Comments on Co-ordinated Land Use Plan Review, 2015

Author: Jenn Kucharczyk

Posted: May 28, 2015

Categories: Member Feedback / News from Sustain Ontario

For the last several months, the Ministry of Municipal Affairs and Housing, the Ministry of Natural Resources and Forestry, and the Niagara Escarpment Commission have been working closely with a number of other ministries to conduct a co-ordinated review of four provincial land use plans: the Growth Plan for the Greater Golden Horseshoe, the Greenbelt Plan, the Oak Ridges Moraine Conservation Plan, and the Niagara Escarpment Plan.  These plans play a critical role in planning for the future of food and farmland in the province. Led by Sustain Ontario member, Ontario Farmland Trust, a small member-led working group (Golden Horseshoe Food and Farming Alliance, Farms at Work, and Waterloo Region Food System Roundtable) has prepared a submission on behalf of the alliance. Sustain Ontario submitted the following comments and recommendations on the Coordinated Review to the Environmental Bill of Rights registry on May 28, 2015.

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Dear Mr. Stromberg:

 

Re: EBR #012-3256 – Coordinated Review of the Growth Plan for Greater Golden Horseshoe, Greenbelt Plan, Oak Ridges Moraine Conservation Plan and Niagara Escarpment Plan

 

On behalf of Sustain Ontario, we would like to thank you for this opportunity to share some comments and recommendations as part of the 2015 Coordinated Land Use Plan Review process (“4-Plan Review”). Sustain Ontario is a province-wide, cross-sectoral alliance of over 80 organizational members that work together to promote healthy food and farming.  Sustain Ontario supports the intent of these 4 land use plans to protect agricultural land and support a viable agricultural system. This submission to the 4-Plan Review process is a result of a member-led 4-Plan Review working group, and does not necessarily represent the views of all Sustain Ontario members.

Farming, local food, and farmland are important parts of complete communities – both urban and rural. That is why Sustain Ontario and its members are strong supporters of preserving and encouraging their growth.

We are very encouraged to see land conservation plans being reviewed alongside the growth plan for the entire Greater Golden Horseshoe (GGH) area. It is critical that the relationship between these plans is recognized and understood: urban growth management is an essential complement to land conservation. Proper land use planning for our urban areas is just as important as land use planning for the protection of agriculture, nature and our rural countryside.

Growth planning directly impacts land conservation and complete communities – emphasizing denser forms of development within existing settlement areas and maximizing use of existing infrastructure (eg. intensified residential development along transit corridors) reduces urban sprawl and the loss of near-urban productive farmland and natural resources. Southern Ontario and the GGH contains some of the best farming soils and climate in Canada, and is home to extensive farm infrastructure and established, invested farming communities. These factors have made agriculture the #1 most stable, long-term driver of Ontario’s economy. Rich farmland provides the foundation of Ontario’s agricultural system. This farmland is a non-renewable resource – once it is converted and developed for another use it is gone forever. As a core principle we believe that all working farmland in Ontario should be permanently protected for its ‘highest and best use’ for food, farming and agriculture, for the benefit of all Ontarians.

Great strides have been made in provincial policy in recent years to recognize the strategic importance of protecting farmland and Ontario agriculture. However there continue to be opportunities to strengthen and broaden government support for local food and farming. It is through this food and farming lens that Sustain Ontario has listened to feedback from our members and partners to offer the following recommendations to improve the 4 Plans during this public consultation period. These important plans shape the future of agriculture, land conservation and urban growth in the Golden Horseshoe region and the Province at large.

 

Key Principles & Recommendations – Greenbelt Plan

Maintaining the Greenbelt vision and its existing boundaries and area are essential to upholding public confidence in Greenbelt protections and the long-term effectiveness of the related policy. We urge the government to maintain the Greenbelt Plan mandate and vision to establish “a broad band of permanently protected land… which protects against the loss and fragmentation of the agricultural land base and supports agriculture as the predominant land use.” To this effect, Sustain Ontario recommends the following actions:

• Do not permit settlement area expansions into the Greenbelt or ‘land swaps’ that allow some lands to be removed in one area and added in another, or any reduction of total Greenbelt protected area.
• Develop a clear and rigorous process for review of any future proposals for settlement area expansion from towns and villages within the Greenbelt’s Protected Countryside.
• Recognize that the Niagara Escarpment and Oak Ridges Moraine policy boundaries are based on geological features that can’t be moved. To protect these features, existing boundaries must be maintained.

 

In addition to maintaining  the current Greenbelt mandate, opportunities to expand and grow the Greenbelt should be considered as part of stronger Ontario-wide policy development. There is much prime farmland and many valuable agricultural communities outside of the Greenbelt area that would benefit from greater protection in provincial policy. Policy approaches and strategies for protecting farmland and managing growth need to be coordinated across all of Southern Ontario. The Greenbelt Plan’s “Natural Heritage System” designation offers a model for ‘systems-thinking’ that can help address these coordination needs. We support Greenbelt Plan language that views agriculture as more than individual farms and farmlands (the backbone of the “Agricultural System”) in order to communicate and plan for maintaining broader connections within and across Greenbelt boundaries. Sustain Ontario recommends that the 4 plans are reviewed with the following considerations:

• Policy protections are consistent for farmland across the GGH in order to level the playing field for farmers and municipalities.

• Address outer-ring areas under ‘leapfrog’ development pressure, such as Greenbelt adjacent communities in Simcoe County, Brant County, Waterloo Region, Wellington County, and Niagara Region. If the Greenbelt boundaries are expanded, the potential for displacement of urban growth and leapfrog pressures into other communities on the periphery  and beyond the Greater Golden Horseshoe must be addressed.
• Expand on the concept of an “Agricultural System,” as it relates to landscape connectivity, essential farm community services and the unique water, energy, transportation, and infrastructure needs of Greenbelt farms that contribute to a viable agricultural economy. Relative to planning for Greenbelt “Natural Systems,” the Agricultural System concept is underdeveloped and poorly understood among planners and policy makers. More guidance and resources are needed for municipalities and planners to explain the dynamic elements of the Agriculture System and the relationship between agriculture, prime agricultural areas and other systems (ie. Natural System) throughout the Greenbelt countryside.

 

The outcome of the 4-Plan review must also provide more balanced protection of prime farmland and mineral aggregate resources.  Agricultural land, like aggregate, is also a finite, non-renewable resource in need of protection, and wise use and management. Moreover, aggregate extraction contradicts the Greenbelt vision of permanently protecting the farmland base from loss and fragmentation, as the typical result is permanent loss of agricultural resources. Very few requirements are in place to protect Agricultural Systems and features in particular from negative impacts associated with aggregate extraction. There are few explicit expectations for avoiding impacts to prime farmland or rehabilitating disturbed farmlands in the Greenbelt Plan. To improve long-term sustainability, Sustain Ontario recommends the following:

• Do not permit any aggregate extraction in Specialty Crop Areas.

• Discourage aggregate extraction in prime agricultural areas.
• Require full rehabilitation of all lands in prime agricultural areas back to agriculture after aggregate extraction.
• Prohibit aggregate extraction below the water table on Class 1-3 prime agricultural land, as rehabilitation of this prime farmland resource is not possible.
• As part of impact mitigation on the agricultural community, require aggregate operators to ‘offset’ their impact by funding the permanent protection of at least an equivalent acreage of farmland that is disturbed as part of aggregate operations. This can be achieved using conservation easements or farmland protection easements, in collaboration with land trusts or other conservation bodies. (See development offsetting/impact mitigation recommendations in the Implementation section below.)

• Regulate commercial fill by stopping the dumping of excess, contaminated soil and fill materials onto farmland in the Greenbelt and all agricultural lands across the Greater Golden Horseshoe and throughout Ontario

 

While we believe strongly in planning for the protection and enhancement of riparian lands and associated biodiversity, we recommend that any further discussion of the Rouge North Management Plan is made consistent with the Rouge National Urban Park plans developed by farmers and conservation groups over the past several years in collaboration with community stakeholders. This plan presents a great opportunity to use public lands to enable farmers to produce local food that nearby urban areas desire. The Greenbelt Plan should recognize the national park planning that is underway, ensure consultation with local stakeholders and balance the needs of agriculture and environmental conservation efforts.

 

Key Principles & Recommendations – Growth Plan for the Greater Golden Horseshoe

As with the Greenbelt Plan, establishing and maintaining settlement area boundaries are paramount for upholding public confidence in the effectiveness of these plans to protect natural and agricultural systems. Research by the Neptis Foundation shows that the ample land designated for urban uses can accommodate all growth needs through 2031. To this effect, Sustain Ontario recommends the following:

• Set firm urban boundaries for the next 15-20 years in order to force densification and prevent unnecessary urban development of prime agricultural land.
• Penalties for municipalities that expand their growth boundaries and approve developments that contradict and undermine Growth Plan targets and policies

• Expressly indicate that the Whitebelt, which has some of the best farmland in Canada, should only be used as a proven last resort for future urban development.

• Manage leapfrog development pressure so that any new development must be adjacent to existing settlement areas. Growth Plan policy currently enables this type of sprawl and undermines farmland protection efforts, contradicting other provincial policy.
• Support municipalities that go beyond the minimum standard (eg. Waterloo Region’s Countryside Line and Protected Countryside designation, Permanent Land Protection Areas, higher density targets); and require that municipalities conform to and meet targets.

• Reject the Ontario Municipal Board (OMB) decision in Waterloo Region that concluded municipalities don’t have to meet the intensification targets that they set. Encourage a planning view that budgets land based on new targets, not historical development trends.

• Raise the bar on intensification targets and expectations. Neptis Foundation research indicates that current targets are lower than market demands, and that many municipalities have been permitted to treat “minimum targets” as “maximum requirements,” with some targets not even meeting the minimums.

• Update development charges and incentives to encourage and enable the desired types of development (eg. infill, densification, close to transit, brownfield redevelopment) with greater alignment between provincial planning policy and local planning implementation tools.
• Require that transit planning supports land use planning. Municipalities should be required to pre-zone for appropriate mixed-use densities along transit corridors.
• Dedicate more resources toward helping municipalities get up to speed on zoning updates. Few municipalities have updated sufficiently to enable the Growth Plan vision.

• Shield farms from urban land use influences by:
  • Making urban-side developers responsible for the creation of buffers;
  • Developing provincial or regional edge-planning guidelines; and
  • Developing Agricultural Growth Plans.

 

Implementing these recommendations will ensure that municipalities update their development frameworks to better integrate long-term farmland preservation and local food systems into their land use management policies.

 

Supporting the  Implementation of Plan Objectives

There are a number of new tools and approaches that can help support the implementation of the 4-Plan objectives and the incorporation of these recommendations. Examples include agricultural easement programs, development offsetting, new farmer and farm succession support, and dedicated record keeping and performance evaluation. Sustain Ontario recommends the following approaches:

• Launch a Farms Forever Agricultural Easement Program, originally envisioned as a complementary and value-add ‘implementation tool’ for achieving provincial plans’ objectives when it was introduced as a 2014 election campaign commitment of Premier Wynne. The program would support targeted and permanent farmland protection to curtail urban sprawl. Voluntary easement agreements and related incentives support farmers, farm succession and investment in local food. They empower farmers and communities to engage with and plan for the long-term protection and viability of local farms.

• Organizations like the Ontario Farmland Trust are already in place and can help the Province deliver farmland protection easements and a Farms Forever program in the Greater Golden Horseshoe and throughout the province.
• Partnering with Land Trusts can guarantee permanent, lasting protection that is buffered from development pressures and changes in political commitment in the future.

• Establish a Development Offsetting Requirement using a minimum 1:1 ratio to “offset” greenfield land permanently lost to urban development or aggregate operations with land that is permanently protected. We recommend focusing initial program designs on changes to the Greenbelt area (eg. impact of GTA West Transportation Corridor removing land from the Greenbelt).

• Support land conservation via Ontario’s Cap-and-Trade Climate Change Mitigation Initiative as a source of funding for farmland protection easements and partnerships with land trusts, in combination with the recommended development offsetting. This model is similar to California’s cap-and-trade initiative that funds the state Sustainable Agricultural Lands Conservation Program.
• Support and encourage new farmers and farm succession throughout the province, especially in areas that are in or close to urban areas.
• Create performance indicators for monitoring the progress of farmland preservation in more detail than what is provided via census data. Work with planners to develop new benchmarks that can track the 4-Plan objectives with respect to farmland preservation.

 

By taking immediate action on farmland preservation, setting higher targets for intensification, and building up an enabling environment for new farmers and farm succession, we believe these recommendations will support the Province’s commitment to the long-term sustainability of our finite shared resources.

Thank you for considering our comments and recommendations on the Coordinated Land Use Plan Review.

 

Sincerely,

Carolyn Young                                               Karen Hutchinson
Director, Sustain Ontario                             Vice Chair, Sustain Ontario Advisory Council

 

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Sustain Ontario is a cross-sectoral alliance that is working to create a food system that is healthy, ecological, equitable and financially viable. Sustain Ontario works collaboratively to connect members, showcase food system innovations and champions, explore and research pressing food system issues, and advocate for a healthy and sustainable food system. With over 80 members representing the diversity of Ontario’s food and farming sectors, Sustain Ontario’s reach is province-wide.

Sustain Ontario is a project of Tides Canada Initiatives Society (TCI).  TCI is a shared administrative platform that provides professional organizational support (e.g. governance, financial management, HR, and regulatory compliance) to 40 social justice and environmental projects.

 

References

(1) R. Allan and P. Campsie. “Implementing the Growth Plan for the Greater Golden Horseshoe: Has the strategic regional vision been compromised?” Neptis Foundation, 2013. p. iv.

(2) Allan and Campsie, p. ii.