Attention! Toronto Urban Growers Press Release!
Posted: June 21, 2017
Categories: GoodFoodBites
Toronto Urban Growers has a press release! Speak in favor of streamlining approvals for urban gardens! See below for the details.
The Province is currently consulting on updates to the Brownfields regulation (O.Reg 153/04). Toronto Public Health staff have identified a current opportunity to improve the site assessment and approvals process for urban food growing projects.
We are requesting your support for this initiative to help remove a barrier to starting up much needed community-led urban food growing projects. The proposal will likely garner more interest from the Province if it has support from across Ontario.
TPH has summarized some key points that you can include in a submission. Please note that the below summarized points are still a draft and have not yet been reviewed by the Medical Officer of Health.
The Opportunity – Deadline June 23rd, 2017
EBR#013-0299 can be found here.
The focus of this consultation is on the Province’s management of excess soil during major site remediation projects. However, the Ministry is also considering other amendments that would help to reduce burden and enhance clarify of the Ontario Regulation 153/04 (see note under Heading: Record of Site Condition Regulatory Amendments). This is where this proposal fits in.
What you (or your organization) can do
Submissions can be made on your organization’s letterhead or through an online comments form on the right-hand side of the page here.
It’s better if you can customize your submission, but if not, you can paste the text below with a line saying that you support the Toronto Public Health’s call for a streamlined approach.
The Importance of this Initiative
There is increasing interest in community-led urban food growing projects. These types of projects are often in priority neighbourhoods where access to food and green space are limited and incomes are typically low. For these projects, a Record of Site Condition (RSC) would be required. This requirement is based on the shift from a less to more sensitive land use (i.e., from commercial or parkland to agricultural land use) triggering an expensive and time-consuming site assessment and regulatory approval processes. The resources required to meet this regulatory hurdle exhaust the resources available for getting these projects started and significantly impair the creation of critically needed community food initiatives.
Proposed Solution
A. Streamlined and Tailored Approach for Urban Community-Led Food Growing Projects
As part of initiatives to innovate, the Ministry developed a Tier II site assessment approach to streamline RSC assessments for low risk, standardized sites. Unfortunately, this process does not include key risk assessment and risk management assumptions that are specific to urban food growing projects, for instance, non-permanent structures (i.e., no indoor air inhalation pathway), no groundwater consumption, no livestock production and above-grade container gardening as a risk management approach.
The Ministry could consider a streamlined and tailored approach to assessing sites for the purposes of small-scale, community-based urban food growing projects, analogous to the Tier II streamlined site-specific risk assessment approach. Assumptions that are tailored and standardized to urban food growing projects could be built into the approach, significantly simplifying the process to assess and manage potential risks while maintaining health objectives
B. Expedited Review Process
An expedited Environmental Approval Site Registry (EASR) process is already in place for other low-risk sites. In these cases, site assessments are conducted and signed off by a QPRA and filed on a transparent environmental approval site registry for automatic approval.
The Ministry could create an analogous provision for urban food growing projects. This provision would allow for an expedited review process facilitated by the local district Ministry offices
C. Finding a Solution in Time for the 2018 Growing Season
Given the urgency for improving access to good nutritious food, communities cannot wait another growing season for access to food grown in their own food growing projects.
The Ministry could initiate a working group to quickly identify how to leverage existing Ministry processes to develop an approach that could be ready by January of 2018. Under this timeline projects will be able to go through the site assessment and approvals process in time to break ground in the spring 2018.