On behalf of the Ontario…

On behalf of the Ontario Federation of Agriculture (OFA) please find attached our submission.

OFA appreciates this opportunity to provide input to ERO #019-6177 Review of A Place to Grow (APTG) and Provincial Policy Statement (PPS) as the Ministry of Municipal Affairs and Housing (MMAH) seeks input on how to create a streamlined province-wide land use planning policy framework that enables municipalities to approve housing faster and increase housing supply. OFA sees that a merging of APTG and the PPS must demonstrate that provincial direction is explicitly satisfied to ensure all provincial interests are protected and balanced across Ontario. We are not against development but want to see provincial policies and legislation that meet the goals of all these provincial interests, without undermining Ontario’s agricultural resources. We emphasize that many components of the current PPS are working well to achieve both goals of building houses and protecting farmland, and requests the provincial government recognize this and retain these beneficial policies.

OFA sees that APTG policies on urban intensification and densification must be included within the PPS for every municipality across Ontario to ensure the strength of the growth management framework provided by APTG is not lost. OFA supports fixed, permanent urban boundaries to limit the loss of agricultural land, thereby focusing future urban growth within existing urban boundaries. We further believe that in urban areas, higher density development should be mandated province-wide to take full advantage of existing infrastructure. OFA supports urban intensification/densification to protect agricultural land and create complete communities.

OFA wants to see PPS policies in Section 1.1.3.8 (Settlement Area Boundary Expansions) remain as is. Keeping these policies intact 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 PPS policies on settlement area boundary expansions (APTG Policy 2.2.8.3 h). OFA asks that the Ontario government should designate all farmlands in Ontario that are outside of current settlement area boundaries as Greenbelt and afford them permanent protections from the threat of urban development.

PPS (2020) Policies 2.3.1 and 2.3.2 outline policies for the protection of prime agricultural areas, the designation of prime agricultural areas and specialty crop areas by planning authorities. OFA wants these policies to remain intact.

OFA sees that APTG (2020) Section 4.2.6 Agricultural System policies must be retained in the review of APTG-PPS. OFA wants to see the Agricultural System mapped, and its policies applied, protected, and enabled provincewide. OFA supports the provincial mapping of the Agricultural Land Base, including identification of Candidate Areas for inclusion in the Agricultural Land Base. OFA requests that the government continue to review and update mapping upon a municipal request, as not all municipalities will have the capacity to undertake this work.

OFA sees Minimum Distance Separation (MDS) as an essential component of responsible land use planning that must continue to be in the revised APTG-PPS instrument. OFA maintains that both PPS (2020) Policy 2.3.3.3, requiring new land uses in prime agricultural areas, and Policy 1.1.5.8 requiring new land uses in rural areas, including the creation of lots and new or expanding livestock facilities, must continue to comply with MDS Formulae.

OFA wants to see an additional policy added to Section 2.3 Permitted Uses in the PPS. We request the following be added to clarify that on-farm accommodations for labour be permitted as an agricultural use, in accordance with PPS (2020) definitions and provincial guidance.

OFA supports the current lot creation policies under Section 2.3.4.1 of the PPS (2020) as is. OFA is utterly opposed to any re-introduction of lot creation policies in the agricultural area that may resemble policies in previous versions of the PPS. We desire to work with the Ontario government to increase density and housing in rural Ontario in ways that do not sacrifice farmland. Anywhere low-density housing already exists presents critical opportunities to advance “gentle density” that addresses the provincial housing supply, preserves farmland, and builds complete communities characterized by smart growth principles in land use planning.

OFA believes that in prime agricultural areas, the only permitted uses should be agricultural uses, agriculture-related uses, and on-farm diversified uses. OFA sees that the definition of development should be expanded to include a clause stating that “the full range of agricultural uses (as defined in the 2020 Provincial Policy Statement) do not constitute as development.

When comparing Natural Heritage policies between APTG (2020) and the PPS (2020), OFA prefers Natural Heritage policies under Section 2.1 in the PPS (2020). Natural Heritage System (NHS) policies in APTG (2020) have introduced red tape for our members with the requirement for costly environmental impact studies and the requirement to retain buffers from features, which further push development onto farmland and contribute to farmland loss and inefficient use of land for farming. We further believe that PPS Policy 2.1.9 succinctly speaks to the relationship between natural heritage features and areas and agricultural lands; “nothing in policy 2.1 [Natural Heritage] is intended to limit the ability of agricultural uses to continue”, and we expect this policy to be universally applied and complied with. OFA cannot underestimate the importance of ground-truthing as a mandatory requirement in the identification and designation of natural heritage features. OFA believes municipalities and relevant ministries should be required to notify landowners and tenants that an evaluation is being undertaken on their property.

Lastly, OFA sees that the “Analysis of Regulatory Impact” provided in the consultation does not accurately reflect the ability to achieve these core proposed principles in the new APTG-PPS instrument in a short timeframe. We understand the government is looking to ‘reduce red tape’ to get more homes built faster. However, we urge the government to recognize that frequent provincial reviews and changes to plans and policies are a barrier to new housing development. Municipal capacity is limited and lags when adopting changes to provincial plans. OFA asks the Ontario government provides a period of policy stability in land use planning once upcoming changes are in place.

OFA appreciates the opportunity to provide our feedback and agricultural perspectives on the review of A Place to Grow and Provincial Policy Statement. We must ensure that any future changes to Ontario's land use planning policy framework protect our agricultural land base and support our agri-food sector as an economic powerhouse.

Kindest regards.