OFVGA Response: Land Use Planning

RE: Proposed Growth Plan for the Greater Golden Horseshoe (2016), EBR Registry #012-7194; Proposed Greenbelt Plan (2016), EBR Registry #012-7195; Proposed Oak Ridges Moraine Conservation Plan (2016), EBR Registry #012-7197; Proposed Niagara Escarpment Plan (2016), EBR Registry #012-7228; and Proposed Amendment to the Greenbelt Area Boundary Regulation, EBR Registry #012-7198.

The Ontario Fruit and Vegetable Growers’ Association (OFVGA) would like to thank you for the opportunity to provide feedback on the proposed changes to the Growth Plan for the Greater Golden Horseshoe, Greenbelt Plan, Oak Ridges Moraine Conservation Plan and Niagara Escarpment Plan as part of the Co-ordinated Land Use Planning Review.

Unify the approaches to agricultural planning, terms and definitions

OFVGA would like to see a unification of the language between the Plans and the Provincial Policy Statement making it more consistent. There are several inconsistencies that should be addressed. Examples include:

  • The definitions of ‘Prime Agricultural Area’ and ‘Prime Agricultural Land’ in ORMCP Part I, Section 3, should to be changed to make for consistent definitions in the other Plans and the Provincial Policy Statement. It is important that Prime Agricultural Areas be defined in all the Plans as explicitly including “Prime Agricultural Lands and associated Canada Land Inventory Class 4 through 7 lands, and additional areas where there is a local concentration of farms which exhibit characteristics of ongoing agriculture.” All active farmlands in Ontario should be protected because they contribute to the agricultural economy regardless of CLI Classification or a ‘prime’ designation.
  • There is no acknowledgement of the ‘Agricultural System’ or ‘Agricultural Support Network’ in the NEP as there is in the other three Plans; this should be added.
  • Changes to Section 2.1 of the 2014 Provincial Policy Statement dropped the word existing. NEP only permits “existing” agricultural uses, existing agriculture-related uses and existing on-farm diversified used. OFVGA sees the current wording to be problematic because agriculture and farm businesses are constantly changing, especially with the adoption of new farming practices thanks to technological advancements or growing new crops. The word “existing” should be removed to allow farms to remain sustainable.
  • In general, OFVGA strongly cautions against policies that create barriers for farmers’ ability to farm their land. Policies that prohibit agricultural uses should not make their way into the NEP or similar plans.

Ministerial oversight should be taken into consideration

OFVGA recommends that ministerial oversight for the NEP be transferred from the Ministry of Natural Resources and Forestry to the Ministry of Municipal Affairs. Currently, the ministerial oversight for the other plans namely, the Greenbelt Plan, the Growth Plan for the Greater Golden Horseshoe and the Oak Ridges Moraine Conservation Plan, including the Provincial Policy statement fall under the Ministry of Municipal Affairs. The NEP would be best suited for land use planning purposes to also fall under the same ministry and not be treated as a standalone document.

Reexamine some of the requirements outlined in the Escarpment Rural Areas (pages 23-29) and the NEP’s “agricultural” policies section (pages 74-77)

The NEP currently states that property owners need to obtain a development permit, in addition to a building permit. OFVGA feels that this is an unnecessary and costly inefficient use of time and resources.
Surplus dwelling severance policies has a stipulation that the application for a surplus dwelling severance must occur within two years of the date from when the lands were acquired. OFVGA sees the two-year timeframe as restrictive, especially given that no other provincial plan contains such a provision.
Policy 2.8.5 imposes that only mobile. Portable accessory dwelling united for farm workers are allowed. This mandate forces farmers that employ staff to house them in mobile or portable dwelling units – a requirement that no other farm employer in the province has to comply with. OFVGA would argue that this stipulation is not only archaic but it discriminates against farm workers by confining them to housing types not imposed outside of NEP.

Policies on transportation (3.2.2; page 31) should consider agricultural equipment

The policies on transportation include no reference to the use of agricultural equipment. This should be noted as farmers rely on roads to move farm equipment back and forth from the fields. Some farm equipment is significantly bigger in terms of overall size and width compared to most other vehicles using the roads. OFVGA would like to make mention that the policies referencing “complete streets” make way for farm vehicle needs to be fully met.

Policy 3.2.5 (page) 33

This section discusses infrastructure corridors but fails to mention local distribution networks for things such as natural gas, electricity, municipal water, and in some cases sanitary sewer access, to support greenhouses and food processors. The sustainability and viability of agriculture within the Growth Plan relies on agriculture’s access to these necessities.

Consideration of storm water management Re: Oak Ridges Moraine Conservation Plan (page 70)

With regards to storm water management, this requirement should be site specific rather than tied to a specific footprint. The 500m2 limit may make sense in an urban setting but not in a rural setting. OFVGA ask that you take this under advisement.

OFVGA questions the discrepancy between the Growth Plan for the Greater Golden Horseshoe and Ministry of Finance population figures

The OFVGA would like to point out the gross disparity between the forecasts found in the Growth Plan for the Greater Golden Horseshoe and that by the Ministry of Finance. It is concerning as the Growth Plan’s projections exceed the Ministry of Finance’s figures.

OFVGA strongly encourages that the urban expansions and any re-designation of agricultural lands as outlined in the Growth Plan be postponed until the 2016 Census data is made available. This would ensure that the Growth Plan’s “Distribution of Population and Employment for the Greater Golden Horseshow can be adjusted to reflect the 2016 Census data.

Plan review and updates should be separate from expansion

OFVGA strongly objects to the intension to have approximately 45,000 hectares (113,000 acres) added to the Plan’s existing area of 193, 340 hectares (477,754 acres), an increase that represents more than 23 per cent. We firmly believe that a plan review and updates should be separate from expansion. In addition property owner support should be needed before the plans in one plan designation are changed to another.