OFA appreciates this opportunity to provide input to ERO #019-8462 Review of proposed policies for a new provincial planning policy instrument as the Ministry of Municipal Affairs and Housing (MMAH) seeks input on how to create a streamlined provincewide land use planning policy framework that enables municipalities to approve housing faster and increase housing supply.
OFA thanks the government for updating the proposed Provincial Planning Statement (proposed PPS2024) to include the following recommendations made by OFA:
- to not carry forward previously proposed policies that would have permitted the creation of three additional residential lots per parcel in prime agricultural areas;
- to permit more housing on farms to support farmers and farm families without creating new lots, through enhanced policy and criteria supporting additional residential units;
- require planning authorities to use an agricultural system approach, based on provincial guidance, to maintain and enhance a geographically continuous agricultural land base; and
- state that impacts from any new or expanding non-agricultural uses on the agricultural system, or where avoidance is not possible, are to be minimized and mitigated as determined through an agricultural impact assessment or equivalent analysis, based on provincial guidance.
OFA recommendations include:
- explicitly stating that only one new residential lot may be created in a prime agriculture area per farm consolidation in the case of the severance of a residence surplus to an agricultural operation and that the new residential lot must include the surplus residential dwelling and any associated additional residential units;
- revising the meaning of “prime agricultural lands” to include soil class 4 farmland, and adding the meaning of “farm consolidation”, in the definitions section of the PPS;
- developing and releasing provincial guidance with respect to:
- Additional Residential Units located on a lot in a Prime Agricultural Area, including application of Minimum Distance Separation (MDS);
- Lot creation in prime agricultural areas;
- Agricultural Impact Assessments; and
- Required information for the implementation of the Agricultural System approach including mapping.
- a greater emphasis be placed on intensification and redevelopment by setting fixed urban boundaries and mandating planning authorities to meet significant minimum targets for intensification and redevelopment within built-up areas.
- that no settlement area boundary expansions be permitted unless all established minimum requirements for intensification and redevelopment within the existing built-up area have been met. When identifying a new settlement area or allowing a settlement area boundary expansion, OFA recommends that planning authorities be required to demonstrate that criteria were considered, including:
- whether the applicable lands comprise specialty crop areas;
- the evaluation of alternative locations which avoid prime agricultural areas and, where avoidance is not possible, demonstrate reasonable alternatives on lower priority agricultural lands in prime agricultural areas were considered;
- whether the new or expanded settlement area complies with the minimum distance separation formulae; and
- whether impacts on surrounding agricultural operations and lands as well as the agricultural system are avoided, or where avoidance is not possible, minimized and mitigated to the extent feasible as determined through an agricultural impact assessment or equivalent analysis, based on provincial guidance.
OFA is pleased the government decided to hold further public consultations on the specific proposed wording contained in these proposed PPS2024 policies. OFA appreciates the opportunity to provide our feedback and agricultural perspectives. We look forward to working with the provincial government and our municipal counterparts to find ways that build more homes and protect farmland and the Agricultural System.
Previous related OFA submissions:
May 11, 2023 – OFA submission to the Standing Committee regarding proposed Planning Act changes as specified in schedule 6 of Bill 97
May 5, 2023 – OFA submission regarding proposed Planning Act changes as specified in schedule 6 of Bill 97 (ERO 019-6821)
December 23, 2022 – OFA submission to the Ontario Ministry of Municipal Affairs and Housing regarding the review of A Place to Grow (APTG) and Provincial Policy Statement (PPS) (ERO 019-6177)
December 9, 2022 – OFA submission to the Ministry of Municipal Affairs and Housing regarding proposed changes to Ontario Regulation 299/19: Additional Residential Units (ERO 019-6197)