In considering the proposed…

In considering the proposed legislative changes, we respectfully provide the following comments for consideration:

1. County Planning staff have significant concerns over the potential fragmentation of agricultural land and the agri-food network through permissions for multiple, private sewage systems of up to a combined capacity of 50,000 litres per day to be located on one farm. The increased capacity permissions do not limit the amount of sewage systems, save and except limiting the system for non-employees to 10,000 litres per day. The current policy proposal could allow for a cluster of systems located on one lot, which would lead to an expansion of the farm property’s farm building cluster. Each system would require minimum clearance distances between other systems located on the property which would expand the Farm Building Cluster existing on an agricultural lot and remove lands from agricultural productivity. There is also concern that distancing ‘farm worker housing’ from the farm cluster could give opportunity for future severances of these units from the overall farm lot. There does not appear to be a safeguard in place within the current proposal to avoid these potential impacts. Perth County requests the Province to implement such safeguards to protect the Province’s agri-food system.

2. Perth County’s Chief Building Officials have concerns surrounding the lack of detailed design criteria included within the proposed modifications to calculate design capacity. The proposed policy should be extremely clear with how the Province intends building officials to calculate design capacity. As currently written, the 50,000 litres per day per lot implies that any other uses on the property requiring sewage capacity would be subtracted from the 50,000 litres per day and only the leftover capacity would be available for worker housing. If there were no other uses requiring septic capacity, then all 50,000 could be used for worker housing presumably. It is also presumed that all other uses requiring septic capacity must collectively remain under the 10,000 limit. Other uses on farms that may take up some of the sewage system capacity include on-farm diversified uses, non-employee related housing, laundry and washroom facilities, and floor drains. The Chief Building Officials request that the Province clarify the modifications with design criteria before implementing the modification.

3. Planning Staff and the Lower Tier Chief Building Officials have concerns about the permanence of the capacity increases, regardless of the amount of farm labour needed over time. As it is currently written, if a change in the farming operation occurs, that results in less labour being required, the 50,000 liters per day per lot capacity stays the same. This can lead to housing that was once used for farm labour being used for non-farm related housing and income opportunities for farmers such as agri-tourism and short-term rentals. It is further anticipated that the argument will be made that capacity of the infrastructure investment needs to be utilized to support farm income. County and local staff request that the Province implement safeguards to ensure capacity increases are dedicated solely to farm worker housing and restrictions are placed on capacity once the need for farm worker housing subsides.

The following general comment is provided regarding commenting timelines for Bill 60:

1. Over the past year alone, there have been at least 12 bills and regulations released by the Province that have significantly changed the planning policy and development framework within Ontario. The frequency in which policy changes have been released by the Province and the short commenting periods associated with each change are not conducive for meaningful feedback, as municipal staff are not provided an appropriate amount of time to understand the implications of Provincial directions before the next round of changes are released. The rapid-fire release of legislation changes, combined with limited staffing capacity and statutory review timeline requirements, negatively impacts County planning staff’s ability to provide meaningful comments on such policy changes. Meaningful comments are not possible where staff are only given a matter of days to review, digest, understand, and comment on legislative changes being made to dozens of Acts. Further, frequent release of omnibus bills at the Provincial-level takes away staff’s focus from local policy initiatives. A month spent on reviewing, understanding, and commenting on provincial policy changes is a month taken away from updating policies and regulations that are already outdated at the local level.

The above-noted comments have been discussed by County Council and endorsed for submission to the Ministry for consideration regarding the important amendments proposed through ERO Number 025-0900.