By Kate Russell
Farmers across the province are concerned about recent changes in process and development around agricultural lands and planning policies.
As we heard late last year, when Bill 23 was passed by the Ontario government, Greenbelt areas and wetlands are under threat of development with the More Homes Built Faster Act. The act includes changes to several other pieces of legislation including the Planning Act, the Conservation Authority Act, the Development Charges Act and the Ontario Land Tribunal Act.
In an Ontario Federation of Agriculture viewpoint opinion from OFA Vice-President Drew Spoelstra, back in November after the bill was passed, the challenge of farming close to urban areas was addressed.
“The Ontario government announced it is proposing to rezone thousands of acres of prime farmland in the Greenbelt and other regions to build up to 50,000 new homes,” wrote Spoelstra, whose family farms just outside the urban boundary of the City of Hamilton, which happens to be in the Greenbelt. “That’s a change that’s of serious concern to the OFA.”
Citing 2021 Census of Agriculture, Spoelstra wrote that farmland losses are already at an incredible 319 acres per day in our province.
“Farmland is farmland no matter what colour its belt is or what designation it receives,” he said. “Once it’s lost to development, it is gone forever, and that’s why preserving it is one of the OFA’s top priorities.”
Spoelstra attended a politicians’ day, hosted by the Bruce and Grey County Federations of Agriculture, back in late March, where he noted the OFA had made presentations to the provincial Standing Committee on Heritage, Infrastructure and Cultural Policy about Bill 23.
“We want to make sure we have the ability to perform agricultural activities in our counties,” Spoelstra said at the politicians’ day, adding a detailed submission to the standing committee, available in the OFA’s website resources, “drills down through Bill 23.”
The submission takes the form of several letters, signed by OFA President Peggy Brekveld. While applauding the province’s efforts toward addressing Ontario’s housing crisis, they each note various concerns about actions which may affect agricultural land, which currently makes up only five per cent of the province’s land base.
“The OFA opposes any re-introduction of severances in agricultural areas and desires to work with the Ontario government to increase density and housing in rural Ontario in ways that do not sacrifice farmland,” the submission reads, in response to continuing urban sprawl which is eating up farmland. “Agricultural lands are a finite and shrinking resource. We cannot sustain continuing losses of agricultural land while maintaining our ability to produce food, fibre and fuel from this limited and declining agricultural base.”
It seems clear the province was not necessarily listening to these concerns, as on April 6, a new proposed Provincial Planning Statement (PPS) was released. It was written to clarify and expand the 2020 Provincial Policy Statement and A Place to Grow: Growth Plan for the Greater Golden Horseshoe (A Place to Grow) 2019, across the province. This new PPS not only allows for additional (up to three) severances on agricultural lands, it also appears to permit rural plans of subdivision and condominium.
Where Bill 23 sought to remove protected lands from the Greenbelt, reduce Conservation Authority oversight on natural heritage areas and even seek protected lands to be sold for development, it also sought to remove third-party appeals and public meetings around plans of subdivision.
“It diminishes opportunities for meaningful public engagement and stakeholder input,” the OFA submission reads. “As Ontario becomes more urbanized, farmers increasingly need to engage with their municipalities in land use planning, as councils and staff may not apply an agricultural lens.”
In Grey County, Director of Planning Scott Taylor is well aware of agricultural concerns. In a recent Agricultural Advisory Committee meeting, he presented a report on the proposed PPS, which he finds is much more concerning for agriculture than Bill 23.
“At the county and municipal levels we’re struggling with Bill 23,” he said in an interview after the meeting, noting Grey County has hired a planning ecologist to take on some of the review process removed from Conservation Authorities in the act. Referring to his report on the PPS, he observed there is “no one voice of farmers,” as many on the advisory group saw some parts of the new PPS as positive, even though it may have “some deleterious impacts on farmers.”
He suggested some farmers may welcome being able to sever additional lots to help with economic need or to purchase ever-more-expensive equipment. But, he added, from a planning perspective, the potential of severances and additional residential units (ARUs) on farms, which could also potentially be severed now under the new provincial policy may have huge impacts on farmland across Grey and other parts of the province.
“We did a sample analysis across the county and it could result in 10,000 residential lots within our agricultural lands,” he said, stressing this took the assumption each owner would want to sever property. With an estimated lot size of one to two acres, this could remove 5,000 acres from agricultural production. “It would be much more efficient to create new lots within settlement areas.”
His report also included a look at minimum distance separation (MDS) which would affect existing and sometimes overlapping areas and add to congestion as new lots would adversely decrease available space for new barn builds for livestock operations.
“For every new residential lot created, this would cast a larger shadow in which livestock operations could not be sited or expanded,” Taylor explained in his report, using a sample land block as illustration. By using a map with MDS added, his report showed the amount of land potentially removed from production. “The actual impact on agriculture, particularly livestock production, would be much greater based on the impacts related to MDS formulae.”
Taylor also noted, the PPS is unclear on many details, with the entire natural heritage portion of the policy not included in the draft as it indicates “policies and related definitions remain under consideration by the government” at the time of the proposed PPS release on April 6.
“The intent of the proposed PPS is to accelerate the development of housing and to increase the housing supply in Ontario,” Taylor’s report read. “However, staff do not believe the agricultural lands are the appropriate location for increased residential development and lot creation.”
He also noted concerns of unintended consequences of these new policies could be to drive up the price of farms across Ontario. If a landowner selling a farm knows that the future buyer can sever up to three lots from the farm, it could dramatically increase the asking price of that farm.
“This may have the effect of creating an additional barrier to entry for young farmers,” the report read, “or creating an additional tax burden on existing farmers (ie. if the assessed value of their farm increases).”
Finally, from a recognition of the need for housing, as seems to be the impetus for both Bill 23 and the proposed PPS, Taylor noted both seem to be seeking more housing in rural areas. These homes are often not on services, have septic systems which create need for capacity of pump out and disposal and generally do not have access to transit, so require vehicles and large front-end costs for building.
“Our most critical need is for affordable and attainable housing for lower income people,” he said, in wrapping up his interview comments, noting rental housing and townhouses in settlement areas are more likely to provide affordable living. “Our concern is if we have rural agricultural lots, is it providing the kind of housing we really need?”
The OFA submission about Bill 23 is available onthe OFA website. The Grey County Planning report to the Agricultural Advisory Committee is also online at Grey County’s website.
Taylor’s report will go through the Grey County council review process and be forwarded to the province as a comment on the PPS. The proposed PPS is online on the Environmental Registry of Ontario at https://ero.ontario.ca/notice/019-6813. Comments on the proposal will be accepted by the province until June 5. ◊