Recently, the provincial government put forward Bill 23, the More Homes Built Faster Act. The purpose of this bill is to address the housing crisis, which is a serious concern for many Ontarians. However, whether these policy changes will provide any solutions or progress towards housing affordability is being questioned by groups across a variety of sectors. If we fail to address this crisis effectively, we will only be adding to challenges that Ontarians will face in the coming years.

With a growing population, Ontario does need more housing, particularly affordable housing, however we will also need farmland to feed the people living in those houses. The effects of climate change (like increased flooding, droughts, and wildfires) are being felt around the globe, and are affecting the ability of Ontario to import food. Now, more than ever, we need to focus on ensuring Ontario has the ability to be food secure.

Any potential positive changes for agriculture in Bill 23 are overshadowed by the significant threats it poses to the overall Ontario agricultural system and the associated natural habitats, which we rely on for significant ecosystem services.

OFT has summarized our understanding on the impacts Bill 23 will have on farmland. To begin, we chose to focus on the aspect of merging the Provincial Policy Statement (PPS) and the Growth Plan that is proposed. We have also briefly touched on the proposed offsetting program and the potential changes to the Greenbelt.

The bill is significant, and we will continue to explore these proposed changes.

The Integration of the Provincial Policy Statement (PPS) and A Place to Grow (The Growth Plan)

This is change will likely have the greatest impact on agricultural lands.

The Growth Plan is a set of policies that affect land use planning in the Greater Golden Horseshoe, an area with some of the highest development pressures in the country1. The Provincial Policy Statement informs community planning elsewhere in Ontario. The PPS does not have the same strong protections for farmland and natural habitats as the Growth Plan does, and their proposed integration is of significant concern.

1. The PPS does not require the mapping of agricultural systems, whereas the Growth Plan does. The mapping of these systems allows for local municipalities to apply local knowledge to land use planning policy. OFT has recommended that the Province create a comprehensive agricultural system map for the entirety of Ontario in the past, and we still encourage this approach. Removing the requirement for this mapping may result in local agricultural systems being fragmented by development which can negatively impact local agriculture.

2. We know that Ontario’s agricultural sector is as diverse as the soils that support it, and it is important that we protect all of our agricultural soils. Changes to protections for rural lands that have been proposed in Bill 23 could result in Class 4, 5, and 6 lands being lost to development as they do not receive the same, stronger, protections as prime agricultural lands (Classes 1, 2, 3 and Organic).

3. Allowing more development in rural areas without proper municipal services (e.g. sewer, water) may create problems for rural municipalities in the future, as rural infrastructure (e.g. septic, well water) may not be able to support it. The increased allowances for severances and development on rural lands will also increase the likelihood of the local agricultural system experiencing fragmentation. Fragmentation can also result in negative impacts on existing communities, such as increased traffic on rural roads which can impede the safe movement of farm equipment.

4. The PPS also provides broader permissions for development within the natural heritage system in comparison to the Growth Plan. Agricultural lands work hand in hand with natural areas for important ecosystem services like pollination, flood prevention, erosion prevention, carbon sequestration, and more. The combination of farmland and natural lands has made the GGH one of the most productive agricultural areas in Canada 2. It is important that both natural areas and farmland receive high levels of protection in land use planning policy.

    The Greenbelt and Offsetting

    Bill 23 proposes removing 7400 acres of farmland and greenspace from the Greenbelt and offsetting this loss by adding 9400 acres of land to the Greenbelt in other areas.  While overall this will result in a net increase in protected area, most of the lands that are going to be added to the Greenbelt already receive protection through environmental policy (e.g. river valleys). The land that is being removed, much of which is farmland, does not receive these same protections. Note, the International Union for Conservation of Nature (IUCN) states that offsets must be more than twice the area being lost in order restore the lost biodiversity and ultimately, that offsetting is not a viable solution 3. Farmland may also be an easy target for places for the offset wetlands, which will result in more agricultural lands being taken out of production.

    Offsetting has also been proposed within Bill 23 in order to permit development on wetlands and sensitive ecological areas, however no detailed offsetting requirements were provided. Wetlands are crucial to our landscape, and help to mitigate and prevent floods4. Without them, the landscape is at risk of increased flooding, which means that farmlands may experience higher levels of erosion that wash away precious soil. It takes approximately 100 years for one inch of soil to form, so it is crucial that we protect what we have.

    It is also worth noting that in the proposed changes to the Greenbelt, parts of the Duffins Rouge Agricultural Preserve are going to be removed from the protected area. These lands contain specialty crop areas and are home to unique microclimates that contribute to our diverse food system, and cannot be replicated elsewhere.

    Additional Comments

    Finally, OFT is concerned about the changes of powers for the Ontario Land Tribunal that are proposed in Bill 23. Currently, the Tribunal allows for a third party to appeal planning decisions, which can be crucial for farmers when planning mistakes will impact their livelihood (e.g. when the Minimum Distance Separation Formulae has not been followed, allowing development to occur too close to a manure storage facility, causing significant conflicts between farmers and the new residents). OFT believes it is important that the agricultural community still have mechanisms such as third-party appeals, as a means to correct planning issues.

    Ontario needs an increased housing supply, but this is not an effective solution. It is likely that these changes will result in mainly detached, single-family homes being built. These homes will still be unaffordable for potential new homebuyers, and will not solve the housing crisis. We need to focus on building high-density housing options in pre-developed areas that are affordable, walkable, and easily accessible via public transit. Doing so will help ensure that we are developing equitable communities that will actually address the housing crisis and help Ontarians5.

    We understand that this is a lot to take in, however we cannot let the extent of the changes make us apathetic. Your voice has the chance to make a difference.

    Reach out to your local MPPs and let them know what you think about Bill 23. Your local elected officials need to know that you care about farmland and natural habitat in your area.

    OFT will also be preparing a policy submission on Bill 23 to be sent through the Environmental Registry of Ontario (ERO), in the hopes that the Province will consider adjusting the Bill to meet the needs of current and future Ontarians. Citizens may also submit comments through the ERO, and via email. For instructions on how to submit a comment through the ERO refer to the specific posting you would like to comment on. Find postings about Bill 23 by searching the ERO here.

    Read the entirety of Bill 23 here: https://www.ola.org/en/legislative-business/bills/parliament-43/session-1/bill-23


    References

    1. Statistics Canada. (2022). Canada’s fastest growing and decreasing municipalities from 2016 to 2021. https://www12.statcan.gc.ca/census-recensement/2021/as-sa/98-200-x/2021001/98-200-x2021001-eng.cfm
    2. Ontario Federation of Agriculture and Environmental Defence. (2015). Farmland at risk: Why land-use planning needs improvement for a healthy agricultural future in the Greater Golden Horseshoe. https://d3n8a8pro7vhmx.cloudfront.net/greenbelt/pages/2544/attachments/original/1449244985/2015-11-18-Farmland_at_Risk-highres_WEB_(1).pdf?1449244985
    3. Sonter, L., Simmonds, J., Watson, J., and Maron, M. (2020). Biodiversity offsetting requires lots of land. International Union for Conservation of Nature. https://www.iucn.org/news/business-and-biodiversity/202004/biodiversity-offsetting-requires-lots-land
    4. Pattison-Williams, J. K., Pomeroy, J. W., Badiou, P., and Gabor, S. (2018). Wetlands, flood control and ecosystem services in the Smith Creek Drainage Basin: A Case Study in Saskatchewan Canada. Ecological Economics. 147:36-47. https://alus.ca/wp-content/uploads/2018/06/Pattison-Williams_et_al_2018.pdf
    5. Jacobus, R. (2019). Inclusionary housing: Creating and maintaining equitable communities. Lincoln Institute of Land Policy. https://www.jstor.org/stable/pdf/resrep22075.pdf