OFA submission to the Standing Committee regarding proposed Planning Act changes as specified in schedule 6 of Bill 97
OFA does not support the Planning Act amendment specified in Schedule 6 of Bill 97 to give the Minister the ability to issue MZOs that are not consistent with policy statements, provincial plans and official plans. However, OFA understands the need for the Minister to have the power of an MZO and we support MZO usage in areas of the province that are without robust local planning processes. We have no objection to MZOs being used within the lands that would be considered the Urban Envelope.
As a strong advocate for the protection of Ontario’s farmlands for their long-term ability to produce food, fibre, fuel, flowers, and nursery stock, OFA is unable to support amendments to the Planning Act that would give the Minister or any other planning authority the ability to make planning decisions which are not consistent with the PPS 2020. On balance, the policies of the PPS 2020 represent the minimum standard in support of protecting the environment, farmland and public health and safety
OFA believes that farming is the best use for farmland. Ontario’s limited supply of farmland is a scarce resource, making up less than five percent of all the land in the province. It’s vital that Ontario has a strong, viable and sustainable supply of food products grown, harvested, and processed right here at home. Ontario’s shrinking agricultural land base is alarming. The current rate of loss is measured at 319 acres per day in our province, according to the 2021 Census of Agriculture. These losses are not sustainable.
Provincially, the protection of Ontario’s prime agricultural areas for their long-term agricultural use must be a key objective. It is one thing to think about housing the anticipated additional two million people that will reside in Ontario over the next ten years, but it is another to think seriously about how we will feed this increased population. Ontario’s agricultural lands are a finite and shrinking resource. We cannot sustain continuing losses of agricultural land while maintaining our ability to produce food, fibre, fuel, flowers, and nursery stock from this limited and declining agricultural land base. Therefore, any proposals looking at increasing housing supply must be done with consideration to the needs and support of the agricultural community.
While OFA does not support further lot creation and severances, we do support additional residential units on existing farm parcels, and in rural hubs, hamlets, and communities to support our agricultural system. As Bill 97 is the legislation enabling the policies within the proposed Provincial Planning Statement, OFA would like to establish our support for additional dwelling units subordinate to the principle dwelling on an agricultural parcel but do not support the establishment of additional lot severances on these parcels.
OFA endorses the 2020 Provincial Policy Statement (PPS 2020)’s Agriculture policies [Section 2.3] that require municipalities protect their prime agricultural areas for their long-term agricultural use. We further support the flexibility afforded to farmers to engage in on-farm value adding of primary farm products, as well as agriculture-related, on-farm diversified and agri-tourism uses. Although the PPS 2020 defines prime agricultural land as Canada Land Inventory (CLI) Class 1- 3 soils plus specialty crop areas, the OFA believes that prime agricultural lands should be defined as Class 1 to 4 soils plus specialty crop lands. Class 5-6 soils that are part of an ongoing agricultural operation deserve protection too. These soils can support agricultural activities such as grazing livestock or growing crops for biofuels, and their productivity can be improved through activities such as tile drainage, stone picking and the addition of lime. Where Class 1-4 soils are not present in a county or region, the best agricultural lands in that county or region should be recognized and protected for their agricultural use.
OFA is a strong supporter of the preservation of Prime Farmland classes 1, 2, 3 & 4 plus specialty crop lands across rural Ontario. We believe strongly in the PPS 2020 Agriculture policies that governs farmland and rural areas protecting the right to farm and the Agriculture System in Ontario. In addition to this, OFA believes strongly that lot creation and further fragmentation of farmland in the rural area is counterproductive for the agricultural business structure in Ontario’s rural areas. However, OFA supports additional residential units on existing farm parcels (but not on a severed lot from the farm parcel), and in rural hubs, hamlets, and communities to support our agricultural system.
In our previous submissions to the government regarding the PPS 2020, we have commented that the PPS 2020 does not go far enough in protecting our finite agricultural lands. We have recommended strengthening of the PPS 2020 in order to require fixed urban settlement boundaries and policies requiring mandatory intensification within the existing built urban areas as well as mandatory “greenfield” density requirements to better utilize infrastructure, improve the financial viability of public transit and protect our prime agricultural lands from sprawl.
We are concerned that amending the Planning Act in a way that would allow for planning decisions that are inconsistent with the PPS 2020 could open up the floodgates for a rash of developments that run counter to our overarching philosophy of farmland preservation which is paramount to our mission of “Farms and Food Forever.”
OFA additionally cautions against the alternations to the definition and policies for Employment Lands proposed in the Planning Act amendment in Schedule 6 of Bill 97. These changes allow for the conversion of some employment lands to residential uses. The resulting impacts of reduced protections for Employment Lands could result in increased pressure to utilize agricultural lands such as Prime Agricultural Lands and Specialty Crop Areas for employment uses in the future.
Download PDF file‘OFA submission to Standing Committee re Bill 97 – May 11 2023 (final)’