

The independent study confirms that the lands should be designated as Rural Lands and not Agricultural System outside Prime Agricultural Areas.

In addition to the incorrect designations, there are no policies in either the Halton Official Plan or the Burlington Official Plan specific to lands designated Agricultural System outside Prime Agricultural Areas. Our property is incorrectly designated and there is no policy direction on the planning matters of importance including permitted uses. This property is left in a quagmire of planning policy created by the agricultural system requirements of A Place to Grow.

Provincial Planning Statement (2024)

This document includes policy wording updates relative to matters that are important for the future of this property. Comments are as follows.

Policy 4.3.1 – This policy changes wording from “encouraged” regarding the agricultural system planning to “required”. This mandatory approach does not allow for flexibility in implementation of the policy. There is a significant difference between Agricultural Lands and Rural Lands. Forcing an agricultural system approach across Ontario does not recognize local differences and local priorities for both agricultural and rural lands. Nor does this allow local decision making on what is best for each community. At most the agricultural system should be considered in implementing the PPS (2024). This cannot, however, be considered without addressing other key items including investment in agricultural infrastructure. Farmers should not bear the burden of a “systems” approach – it is too restrictive.
Policy 4.3.5 – This policy identifies that the agri-food network and local food are “encouraged”. This too is the wrong approach. If agriculture and rural lands are to succeed, there must be investment in the agri-food and local food infrastructure.
Definitions:
The definitions in the proposed PPS (2024) move wording around between Agricultural System and Prime Agricultural Area definitions. But the fundamental requirement to rely on provincial mapping remains which cannot continue. In the instance of 6589 Milburough Town Line, the provincial mapping and the application of the provincial guidance is incorrect. Municipalities must be able to use their own local information including the input of farmers on the quality and capability of their lands. There is no reference in the policies or definitions to agricultural viability and that must be the first consideration.
Prime Agricultural Lands now includes Class 4-7 CLI lands. This ignores the reality of lower class agricultural lands coupled with the numerous factors that go in to determining agricultural viability such as parcel fragmentation, presence of natural heritage features, proximity to settlement areas, and presence of non-agricultural uses.
Rural Lands/Rural Areas – the agricultural definitions are very specific as to how they are determined based Canada Lands Inventory classification. There is little to no specific criteria on what constitutes Rural Lands and Rural Areas. Farmers know the lands best and the input from farmers and landowners must be included in how these determinations are made. Rural lands are often mischaracterized as agricultural lands due to limited criteria for agricultural lands. This cannot continue and direction on how to assess lands to be a rural designation must be provided.