Letters & Submissions

December 21, 2022

Attention: Growth Planning
Provincial Land Use Plans Branch
Ontario Ministry of Municipal Affairs and Housing
College Park, 13th Floor, 777 Bay St.
Toronto, ON
M7A 2J3

Re: ERO 019-6177 Review of A Place to Grow and Provincial Policy Statement

Dear Ministry,

The Christian Farmers Federation of Ontario (CFFO) is an Accredited Farm Organization representing the interests of over 4,000 farm families in Ontario who are called to the vocation of farming. CFFO policy promotes economically, socially, and environmentally sustainable farming, advocating that farmers receive fair return for their production and stewardship efforts.

The CFFO is concerned about the protection of productive agricultural land. Ontario’s farmland is valuable as the foundation for the significant economic contributions of our agri-food sector. Farmland also provides many important environmental goods and services. Productive farmland is vital to our food security, here in Ontario and globally. All these benefits need to be appropriately considered when reviewing policies that may increase farmland loss in Ontario.

The CFFO values policies that address important regional differences across Ontario. Ontario is both large and diverse. Land use planning policy needs to recognize and fairly address specific regional differences to ensure the best use of land in each unique region of the province. The CFFO also wants to see stronger protections on farmland in provincial and municipal land use planning.

In particular the CFFO recommends that:

1. Policies from A Place to Grow which encourage greater density within settlement area boundaries be applied in the GGH and large and fast-growing municipalities across the province.
2. Provincial mapping of prime agricultural areas be consistently applied across the province (as has been done in the GGH).
3. Current requirements to conduct AIAs in A Place to Grow be required in the GGH region and in large and fast-growing municipalities with adjacent productive farmland across the province.
4. Rural residential settlement focus on increased density within towns, hamlets and villages rather than through lot creation.
5. Increased lot creation should not be permitted in prime agricultural areas or in rural areas that are actively farmed.
6. Additional residential units be permitted on a farm property provided no future severance is possible for the added residence(s).
7. Minimum Distance Separation (MDS) formula continue to apply across the province, including when establishing new settlement area boundaries.
8. Protections for farmland concerning aggregate extraction found in the PPS 2020 be retained or strengthened.

A Place to Grow
A Place to Grow was developed in conjunction with the Greenbelt Plan, the Oak Ridges Moraine Plan and the Niagara Escarpment Plan to work together and direct growth in our most populace region in order to protect important natural features, including our most productive farmland, and to ensure development of complete communities that also make the best use of public infrastructure investments.

We have seen significant benefits from the policies in A Place to Grow that encourage increased density within settlement area boundaries, especially in proximity to key infrastructure such as public transit. The CFFO recommends that, across the province, A Place to Grow policies that support increased density should be applied in large and fast-growing municipalities to encourage complete communities and protection of productive farmland outside settlement area boundaries.

Agricultural System and Agricultural Land Mapping
Within the GGH region, the province has defined, identified and mapped prime agricultural areas. This ensures that a consistent definition is being applied in all municipalities across the region and that policies intended to apply to prime agricultural areas will be fairly applied. This also alleviates cost and staff burden from municipalities.

The CFFO requests that the provincial government should continue to identify and map prime agricultural areas across the province, beginning with those counties outside the GGH which have the highest quality farmland in proximity to large or fast-growing settlements. This will ensure that provincial interests of protecting farmland are appropriately and fairly applied and reduce costs to municipalities.

Agricultural Impact Assessments
It is important that municipalities consider the province’s Agricultural Systems mapping and Agricultural Impact Assessment (AIA) guidelines before they make decisions about where settlement areas will expand. Municipalities need to choose sites less suitable for farming that will not jeopardize the viability of surrounding farm businesses.

The province has developed excellent guidelines on how to conduct an AIA. The CFFO recommends that the current requirements to conduct AIAs in A Place to Grow be required in the GGH region and in large and fast-growing municipalities with adjacent productive farmland across the province.

Lot Creation and Severances
There is significant opportunity to increase density within rural settlement areas. This should include focus on intensification and redevelopment within settlement areas boundaries. Rural settlements can accommodate far more “missing middle” type density increases, including multi-unit housing of various types. These should focus on ensuring living accommodations suitable for family members and farm workers living off-farm and for seniors who wish to remain within their preferred community and maintain family and community connections through their entire lives. The CFFO encourages increased rural residential settlement within towns, hamlets and villages rather than through lot creation.

It is not only our highest classes of farmland that deserve protection. All arable land has the capacity to produce food. Classes 4-7 land are often ideal for livestock production and can be improved for crop production through good stewardship. Microclimates for growing particular crops are found in different regions of the province beyond those currently defined as specialty crop areas.

The CFFO has long argued for the importance of continued protection of the highest quality farmland by region, even where that farmland may be defined as class 4 or lower. This helps to preserve the local food-producing capacity of each region and to preserve our overall food security as a province. The impact of severances or lot creation must be considered for all farmed land, not only prime agriculture land.

The CFFO does not support residential lot creation or severances in prime agricultural areas or in rural areas that are actively farmed.

The CFFO does not support permitting new residential lot creation or severances in prime agricultural areas beyond what is permitted in the Provincial Policy Statement, 2020, which in section 2.3.4.1 (c) permits severance of a “residence surplus to a farming operation as a result of farm consolidation, provided that: 1. the new lot will be limited to a minimum size needed to accommodate the use and appropriate sewage and water services; and 2. the planning authority ensures that new residential dwellings are prohibited on any remnant parcel of farmland created by the severance. The approach used to ensure that no new residential dwellings are permitted on the remnant parcel may be recommended by the province, or based on municipal approaches which achieve the same objective.”

Severances, or lot creation, have been a controversial issue in the countryside and continue to cause problems, especially for farm operations. While the initial impetus for lot creation may be for family members, such as for a retirement property or adult siblings, once the lot is created there is no guarantee of a continuing relationship with abutting farming operations either as family or workers. These lots often end up purchased by those looking for a bucolic lifestyle away from the city, but who are unfamiliar with normal farm practices. This can create conflict between neighbours and increased risks for farm operations.

Rural lot creation outside settlement areas can have negative impacts on existing and future farming operations for many reasons. While Minimum Distance Separation rules must be followed based on existing operations, a new residence creates a “shadow” that may limit future establishment or expansion of animal agriculture operations within the vicinity of the new lot.

Farmland values can also be impacted. Allowing severances can unfairly increase the cost of farmland by encouraging overpayment for a parcel of farmland on the expectation of the subsequent severance and sale of a lot from that parcel to cover the added costs. This inflates farmland values in the area, which is particularly troubling for new and expanding farming operations.

The CFFO supports permitting additional residential units on a farm property provided no future severance is possible for the added residence(s). There is significant potential for increasing rural housing options by permitting secondary dwelling units as part of existing residential properties in rural areas. Increasing housing options in this way minimizes potential impact on surrounding farmland and farming operations.

Minimum Distance Separation and Settlement Areas
Many different land uses are competing for space, especially within the most populated areas of the province. Our most productive agricultural land is predominantly found in these highly populated regions of the province.

It is important that land use planning appropriately considers potential impacts of neighbouring land uses, be they agricultural, industrial, residential, or other types of land uses. Agricultural uses, especially in the most populated regions of the province, will need to be effectively planned with many other types of land use in close proximity. Good planning will help to ensure the ongoing vitality of the agricultural sector in these regions of the province.

Minimum Distance Separation is an excellent and well-established tool to ensure risks are minimized when farming and other types of land use are in close proximity. OMAFRA has excellent tools and training to assist municipalities in implementing MDS policies, which should be more widely promoted. No settlement area boundary should come closer than the MDS calculated distance from an existing farm operation. It is vital that MDS formula continue to be applied across the province, including when establishing new settlement area boundaries.

Agriculture and Aggregates
The CFFO recognizes the need for different resources that supply development of housing, including aggregates. While aggregate extraction close to development has its advantages, it is also important to consider the broader impacts of aggregate extraction over the long-term.

While aggregate extraction is considered a temporary land use, it has permanent impact on the land in question. In particular, aggregate extraction on existing farmland immediately takes that land out of production, often for many years. While policies exist to encourage remediation, the quality of remediated land for agricultural production is significantly diminished. Ensuring remediation occurs has proven problematic. Furthermore, if extraction moves below the water table, remediation is no longer possible.

At a minimum, the CFFO wants to see protections for farmland concerning aggregate extraction found in the PPS 2020 retained. We do not support more permissive policies regarding aggregate extraction that would see more productive farmland lost, temporarily or permanently, especially in areas under the greatest development pressure.

Conclusion
In a context of increased pressure for housing development, productive farmland will be put at much greater risk of permanent loss. Land use policy needs to fairly balance provincial interests for increasing housing supply while still protecting our vital resources, including natural heritage features and our productive agricultural land.

The CFFO strongly encourages that growth be directed within existing settlement areas. The CFFO supports policies from A Place to Grow which encourage greater density within settlement area boundaries, and recommends they be applied in the GGH and large and fast-growing municipalities across the province.

The CFFO wants to see provincial mapping of prime agricultural areas consistently applied across the province (as has been done in the GGH). Current requirements to conduct AIAs in A Place to Grow should apply within the GGH region and in large and fast-growing municipalities with adjacent productive farmland across the province.

Rural residential settlement needs to focus on increased density within towns, hamlets and villages rather than through lot creation. Increased lot creation should not be permitted in prime agricultural areas or in rural areas that are actively farmed. However, permitting additional residential units on a farm property provided no future severance is possible for the added residence will support increased housing options.

Minimum Distance Separation (MDS) formula must continue to apply across the province, including when establishing new settlement area boundaries. The CFFO wants to see protections for farmland concerning aggregate extraction found in the PPS 2020 be retained or strengthened.

We appreciate this opportunity to provide input and thank you for your consideration of our concerns and comments.

Sincerely,

Ed Scharringa, President
Christian Farmers Federation of Ontario