Comments on Coordinated Review of Land Use Plans

Today, the members of the Sustain Ontario Farmland and Agriculture Network submitted a letter, outlining their feedback on the Coordinated Review of four plans: the Proposed Growth Plan for the Greater Golden Horseshoe, EBR Registry #012-7194; Proposed Greenbelt Plan, EBR Registry #012-7195; Proposed Oak Ridges Moraine Conservation Plan, EBR Registry #012-7197; Proposed Niagara Escarpment Plan, EBR Registry #012-7228; and Proposed Amendment to the Greenbelt Area Boundary Regulation, EBR Registry #012-7198. While the members gave specific comments on the various sections of the coordinated review of these four plans, the response as a whole was informed by three key principles:

• Prime Agricultural lands are a finite resource in the Greater Golden Horseshoe and should be afforded the highest protection available for their continued use for agriculture and local food production.

• Food Production is the best use for agricultural lands in near-urban areas where food can be grown close to people and sold fresh into local markets.

• There is a need to protect and support Ontario’s agricultural sector and farming communities and create an environment where a diversity of farm businesses can thrive and remain viable for generations to come.

RE:The Coordinated Land Use Planning Review, including the Proposed Growth Plan for the Greater Golden Horseshoe, EBR Registry #012-7194; Proposed Greenbelt Plan, EBR Registry #012-7195; Proposed Oak Ridges Moraine Conservation Plan, EBR Registry #012-7197; Proposed Niagara Escarpment Plan, EBR Registry #012-7228; and Proposed Amendment to the Greenbelt Area Boundary Regulation, EBR Registry #012-7198.

On behalf of the undersigned members of Sustain Ontario’s Farmland and Agriculture Network, we would like to thank you for this opportunity to share our recommendations as part of the Coordinated Land Use Planning Review process. The undersigned members support the intent of the recommendations of the Advisory Panel on the Coordinated Review of these 4 land use plans to protect agricultural land and support a viable agricultural system. While we have specific commentary on key sections of the document, as discussed below, our response to this is governed by three key principles, which in turn, yield a number of “big ideas.”

Key principles underlying our response

• Prime Agricultural lands are a finite resource in the Greater Golden Horseshoe and should be afforded the highest protection available for their continued use for agriculture and local food production.
• Food Production is the best use for agricultural lands in near-urban areas where food can be grown close to people and sold fresh into local markets.
• There is a need to protect and support Ontario’s agricultural sector and farming communities and create an environment where a diversity of farm businesses can thrive and remain viable for generations to come.

The Big Ideas

• We agree that provincial and municipal plans need to go beyond protecting farmland, to including protection for the entire agricultural support network. The agricultural system should be developed collaboratively with the farm community rather than being an additional layer of regulation that becomes burdensome for farmers and farm operations.
• We support efforts to introduce firm settlement area/ urban boundaries around all communities in the GGH. There is already a surplus of land set aside by municipalities to accommodate forecasted population growth for the GGH beyond 2031.
• We urge a 10+ year moratorium on any rezoning of lands within prime agricultural areas until Greenbelt and Growth Plan policies have proven to be effective at curbing non-agricultural development on farmland.
• We recommend that plans raise and enforce the intensification and density targets to accommodate new growth in communities across the GGH, and then follow through on implementation (monitoring and enforcing compliance of urban and rural municipalities) to ensure that urban sprawl is significantly reduced, urban and urban-designated lands are being utilized efficiently, and conversion of agricultural lands to urban use is firmly established as the last resort.
• We should enhance the GGH provincial plans and their implementation by linking land use policy objectives with the emerging provincial Farms Forever program (OMAFRA) and Ontario’s cap-and-trade program (MOECC); dedicating more resources to permanent land protection (land securement) and local food systems development in strategic areas, by working with land trusts and farmers within the agricultural system to strengthen the protection of farmland, improve land stewardship, grow more food for local markets, and by supporting new farmers who want to establish farms in the GGH.

• We see that the plan groups are still working in silos. More work must be done to make each plan work seamlessly with the others.

Suggestions Concerning Specific Recommendations

Reflecting on the recommendations of the Advisory Panel on the Coordinated Reviews, we offer the following suggestions in order to enhance the effectiveness of the Plans to build complete communities, support agriculture, protect natural heritage and water, strategically grow the Greenbelt, integrate appropriate infrastructure, improve plan implementation, and measure performance while increasing awareness and engagement. While not exhaustive, the following set of recommendations represents the priorities of the Farmland and Agriculture network of Sustain Ontario.

Building Complete Communities

• We would like to see the growing of food through urban agriculture, community gardens and other initiatives articulated as part of a complete community.

• To prevent further sprawl and support efficient use of land, urban centres must be held to intensification targets and firm urban boundaries. End municipal exemptions for intensification targets in urban growth centres.
• Build and invest in denser cities and align growth with existing public transit, water, road and sewer capacity. Prioritize investment in municipalities that meet their intensification and density requirements. Protect farmland along highway corridors.
• Community hubs should include food and agriculture hubs (places for people to come together around food like community kitchens or distribution points).

Supporting Agriculture

• When the Agricultural System is identified, clear guidelines for application of the System must be given.  The Province must work collaboratively with municipalities, local planners and the agricultural stakeholders  to identify the Agricultural System and its components in each community using local knowledge.   
• The Agricultural System must ensure that agricultural lands across the Greater Golden Horseshoe are not fragmented and are contiguous to each other, acknowledging that the Agricultural System crosses municipal boundaries and applies to the entire GGH and much of Southern Ontario
• Work on Edge Planning must be a priority with guidelines developed by the province.  Proper edge planning for non-agricultural uses that abut agricultural land will result in less urban-rural conflict
• Support for agriculture includes the infrastructure that is required. Access to transportation networks, natural gas, water, broadband and three phase power continue to be a priority.
• It is good to see harmonization of language in the four plans and that of the PPS to allow for agriculture-related uses and on-farm diversified uses that support value-added farm activity. We support small scale uses, but not industrial operations. Provide additional support to farming communities with enhanced policy guidance (eg. permitted uses, agricultural impact assessments, appropriate scale) and incentives for farmer-led land preservation, economic diversification, and local food production.

Protecting Natural Heritage and Water

• Maintaining a safe and long term water supply should be a priority of all Ontarians
• Watershed planning is currently being done by the Conservation Authorities. The role of the Conservation Authority should be clearly defined and articulated within the review to help implement the goals of protection of natural heritage and water
• Significant work needs to be done on the fill issue.  Municipalities must have a plan for what they are doing with excess fill and the receiving municipality must have stronger assurances that the fill is clean and not contaminated.  This has been treated as an issue between landowners but municipalities have long term liabilities for imported fill.
• No aggregate extraction should be permitted below the water table or in Prime Agricultural Areas.

Growing the Greenbelt

• Harmonize planning for any Greenbelt expansion between the Niagara Escarpment  and the broader Greenbelt area. Consult with municipalities, landowners and other community stakeholders in a meaningful way, acknowledging potential financial implications for affected municipalities and landowners
• The process to allow municipalities and individual properties to request inclusion in the Greenbelt Plan should be clearly articulated
• Provide  a clear criteria/rationale for what lands are included and excluded from any Greenbelt expansion so it doesn’t feel like arbitrary boundaries are being set by the Province. Communicate criteria with stakeholders and engage municipalities and communities throughout the process
• Recognize the potential financial impacts of permanently protected land designations on farmers and landowners. Introduce a farmland/conservation easement program that creates financial benefits for farmers whose farm business is negatively affected by an expanded Greenbelt policy area, or for farmers who voluntarily protect their land for farming in perpetuity with easements. This could be a program led by the Province in partnership with municipalities and land trusts like the Ontario Farmland Trust and the Langford Conservancy. One model to build on, that could be revived as a pilot initiative, is the 1995 Niagara Tender Fruit Lands Program

Integrating Infrastructure

• Transportation corridors (planned or conceptual) should take into account impacts on prime agricultural lands and the Agricultural System.  Removal of tender fruit lands in Niagara and other significant agricultural lands in the GTA for a transportation corridor would involve the loss of thousands of acres of prime farmland and place a huge cost burden on Canada’s food security and local food economy. Protect farmland along transportation corridors just as it is in the Greenbelt in Hamilton.
• Continued investment in major ports allows the Agricultural System to thrive and grow, makes our economy more resilient to plant closures and economic downturns, and reduces our transportation carbon footprint (i.e. Ports of Hamilton, Oshawa)

• Greater coordination should occur to place linear infrastructure in the same corridors.
• Broadband and natural gas for rural areas must be identified as critical infrastructure
• Planning priority should target “brownfield” areas for redevelopment (e.g. Hamilton planning to use prime farmland around its airport for industrial development instead of redeveloping abandoned U.S Steel/Stelco property), to ensure that transportation infrastructure (highways, airports) is fully utilized before new infrastructure is built on prime farmland and natural habitat.

Improving Plan Implementation

• Not enough integration yet between the plans. Not looking for total harmonization but looking for more standardization of definitions, methodology and consistency
• A  “level playing field” among municipal planning departments for agricultural business infrastructure projects is required (e.g., rural planning departments view a new barn as a barn, planning departments in the urban fringe have decided a new barn as a major industrial structure, adding at least a significant regulatory burden in time and cost to the project, if not outright denying approval of the project)
• Require that streamlining of regulatory burden be implemented
• Additional updating required of NEP policies to align with the ORM and Greenbelt plans

Measuring Performance, Promoting Awareness and Increasing Engagement

• Provincial Ministries and agencies should lead performance measurement of the plans through a monitoring group that includes representation from government and stakeholder groups that can provide data, as well as accountability and oversight.
• The monitoring group will develop measurements and assess the effectiveness of policies to:
  • protect agricultural lands,
  • streamline regulations,
  • prevent fragmentation of ag lands,
  • require municipalities to meet intensification and density targets (limiting urban sprawl), and
  • maintain active, working farms and food production over time

Sustain Ontario is a province-wide, cross-sectoral alliance of members that work together to promote healthy food and farming.  Our mission is to provide coordinated support for productive, equitable and sustainable food and farming systems that support the health and wellbeing of all people in Ontario, through collaborative action. This review process submission is a result of a member-led network on Farmland and Agriculture, and does not necessarily represent the views of all Sustain Ontario members.

We thank you again for the opportunity to respond to this report.  Sincerely, the Undersigned members of the Farmland and Agriculture Network of Sustain Ontario,

Clarence Nywening, President, Christian Farmers Federation of Ontario (CFFO)