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Community Focus Bulletin: Creating Community Conversations

Prepared by Merriam & Associates Our Planning Philosophy:

The Seventh Generation Principle takes its name from the Great Law of the Haudenosaunee, the founding

document of the Iroquois Confederacy, the oldest living participatory democracy on Earth. It is based on

an ancient Iroquois philosophy that:

“In our every deliberation, we must consider the impact of our decisions on the next

seven generations.”

No. 1 – 2019

Keeping the Dialogue Going on: “Restoring Ontario’s Competitiveness Act, 2018: Bill 66”

(for the complete document go to https://www.ola.org/en/legislative-business/bills/parliament-

42/session-1/bill-66)

In December 2018 the provincial government introduced legislation: Bill 66, the Restoring

Ontario’s Competitiveness Act. Its 12 schedules amend many different existing pieces of

legislation relating to everything from farm regulation to day care regulation.

Purpose of the Act

The proposed Restoring Ontario’s Competitiveness Act, 2018 is the second package in the Ontario Open for Business Plan that helps the government reduce its red tape.

The Making Ontario Open for Business Act, 2018 was the first step by the government to eliminate unnecessary costs and burdens to businesses in Ontario.

The government is committed to bringing forward a series of red tape reduction packages over the coming years to eliminate or reduce costly requirements on Ontario businesses, while improving Ontario’s competitiveness.

An analysis of the bill shows that there could be a significant impact on a number of

environmental protection and farmland protection processes and would have major impact on

the Greenbelt, a 7,200-square-kilometre parcel of land that during the election the Tories

promised to protect.

Bill 66 would allow municipalities to create “open for business” zoning bylaws. If the Bill is

passed this change would allow municipalities to bypass numerous existing pieces of legislation.

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The intent is to attract major employers to the province and allow them to expedite municipal-

planning approvals for such developments as factories and office parks. It should be noted that

the changes are not intended to speed the development of housing.

The planning process would be changed so that the Minister of Municipal Affairs would be

required to approve bylaws passed by town and city councils.

The Bill would allow municipalities to bypass significant chunks of legislation:

major water-protection acts (the Clean Water Act, 2006, Great Lakes Protection Act,

2006 and Lake Simcoe Protection Plan Act, 2008) and

the recent solid-waste-management law (Resource Recovery and Circular Economy Act,

2016) would no longer apply to projects being approved under these new powers.

Planning Act legislation.

From an environmental perspective the changes that are of most concern involve the

province’s planning laws:

the Metrolinx Act, 2006

the Places to Grow Act, 2005

the Greenbelt Act, 2005

The Oak Ridges Moraine Conservation Act, 2001

For more detail see also our Community Focus Bulletin Restoring Ontario’s Competitiveness Act, 2018: Bill 66 – How will it impact community sustainability?

dated December, 2018 on our website.

The following questions were posed in the earlier Community Focus Bulletin:

1. Should bylaws be passed by municipalities with no public consultation? (Open for Business bylaws do not require municipalities to inform or engage the public,) 2. Should municipal bylaws be allowed to override provincial acts that have been in place for many years to protect people and the environment?

3. Given that 65% of the best farmland in Canada can be seen from the top of the CN Tower in Toronto (paved and built on) how can we continue to protect what is left if Bill 66 is allowed to be passed?

4. Even if the Open For Business bylaws proceed, is the 50 person employment bar set too low? What guarantee will the municipality have that the business will remain open for a significant length of time?

5. Does the public understand that the Bill will override such protection for clean drinking water, source water protection and Great Lakes and Lake Simcoe protection?

6. Is Bill 66 supporting the present government’s commitment to protect the Green Belt?

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7. The Planning Act will be changed to allow the proposed bylaws to override Official Plans, zoning requirements and site plan approvals as well as provincial policy statements regarding the Acts listed in the schedules found in the appendix of this Community Focus Bulletin. It does not allow appeals to the Local Planning Appeal Tribunal (replacement for the Ontario Municipal Board or OMB). How does this effect the application of both municipal and provincial policies? Does this allow for good planning for sustainable communities?

How the agricultural community is responding to Bill 66:

1. Response from the Peterborough Agricultural Roundtable:

The provincial government recently tabled Bill 66, the Restoring Ontario’s Competitiveness Act,

2018.

It is composed of a series of 12 unrelated proposals, all lumped together in one piece of

legislation. Generally, the legislation is intended to help businesses grow by reducing regulatory

restrictions (“red tape”) in specific sectors.

Schedule 10 of Bill 66 is one of the 12 different proposed changes. It would amend the Planning

Act to allow municipalities to pass “open-for-business” by-laws that could allow the use of lands

without having to strictly adhere to existing local and provincial planning requirements; make

public consultation at the discretion of the municipality; and, limit the public’s ability to appeal

decisions to the Local Planning Appeal Tribunal – the provincial body in charge of settling land

use planning disputes.

For those of us concerned with the future of agriculture in our province, and for the general

public as well, there are some serious flaws with the Bill. If approved, an open-for-business by-

law would enable municipalities to approve development of prime agricultural land, bypassing

all the land use and environmental safeguards that are in place in provincial legislation. They

would not be required to consult the public and there would be no right of appeal, as long as

jobs would be created on the land. This new law would benefit only land developers and those

who speculate in farmland.

Why is this a problem?

1. The availability of land for employment is not really an issue, and so allowing

indiscriminate development of prime agricultural land is unnecessary. There is already

more than enough land set aside for development in the Greater Golden Horseshoe

(which includes Peterborough). Currently designated employment lands not only meet

but also exceed municipal needs for the next long-term planning horizon in the GGH as a

whole. The City of Peterborough has approximately 95.5 acres of vacant designated

employment land and an additional 46 acres of employment land that are in various

stages of development. Looking forward, the new City Official Plan could also designate

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additional suitable employment lands. Throughout the County of Peterborough, each

Township also has vacant, readily-developable land designated to accommodate new

employment opportunities.

2. If speculators believe there is the possibility of developing land designated for

agriculture, it will only serve to drive the price of farmland up further. Farmland prices

have skyrocketed over the past decade, and farmland is no longer affordable for most

farmers and new farmers. This is a serious problem for the future production of

affordable, safe food for Ontario.

3. The idea that farmland should be developed to create industrial jobs completely misses

the fact that policy to support farming would also create jobs – many jobs. Farmland is

not just land waiting to be developed. It is the basic building block of the economic

driver that is food and agriculture.

Jobs are needed – but they need not be created at the expense of farmland protection and the

security of food for Ontarians in the future. Continuing protection of farmland should not be

dismissed as “red tape”.

2. Sustain Ontario’s approach

Bill 66, Restoring Ontario’s Competitiveness Act, is open for consultation until January 20, 2019. We urge you to submit your comments before then online here. You can find more details on Bill 66 on the Legislative Assembly of Ontario website. Shared by Farms at Work: Agricultural groups across the province are very concerned with Bill 66, Schedule 10. Why? Because it would allow municipalities to pass “open for business” bylaws that could lead to development of prime farmland in order to “reduce red tape” and create jobs – without any public consultation, without regard to any planning laws or water protection and with no right of appeal. Developers and speculators will benefit – but will the public? Farm organizations believe that jobs are created by building on properly zoned lands, and by supporting agriculture on prime farmland, which creates jobs along the entire food chain. If you believe that farmland protection is not “red tape”, consider signing the petition created by Environmental Defense, and/or make a comment on the Environmental Bill of Rights Registry by Sunday, January 20 here: https://ero.ontario.ca/notice/013-4125

3. Ontario Farmland Trust comments:

Ontario Farmland Trust (OFT) is a not-for-profit organization whose mission is to protect and

preserve Ontario farmlands and associated agricultural, natural, and cultural features of the

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countryside. OFT achieves this through direct land securement, stewardship, policy research

and education to benefit all Ontarians.

Ontario’s agri-food sector is a major economic engine for the province. In terms of job creation

and economic growth, a 2018 report confirmed that the agri-food sector contributes over $39

billion to Ontario’s GDP and employs more than 820,000 Ontarians in the supply chain [1]. This

contribution is overwhelmingly significant in rural areas, where roughly 12% of the GDP and

10% of rural jobs are attributed to the farm sector [2]. Ontario is also positioned favourably to

attract agricultural and manufacturing investment because it is a global leader in the agri-food

industry and houses one of the largest agri-food hubs in North America. This, in turn, generates

growth in employment and GDP.

OFT believes that, as currently written, the Open-for-Business Zoning By-law proposed within

Schedule 10 of Bill 66 places the agri-food sector and its substantial economic benefits at an

unacceptable level of risk. If adopted it will jeopardize the economic contributions of the

agrifood sector and expose rural areas to greater economic vulnerability. As such, OFT

recommends that Schedule 10 be removed from Bill 66. It is critical that all Acts that protect the

permanency, health, productivity, and profitability of Ontario’s farmland and the agri-food

sector are retained in full and without exception.

The following sections provide greater detail regarding Schedule 10’s threats to the farm sector

and suggests alternative actions to improve the province’s business environment while

attracting agri-food investment. Threats to the Farm Sector Schedule 10 of Bill 66 and the

Open-for-Business Zoning By-law (OFB-ZBL) could open up for development farmland that is

either currently protected (e.g. through the Greenbelt Plan) or is outside of projected municipal

growth areas.

This negatively impacts the agricultural sector in a number of ways. Schedule 10 of Bill 66:

• Threatens to pave over and permanently destroy productive farmland. Only 5% of the

Canadian land base is prime agricultural land, the majority of which is in southern Ontario and

contributes to the success of the Province’s agri-food sector. Ontario is already losing 175 acres

of farmland every day, a rate that could increase under the proposed OFB-ZBL. The loss of this

land to non-agricultural uses is irreversible and negatively impacts Ontario’s economy, food

security, and agri-food investment potential.

Risks farmland fragmentation and the dismantling of the agricultural system. A successful

agri-food sector relies on a healthy farm sector, which requires access to a contiguous

agricultural land base with a system of supportive infrastructure, agricultural services,

distributors, and processors. This requirement is recognized by, and is being addressed

through, ongoing municipal-level processes to implement the Agricultural System for the

Greater Golden Horseshoe. Development approvals outside of strategic growth areas that are

delineated in Official Plans and in conformity with the Provincial Policy Statement, Growth

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Plan, Greenbelt Plan, etc. will fragment and destroy the systems required by the farm sector.

As farmland and the agricultural system is fragmented by conflicting land uses, the viability of

agricultural enterprises and the agrifood sector is reduced or eliminated.

Will dramatically inflate farmland prices as speculation and land banking increases and

further reduce affordability for farmers. Sustaining large swaths of contiguous, affordable

farmland is crucial because land ownership provides the long-term, land use certainty that is

required for farmers to make investments in their property and business. This contributes to a

stronger agri-food sector and more attractive investment environment.

Introduces conflicting land uses adjacent to land used for agricultural purposes. This

disadvantages both producers and those on adjacent properties because of the nature of

agricultural activity, which generates noise, odours, and dust, and involves the use of slow-

moving farm machinery and hazardous materials. Ultimately, introducing incompatible land

uses makes it more difficult for farmers to continue running financial sustainable farm

businesses, can interrupt normal farm practices, and can create conflict with neighbors.

Re-introduces uncertainty around the permanent protection of land for agriculture and

agribusiness. Uncertainty about the ongoing protection of land for agriculture discourages

investment in agriculture and leads to a deterioration in the resource and the agricultural

community associated with it. Given that the best agricultural land is largely located in areas

experiencing growth pressures, this uncertainty and the resultant reluctance to invest in

agribusiness, will weaken the agri-food sector. Furthermore, the lack of public consultation

will result in farmers being unable to provide feedback, challenge decisions, and advocate for

the ongoing viability of their business.

Increases the agricultural sector’s vulnerability to the adverse effects of climate change.

Studies in Ontario indicate that the effects of climate change will be dramatically different

across the province and that heat and water stress will likely have negative impacts on

agricultural productivity [3,4]. The agricultural and natural lands threatened by the proposed

OFB-ZBL help to offset these negative impacts by providing services including carbon storage

and flood management. Re-introduced land use uncertainty would also reduce farmers’

incentive to invest in on-farm adaptive and mitigative technologies and practices.

Actions to Improve Ontario’s Business Environment As currently proposed, the OFB-ZBL is

unnecessary and does not appropriately solve the issues it seeks to address.

Numerous studies report that there is already enough employment land designated for growth

out to 2031 and beyond, meaning the provisions within the OFB-ZBL meant to open up land

previously unavailable for development are unnecessary. For example, a 2017 Neptis Report

notes that 85% or 87,440 ha of Designated Greenfield Area in the Greater Golden Horseshoe is

unbuilt [5], and a 2017 study from Simcoe County indicated that across its 16 municipalities,

there were 1,514 ha of excess employment lands to accommodate anticipated growth out to

2031 [6]. These planning horizons can be extended well beyond 2031 when growth is managed

through intensification [7].

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Existing planning resources, including Official Plans, already allow municipalities to respond to

employment opportunities on currently designated lands and direct growth in a strategic and

appropriate manner. Municipal polices are developed based on substantive amounts of work

supported by public consultation and should not be pre-empted by the OFBZBL.

The proposed OFB-ZBL disregards the importance and necessity of coordinated, comprehensive

planning to maintain and protect the integrity of regional systems, including the agricultural

system. Current provincial policies address strategic planning processes at a regional level and

should not be bypassed or undermined under any condition.

While the OFT is opposed to the currently proposed Open-for-Business Zoning By-law we

acknowledge that there are other actions that can be taken to improve the business

environment in the province and attract investment in the agri-food sector, which include:

• Coordinating the actions of provincial ministries so they work as a team to facilitate

appropriate development

• Adopting an online ‘single portal’ approach to planning applications, approvals, and

communications between government agencies and applicants

• Providing greater recognition and promotion of the agri-food sector as an economic engine in

the province

• Promoting job creation and investment opportunities that recognize and support agricultural

business potential in rural areas. Farmland is rural employment land and employment in one

sector should not place jobs at risk in another, which is the current reality of Schedule 10 given

the risks it will create for agricultural viability.

• Creating land-use certainty by using existing planning or policy tools to permanently protect

critical sector resources including farmland and the agricultural system.

References:

[1] Ontario Federation of Agriculture. 2018. Agriculture Matters – A Guide for Municipal Councillors and Staff.

https://ofa.on.ca/resources/guide-for-municipal-councillors-and-staff/

[2] Ontario Federation of Agriculture. 2013. Economic Contribution of the Ontario Farm Sector 2013.

https://ofa.on.ca/resources/economic-contribution-ontario-farm-sector-2013/

[3] Ontario Centre for Climate Impacts and Adaptation Resources. N.d. Agriculture: in a changing climate.

http://www.climateontario.ca/doc/factsheets/Agriculture-final.pdf

[4] Tant & Reynolds. 2003. Impacts of Recent Climate Trends on Agriculture in Southwestern Ontario, Canadian Water

Resources, 28 (1).

[5] The Neptis Foundation. 2017. An update on the total land supply: even more land available for homes and jobs in the

Greater Golden Horseshoe. http://www.neptis.org/sites/default/files/land_supply_briefs_2016/an_update_on_the_total_la

nd_supply_even_more_land_available_for_homes_and_jobs_in_the_ggh.pdf

[6] County of Simcoe. 2017. Phase 2 - Employment Land Budget 2017. https://www.simcoe.ca/dpt/pln/growth

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[7] The Neptis Foundation. 2013. Implementing the Growth Plan for the Greater Golden Horseshoe: Has the strategic regional

vision been compromised? http://www.neptis.org/sites/default/files/growth_plan_2013/theneptisgrowthplanreport_final. pdf

4. National Farmers Union-Ontario response:

While the National Farmers Union-Ontario appreciates the government’s desire to cut excessive regulations, farmland and source water protection are not red tape, and we strongly oppose several aspects of Bill 66, Restoring Ontario’s Competitiveness Act, 2018. This Act proposes to keep Ontario “open-for-business,” yet many pieces of it would limit the ability of farmers to remain “open-for-business.” Instead, these regulations provide a long-term vision for a healthy prosperous Ontario and provide much needed long-term protections of farmland. The NFU-O is an accredited farm organization whose members work together to advocate for policies that maintain family farms as the primary food-producers in Canada. The NFU-O believes agriculture should be economically, socially, and environmentally sustainable and lead to enriched soils, biodiverse ecosystems, financially-viable farms, healthy and safe food, and thriving rural communities. The NFU-O collaborates locally, nationally, and internationally to research, educate, and share effective solutions that lead to a better world for farm families and their communities.

We outline our concerns below and trust that they will be considered with respect to all three

relevant ERO postings (i.e., 013-4293, 013-4125, 013-4239).

Open for farm businesses Agriculture is a significant contributor to Ontario’s economy. According to the most recent census statistics, agriculture and agri-food employment is 11 per cent of the total employment rate and contributes approximately $39 billion to the province’s annual GDP. Yet, farmland acreage decreased by 11% from 1996 to 2016, and according to the Neptis Foundation, “Only 5% of the Canadian land mass is made up of prime [farm]land.”

Farmland constitutes about half the land area of the Greater Golden Horseshoe and represents one of the most important economic sectors of the region. In 2011 alone, agricultural production in the GGH brought $6.3 billion into the economy. It is also a significant employer, with 35,000 employees in 2011, representing 39 per cent of Ontario’s employment in this sector. The Greenbelt farms are particularly productive, for a variety of reasons, and produce an average of 55 per cent of Ontario’s fruit and 13 per cent of its vegetables.

The more farmland lost to speculation and developers the less is available to existing and potentially new farmers. One of the major impediments to new farmers wanting to enter the business is the cost of land.

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By allowing municipalities to pass bylaws that would exempt developers from compliance with higher order planning documents and legislation, Bill 66 would reduce farmers’ access to an already limited resource and, at worst, displace farm businesses and limit the possibility of economic growth, not only of the agriculture sector, but of the province as a whole. Prime farmland is not a renewable resource.

Because no advance public notice is required prior to the passing of an open-for-business bylaw and because there is no right of appeal to the Local Planning Appeal Tribunal, many farmers may not know what is being proposed for bordering farmland and how it could impact them. Depending on the type of development, farmers may face complaints due to noise of farm machinery or smells from livestock, or they may have to deal with runoff or issues with source water or drainage due to the changes on a neighbouring property.

In the report on 2017 farmland prices, Farm Credit Canada confirmed that Ontario farmland values as compared to production capacity have now diverged, meaning non-farming speculation is continuing to drive land value. The NFU-O is very concerned that Schedule 10 of Bill 66 would exacerbate the speculative valuation of farmland even higher.

Farmland is vital to farmers and communities. It is vital to food production. It is vital to every single Ontario resident. It sustains us all by providing healthy food and clean water and should be afforded the respect it is owed.

Municipalities We have heard from municipalities expressing concern over the impacts of an open-for-business bylaw on their region. They feel that their desire to protect drinking water, farmlands and natural areas, and ensure public input and transparency in decision-making is under pressure with these proposed changes. The mayors of Hamilton and Burlington have said they oppose the legislation and would not support its use; however, both mayors could be outvoted by their councils under pressure from developers.

Land and water do not follow municipal boundaries, and open-for-business bylaws have the possibility of pitting municipalities against each other in a race to the bottom. By eliminating a municipality’s requirement to consult with neighboring municipalities, one’s decisions could impact the other’s water quality and ability to care for its residents. Many municipalities are already experiencing increased pressure by developers who have “leapfrogged” over protected areas, such as the Greenbelt.

As well, we have heard from certain municipalities that many have a surplus of employment lands and would like to see major development occurring on employment lands already set aside beyond the boundaries of wellhead protection areas or intake protection zones under their official plans, which were developed through community consultation.

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Additionally, because many rural municipalities are already cash-strapped, the NFU-O worries that they may be willing to compromise on good planning to bring in additional revenue, nor will they have resources to fight developers who are requesting exemptions.

As Ontario Nature puts it, “[Bylaws] passed behind closed doors would trump laws, policies and municipal official plans developed through extensive and open public consultation. Communities would have no recourse to influence or challenge them.”

Experts and Public Consultations As an organization who has participated in numerous stakeholder consultation sessions regarding the Growth Plan, Greenbelt Plan, Agriculture Systems and more, advocating for land use planning that promotes an economically and environmentally sustainable agriculture and agri-food sector, the NFU-O is also concerned that municipal councillors, who may not have any land-use planning experience or knowledge of the agriculture sector, would be allowed to develop bylaws that override Acts and Regulations that were written in consultation with and by experts, in particular the Clean Water Act, which was developed after the deaths in the Walkerton tragedy.

Farmers rely upon safe water for their livestock and crops, and all of Ontario’s citizens require safe drinking water. It makes economic sense to protect drinking water since it is much more expensive to clean up contaminated drinking water sources or to build new infrastructure. The recent water crisis in Flint, Michigan and our own Walkterton tragedy serve as reminders that source water protection needs to remain a high priority for all levels of government.

As a government that prides itself on being “for the people,” you recognize the value of public input that has gone into creating these Acts. These consultations were created for all the people of Ontario.

The Ontario Farmland Trust has laid out actions that can “improve the business environment in the province and attract investment in the agri-food sector, which include:

Coordinating the actions of provincial ministries so they work as a team to facilitate appropriate development

Adopting an online ‘single portal’ approach to planning applications, approvals, and communications between government agencies and applicants

Providing greater recognition and promotion of the agri-food sector as an economic engine in the province

Promoting job creation and investment opportunities that recognize and support agricultural business potential in rural areas. Farmland is rural employment land and employment in one sector should not place jobs at risk in another, which is the current reality of Schedule 10 given the risks it will create for agricultural viability.

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Creating land-use certainty by using existing planning or policy tools to permanently protect critical sector resources including farmland and the agricultural system.”

The NFU-O supports these recommendations and would be happy to work with the province to

develop them further.

We propose that if this province wants to remain open for business for farmers, it will not allow municipalities to undo years of work and public consultations that created the Regulations and Acts that protect the very core of our businesses: farmland and water. We strongly recommend that Schedule 10 be immediately abandoned or withdrawn from Bill 66 by the Ontario

government.

4. Ontario Federation of Agriculture

The Ontario Federation of Agriculture (OFA) is Canada’s largest voluntary general farm

organization, representing more than 38,000 farm family businesses across Ontario. These farm

businesses form the backbone of a robust food system and rural communities with the

potential to drive the Ontario economy forward. Schedule 10 of Bill 66 is a direct attack on the

family farm businesses, farm input supply businesses and food processing businesses located

throughout Ontario. On-farm production of food underpins a broad spectrum of rural and

urban businesses. Farm input supply businesses provide the goods and services farm businesses

depend upon; seed, feed and fertilizer, farm equipment dealerships, building supply retailers,

not to mention veterinarians, banking, insurance, etc. There are numerous food processing

businesses located throughout Ontario, but concentrated in the Greater Toronto/Hamilton

area, dependent on the fruits, vegetables, grains, oil seeds, livestock, poultry and fish grown

and raised by Ontario farm businesses.

In 2017, Ontario’s family farm and food processing businesses contributed $39.5 billion in GDP

and supported 822,483 jobs. Agriculture and agri-food processors are the number 1 economic

contributor to Ontario’s overall economy. Jeopardizing these stabile, recession resistant

businesses and jobs runs counter of an “open-for-business” mindset.

Before addressing the proposed amendments to the Planning Act in Schedule 10 of Bill 66, we

emphasize that Ontario only has one landscape. That means that the full range of landforms

and land uses found across Ontario; agricultural, industrial, rural, residential, natural heritage,

commercial, cultural heritage, mineral extraction, etc. must share that landscape. Ontario’s

agricultural areas not only provide us with food, fibre and fuel, but also a broad range of

environmental and ecological goods and services that benefit all Ontarians. To fulfil their role

and function for all Ontarians, Ontario’s prime agricultural lands must be separated from

noncompatible land uses. To do otherwise, as Schedule 10 of Bill 66 proposes, will be “death by

a thousand cuts” for the family farm businesses, farm input supply businesses and food

processing businesses located throughout Ontario.

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Agriculture is Southern Ontario’s principle resource-based land use. Protecting Ontario’s prime

agricultural areas for their long-term agricultural use is a key provincial policy objective, noted

not only in the Planning Act [section 2.(b)], but also in the Provincial Policy Statement, the

Greenbelt Plan, the Growth Plan for the Greater Golden Horseshoe, the Oak Ridges Moraine

Conservation Plan and the Niagara Escarpment Plan. Retaining our finite and shrinking

agricultural lands for the production of food, fibre and fuel is critical, and supportive of

Ontario’s family farm businesses, farm input supply businesses and food processing businesses.

We also face the additional expectation, at least from the Ontario Government, that Southern

Ontario in general and the Greater Golden Horseshoe will accommodate substantial future

population growth, along with the jobs and infrastructure necessary to support this projected

growth. OFA recommends that the proposed Local Planning Appeal Tribunal’s decisions be

viewed through the lens of protecting Ontario’s finite and shrinking agricultural lands from

nonagricultural uses.

Agriculture is a business. This proposal suggests that agricultural land should no longer be used

for agriculture to make way for commercial and industrial businesses. By putting Schedule 10

forward, the Ontario government is suggesting that agricultural businesses should be shut

down and paved over to make way for industrial development.

The agri-food sector is the economic powerhouse of Ontario; employing 822,000 Ontarians and

generating nearly $40 billion in GDP. In addition, agri-food was identified as a key sector in

Canada with untapped potential for growth and expansion. If we lose agricultural land to

development, it is gone forever. This means a loss of rural businesses in our communities; a lost

opportunity to produce more products through innovation and technological advancements; a

loss of employment from on-farm food processing and agritourism; and a loss for rural

communities that the Ontario Government promised to support.

While Bill 66 claims to “give businesses more flexibility to create jobs right here at home”,

Schedule 10 forgets and abandons the businesses that are already here – in our agri-food

sector. Agri-food is the number one employer in Ontario and drives our economy forward.

OFA appreciates the Ontario government’s initiative to cut red tape and be “Open for

Business”. However, there is another way that does not compromise our agricultural

businesses, our clean water, and strategic land use protection. Agri-food is the recession-

resilient answer to economic growth in this province.

OFA urges the provincial government to enhance agri-food growth in Ontario by showing

farmers and food businesses that we are “Open for Business”:

Use the Provincial Policy Statement definitions and language in all Four Provincial Plans.

A lack of consistency across the Plans leads to confusion for businesses and subjective

interpretation by the many stakeholders involved.

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Support the Agricultural System to consistently protect farmland across the Greater

Golden Horseshoe and support the prosperity of the agri-food sector. OFA supports the

provincial mapping of the Agricultural Land Base, including identification of Candidate

Areas for inclusion in the Agricultural Land Base. OFA also supports the implementation

of the agri-food network. For agriculture to prosper, smart land use planning that

protects farmland needs to align with economic development to support agriculture-

related businesses along the supply chain.

Adhere to the designated greenfield density targets of “not less than 80 residents and

jobs combined per hectare” and implement this requirement as soon as possible. In

addition, OFA would welcome the adoption of fixed, permanent urban boundaries to

contain urban sprawl.

Oversight of the Niagara Escarpment Plan should be moved from the Ministry of Natural

Resources and Forestry (MNRF) to the Ministry of Municipal Affairs and Housing

(MMAH). Businesses should not need to contact multiple ministries and multiple

governing bodies for similar provincial plans.

Target smaller communities for infrastructure and economic investments to distribute

economic development, reduce congestion and growth pressures in the GTA. The

growth pressures will continue to make life unaffordable and challenging for the

average resident, not to mention the pressure of developing agricultural land; Ontario’s

most important resource.

The current pattern of growth in the Greater Toronto/Hamilton Area is unsustainable. The

Province’s priorities to increase housing supply and affordability, create jobs, reduce red tape,

attract new investments, and build strategic partnerships align exceptionally well with our

Producing Prosperity plan, and OFA has solutions that will mutually achieve our objectives

The primary principle behind land use planning is to group compatible uses together, while at

the same time separate non-compatible land uses. The widespread practice of dedicating large,

contiguous tracts of agricultural land solely for agricultural uses is to facilitate their viability,

and to ensure that non-compatible uses, which are detrimental to agricultural viability, are

located elsewhere. Agriculture in the 21st century needs large, contiguous tracts of agricultural

land reserved for agricultural uses. It minimizes complaints from non-farm neighbours over

agricultural odours, noises, dusts, etc. While none of these “nuisances” pose a threat to public

health or safety, they nevertheless to do present a temporary inconvenience; manure odours,

dusts from planting, tilling or harvesting, noises from livestock or farm equipment operating at

odd hours to avoid impending adverse weather.

Locating industrial facilities outside of urban settlement areas benefits no sector of the

economy. Municipalities will be faced with the need to service scattered sites located at some

distance from fully serviced settlement areas. Neighbouring farm businesses must contend with

incompatible uses adjacent to them (industrial odours, noises, dusts, etc.). Facilitating scatted

industrial sites also facilitates the fragmentation of a finite and shrinking resource, Ontario’s

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prime agricultural land, which provides Ontario’s agri-food processors, retailers and restaurants

with safe, affordable, locally produced (greenhouse gas benefits) and close to market food. A

mere 5% of Ontario’s land base is currently capable of supporting agricultural production.

Between 2011 and 2016, Ontario lost 319,700 acres of agricultural land, or the equivalent of

175 acres/day over that 5-year period. Going back to the 1996 census, Ontario has lost 1.5

million acres of agricultural land.

Agricultural land not only provides us with safe, affordable food, but also provides a range of

ecological and environmental services that benefit all Ontarians. In alphabetical order, these

services include aesthetic and recreational space, air quality (carbon sequestration, climate

regulation, oxygen production), biodiversity, nutrient cycling, pollination services, soil erosion

control and water cycling (flood mitigation, groundwater recharge, purification, retention).

Facilities located outside the urban envelope will face a lack of services, or higher costs to

service their site, plus longer distances for inputs and outputs; distances to shipping points, etc.

Furthermore, employees will live at some distance from these remote and scattered facilities,

leading to longer commute times and reliance on private vehicles as these new sites will not be

served by public transit.

The Ontario Federation of Agriculture believes that the provisions set out in Schedule 10 of the

Restoring Ontario’s Competitiveness Act, 2018 are utterly unnecessary, detrimental to the

integrity of our well-established system of land use planning and an attack on Ontario’s farm

and agri-food businesses. Therefore, we strongly recommend that Schedule 10 be removed

from the Restoring Ontario’s Competitiveness Act, 2018.

For more information about our Community Focus Bulletins or to view past editions go to

http://www.merriam-associates.com/contact-us

Or email Dawn Berry Merriam at dawnbm@merriam-associates.com

or John Merriam at john@merriam-associates.com

or call 705-743-8050.

January, 2019