OFVGA response to Co-ordinated Land Use Planning Review

Entering the Greenbelt
The Greenbelt Plan is one of four Ontario plans under review. Photo provided by Ken Nash, Creative Commons


The Government of Ontario is seeking input into how the four land-use plans in Ontario can be formulated to work cohesively and in concert with each other. Fundamental questions such as how the plans can better support the long-term protection of agricultural lands, water, and natural areas, while continuing to foster healthy, livable, and inclusive communities, are of distinct concern to the horticultural sector.

The OFVGA commends the Government of Ontario’s commitment to continuous improvement and the review of these plans.


The alignment of the four plans under review (The Growth Plan for the Greater Golden Horseshoe – 2006, office consolidated 2013; Greenbelt Plan – 2005; Oak Ridges Moraine Conservation Plan – 2002; and Niagara Escarpment (NEC) Plan – 2005, updated 2012) is a laudable exercise to reduce the amount of overlap and duplication that may be present in these plans. The OFVGA does not support placing more restrictive policies, such that exist in the NEC, on farmers within the Greenbelt area.

The components of these plans affect large numbers of people and have long-term implications for the future of the province of Ontario. The OFVGA takes the direction put forth in these plans very seriously, as it affects many of our members and customers. Economic prosperity and the issues of land-use planning, infrastructure, transportation, urban form housing, natural heritage, and resource protection are all of interest to the OFVGA. We also support the government’s efforts to protect Ontario’s prime agricultural areas for the purpose of enhancing our agricultural sector.  In this context, natural heritage currently also refers to constructed drains and swales, and we would like this removed from the Greenbelt regulation, since these are man-made.  Perhaps reference to significant woodlots, wetlands, natural streams, and lakes would be more appropriate instead of natural heritage.

The OFVGA supports agricultural value creation and diversification, and does not support policies that unknowingly or unintentionally restrict farmer enterprises.  Use of terminology such as development must be clearly defined and clearly interpreted.  Agricultural diversification must be encouraged.

The OFVGA would also like to emphasize that much of the land under discussion is privately held land, and as such, should not be considered similar to public land. Agricultural land is NOT for recreational use, and recreation facilities should not be placed in opposition to agriculturally focused land.

How can the plans better support the long-term protection of agricultural lands, water, and natural areas?

  • The definition of natural areas must be clarified.  It should include significant woodlots, wetlands, natural streams, and lakes, but not man-made structures.
  • Promote the viability and diversification of agri-businesses so that farmers can reinvest in their businesses.
  • Remove regulatory impediments to agri-business operations that impact the viability of farms.
  • Remove agricultural land and constructed drains and swales from the Greenbelt Natural Heritage System. To add clarification, remove constructed drains and farm swales from the Greenbelt Policies, both in the protected countryside and in the Greenbelt Natural Heritage System.
  • Building setbacks from woodlots and wetlands should be reduced to address the uniqueness of different farming areas in the province and flexibility for this should be provided in the Greenbelt Plan.
  • Do not restrict value added development on-farm.
  • Promote processing of farm-based products that are produced on-farm.
  • Enhance rural infrastructure (access to provide power to the grid, natural gas, transportation, and communication).
  • Provide infrastructure for the provision of local produce in urban areas at a reasonable cost.
  • Do not include the farm restrictive policies of the NEC on farms within the Greenbelt.

Evaluation of the Purpose and Potential Impacts of Expanding the Greenbelt

The OFVGA encourages the Government of Ontario to do a complete and extensive evaluation for the purpose of potential expansion of the Greenbelt prior to implementing such an endeavour.  As part of the Ontario government’s own regulatory policy, there is a requirement to fully evaluate the economic, social, and environmental impacts. We would remind the government that regulations need to be justified by a solid business case, serve clearly stated public policy goals, and be effective in achieving those goals. The OFVGA would encourage the government to clearly state their purpose and goals of expanding the Greenbelt prior to instigating new policy.

OFVGA would also support a clear assessment of the total costs and benefits of such an expansion, including those to business, farming and agriculture, the costs to public and government administration, and an evaluation of the economic impacts are critical to making judgements about the reasonableness and practicality of a regulation. The assessment of costs and benefits must be based on the risks posed in the absence of regulation (that is, be based on a clearly identified need) and take into account the overall impact on the competitiveness of those subject to regulation.

A fundamental concern that the OFVGA has across these four plans is that regulatory differences among jurisdictions could compromise competitiveness, increase the burden on business, and lead to barriers to international and internal trade.  It is our position that we need to eliminate unnecessary overlapping or conflicting regulations that could result from four distinct plans.  

Greenbelt Policy

Under the Greenbelt Plan there are several components that directly impact the prosperity of horticultural businesses.  The framework themes Prime Agricultural Land and Fragmentation, Agricultural Economy and Tourism, Water, Infrastructure, and Strong Rural Communities are supported by the OFVGA.  Of these, performance indicators only exist for Prime Agricultural Land and Fragmentation and Water.

Goals of the Review

How the plans can better achieve the following six goals:

1. Protecting agricultural land, water and natural areas: Our agricultural lands, lakes, rivers, wetlands, and woodlands are finite and valuable resources that feed and provide drinking water to communities in our region and beyond. They provide important economic and ecological benefits, and improve our quality of life.

It is recommended that wording be changed from natural areas to natural features.

The OFVGA agrees that fixed, long-term, urban boundaries, with a long time frame (20-25 years minimum), be implemented to prevent the spread of urban sprawl. This would also be in concert with implementing hard intensification targets within urban areas. Communities that do not meet the proposed standards should be incented to do this within a certain time frame, but also should face consequences if they fail to meet the targets.

It is recommended that the re-development of brownfield and existing infrastructure be done as opposed to further development of “greenfield” properties. Companies, communities, and others should be incented to work with already developed properties. Technical operations, such as solar and wind facilities, should be encouraged on brownfield locations since neither of these is impacted by the quality of the soil.

Farm protection policies that enable farmers to establish, develop, and grow farm businesses related to value added and agricultural diversification should be encouraged. Agriculturally related businesses, including agricultural support businesses, should be encouraged and incented to locate and re-establish within the Greenbelt. Provision of services such as high speed Internet, power infrastructure (natural gas, such as announced by Minister Duguid in Leamington in May 2015, electricity), and transportation should be key priorities.   The OFVGA supports the ability of farmers to access Greenbelt funding to enable infrastructure development.

Reasonable set backs from significant wetlands, natural streams, and lakes are encouraged. Graduated setbacks from these are also recommended. Removal of setbacks from human-made watercourses for the purposes of irrigation should happen. Having these as part of the policy would remove variable municipal interpretation of the policy. Due to the size of some of our specialty crop farms, a 30 metre setback is too large a distance for some properties, so it is recommended that there be flexibility in this requirement to allow for new farm building on existing farms to be built adjacent, but no closer, to existing farm buildings.  Further, the costs associated with the conduct of an environmental impact study for a developer can be passed on, however it is an unreasonable expectation that farmers be required to pay this cost for the development of a simple farm building.

Research and development into farm practices, best management practices, and appropriate goods and services to support environmentally sustainable farming are recommended, including cover crops, bee habitat, crop, and opportunity diversification.

The OFVGA supports development of recreational spaces within the Greenbelt but not at the cost of agricultural land nor at the expense of the farmer. Agricultural lands are privately held lands and should not be considered public land for recreational use. The OFVGA recommends better utility of publically held lands, including Conservation Authority, municipal parkland, provincial lands, and federally owned lands.  Further, it is recommended that businesses associated with recreation set up on publically owned or recreational lands, and not on privately held agricultural land.  The OFVGA considers the creation of off road multi-use trails adjacent to working farms to be a significant concern due to liability issues, particularly when farmers are mowing or using crop protection tools.

Sustainability of farming must be a component of the coordinated land use plans. Economic, environmental, and societally-related aspects must be considered.  This includes consideration provided for those regulations within these land use plans that affect the viability of a farming operation. While these policies do focus on the land, there is a need within the policies to focus on the people who manage the land as well. Economic stability of these areas is essential to have a fully developed rural community.

Before the Greenbelt undergoes an expansion or contraction, we feel it is necessary to have justification for the need for such policy, consistent with Ontario’s regulatory policy.(

We believe that a clear assessment of the total costs and benefits, including those to business, the public, and government administration, are critical to making judgements about the reasonableness and practicality of any proposed land use policy changes. The assessment of costs and benefits must be based on the risks posed in the absence of policy (that is, be based on a clearly identified need) and take into account the overall impact on the competitiveness of those impacted by the policy. Consultations must happen before expansion of the Greenbelt beyond current municipalities is made a reality.

Finally, with respect to how these plans provide for agricultural protection, it is recommended that regulations and policies, which support agriculture across all ministries, be encouraged. Provincial policies and regulations for agricultural lands should only be recommended after fully considering the impacts to all the different areas of the province, especially the specialty crop areas.  Policies that truly support and promote agriculture in Ontario will have a positive impact on the largest contributor to Ontario’s economy and those polices that negatively impact the economic viability of the farming operation should be discouraged.

2. Keeping people and goods moving, and building cost-effective infrastructure: Aligning land use planning and infrastructure, including transit, can realize cost savings, produce more vibrant communities, ensure the mobility of people and goods, and increase our region’s sustainability over the long term.

The OFVGA recommends the continued development of high-speed rail that is affordable to its users.   The OFVGA supports the further development of the GO Transit System and enhancing its affordability.  For example, trains from Kitchener-Waterloo through Guelph, should be accessible throughout the day, not just during peak commuter times.  Pricing on the GO should be reduced to encourage ridership.  Intercity rail transportation must be a goal of keeping people and goods moving.  The OFVGA also supports the restoration of efficient rail shipping options, facilitated truck access to lake ports, and further access to water transport.

By adhering to the firm boundaries and urban density targets, the requirement for more road transportation infrastructure may be minimized. Use of rail that is reliable and consistent will help alleviate the traffic snarl.  Further, it is recommended that infrastructure and transportation corridors be firmly established (power – hydro and natural gas; transportation – road and rail) to more efficiently use the land base. With fixed urban boundaries, long-term transit solutions can be found.

Redevelopment of brownfield sites already in urban areas will support more efficient transportation infrastructure. Redevelopment within existing boundaries is recommended, which will support a compact urban infrastructure.

Long-term infrastructure development is necessary for Ontario to thrive in the new economy.  Mandatory intensification and increased density within urban environments is supported.  Reduction in “bedroom” communities and consolidating working and living areas is recommended. This infrastructure does include the need for excellent communications to facilitate local employment.

Secondary road maintenance and easy access to production is an essential component of horticultural production. In some cases, it is necessary for equipment to remain on the roadside (e.g. to prevent undue soil compaction etc.).  It is also necessary to recognize that the size and scale of farm equipment has increased, so road construction must be such that it facilitates their movement.  To this end, roads, traffic circles and curbs must be created with this in mind.  Funding for rural infrastructure, including the paving of roads, replacement of undersized culverts, natural gas, and water is recommended.

Finally, agriculture must be recognized for its contribution to environmental goods and services.  Infrastructure must be in place, for example, to facilitate the expansion of carbon catching investments such as orchards. Further, aligned policies must be made so that horticultural operations are not impeded.

3. Fostering healthy, liveable and inclusive communities: Healthy, liveable, inclusive, and complete communities can improve our quality of life, attract people and jobs to the region, reduce healthcare costs, and be accessible to all Ontarians at all stages of life.

There is no question that there is a requirement for an enhanced role of rural communities in the economic fabric of the province. Rural communities should have appropriate densification targets, but should not be neglected because of urban communities becoming the priority. 

The provincial funding structure for rural communities is not conducive with the development of vibrant rural communities. Funding for education, including elementary and high schools, must be increased, as these are the mainstays of many rural communities. Further, infrastructure must be in place to support the population as it ages. Consideration must be made for those retiring off the farm and moving into rural communities.

It is suggested that bicycle paths be enhanced, however there are areas where these are not recommended (e.g. within the Holland Marsh). Biking trails should not be constructed through private property. Bicycle parking should be accommodated at places of employment as well as at mass transit locations.  As stated above, the OFVGA does consider the creation of off road multi-use trails adjacent to working farms to be a significant concern due to liability issues, particularly when farmers are mowing or using crop protection tools.

Rural heritage is important to the agricultural community. Uses that allow the farmer to derive income from heritage buildings will support their maintenance and upgrade. Policies must be in place to support the “freedom to operate” perspective, and farmers must be able to replace, if desired, outdated structures with more modern buildings. New farm buildings should also be exempt from cultural heritage status.

4. Building communities that attract workers and create jobs: Communities need to be planned in ways that attract skilled workers and their employers, and that ensure land is readily available for a range of employment uses. This is fundamental to maintaining our economic competitiveness.

OFVGA suggests that the combination of agriculture and aggregate extraction as similar entities be removed. While both are resource based, agriculture is a resource of renewable nature, and as such needs to be treated differently to the one-time use of aggregates. It is recognized that aggregates are required and needed, however, aggregate extraction should not be done at the cost to agriculture.

Development of infrastructure, including transportation, communication, community services, and energy will support rural community development. Pricing for energy, as an example, must be affordable. Internet must be made available across the province to all subscribers. This will facilitate a environment that will not only allow businesses to survive, but will foster job growth.

These policies must support agricultural sustainability, including economic viability. This will happen through infrastructure, agricultural supportive services, and regulatory policy that is supportive of agriculture. Continued educational development, both for those in agriculture and those close to agricultural operations, would support vibrant rural economies.

5. Addressing climate change and building resilient communities: Climate change is one of the most significant challenges facing the region. Taking action to address climate change, and build resilient landscapes and communities can improve our health and quality of life, as well as reduce the damage and related costs resulting from extreme weather events.

Agriculture, and horticulture in particular, must be recognized as a significant contributor to carbon sequestration and a positive carbon economy, in addition to producing food, fuel, and fibre, Orchards and vineyards are net carbon catchers.  Incentives to develop and support these operations must be created.

Increasing the densification of urban areas will reduce travel miles and therefore reduce greenhouse gas emissions. These communities will support mass transit, reducing carbon utilization. 

6. Improving implementation and better aligning the plans: Better implementation and alignment between the plans can improve the efficiency with which the plans’ goals are realized, and provide greater certainty for our communities and developers.

A challenge with these four plans is that they reside under different ministries within the Ontario government. It is suggested that these all be housed under the Ministry of Municipal Affairs and Housing. This would bring consistency to the plans and support the role of agriculture better in terms of environmental goods and services contributions. There should be a larger role for the Ontario Ministry of Agriculture, Food, and Rural Affairs (OMAFRA) in these discussions as well. There is also a need for clearer definition of the roles these plans take when they cross jurisdictions.

It is also suggested that because there are four plans, what policies within each plan should be dropped?  All of these plans impact agriculture to differing degrees, and this should be addressed. Further, enforcement of density targets must happen.

The OFVGA is supportive of one major plan, recognizing the utility of the individual plans where required. These components could be brought in under one plan.  The OFVGA is not supportive of more restrictive policies being applied to other aspects of the Greenbelt, such as seen in the NEC and the Oak Ridges Moraine.


Farmers have long been stewards of the land that they produce off, as it is a necessity and is directly related to their livelihood.  They have long-term investments and policies which negatively impact the economic viability of the farm are strongly discouraged.  Agricultural policies should be developed with the full knowledge of the diversity of the sector, farm unit size, the application of best management practices, and the positive environmental contribution that farms make.  Policies should be made to support farming and investments need to be made to ensure the viability of the farm within the auspices of the coordinated land use evaluation exhibited through these four land use policies.

To download a PDF of the OFVGA response, click here.


The Ontario Fruit and Vegetable Growers’ Association (OFVGA) was established in 1859, which makes it one of Ontario and Canada’s oldest farm commodity organizations. As the voice of Ontario’s fruit, vegetable and greenhouse farmers, the OFVGA is a nationally recognized not-for-profit association that advocates on behalf of Ontario fruit and vegetable farmers and the edible horticulture industry, and represents its members provincially, nationally, and internationally. 

The sector supports 30,000 farm-based, non-family jobs in Ontario, as well as a further 8,700 jobs specific to horticulture and specialty crops. Over 125 different fruit and vegetable crops are grown in Ontario with an estimated annual farm gate value of $1.6 billion (2013).

Members of the OFVGA are strongly committed to providing safe and sustainable food to the consumer.  It is in the best interests of producers and consumers that food be produced and delivered in the most efficient manner possible, taking advantages of the most current technologies and innovation to make this so.  Fruit, vegetable and greenhouse farmers in Ontario must continue to invest to remain competitive in the global landscape.


Dr. John Kelly, Executive Vice President
Ontario Fruit & Vegetable Growers Association
105 – 355 Elmira Road North
Guelph, Ontario.  N1K 1S5
519 763 6160 x115

Jason Verkaik, OFVGA Chair of the Board of Directors
Ontario Fruit & Vegetable Growers Association
905 775 2432

Alison Robertson, Program Manager
Ontario Fruit & Vegetable Growers Association
519 763 6160 x121

Brian Gilroy, Section Chair
Ontario Fruit & Vegetable Growers Association
519 270 3032

Jody Mott, Interim Executive Director
Holland Marsh Growers Association
50 Bradford Street, Suite 1514
Bradford, Ontario. L3Z 1A0
905 251 6786

Kenny Forth, Director
Ontario Fruit & Vegetable Growers Association
905 961 8643

Sarah Marshall, Manager
Ontario Tender Fruit Producers
1634 South Service Road
St. Catharines, Ontario.  L2R 6P9
905 688 0990