Christy Kelly-Bisson

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[Sustain Ontario] Farmland Loss and Preservation in Ontario

By

Christopher Kelly-Bisson

Farming and Farmland NetworkResearch (2017)
Policy Area 1 – Farmland Preservation
By Christopher Kelly-Bisson (cbiss045@uottawa.ca)

Goal:
Survey evidence and policy options to inform advocacy to keep Ontario farmland in agricultural production.

Evidence of Farmland Loss Problem:
Ontario has been facing a steady decline in its agricultural land base since the early 1970s. The total amount of land on farms in Ontario has decreased by 11.5% from 1986 to 2016. The amount of land actively in use for crops and pasture has decreased by 8.9% over the same period (over a million acres)1. Only 5% of the national agricultural land base is considered prime agricultural land (classes 1-3).

This trend is especially problematic in Ontario, where 51% of Canada’s prime agricultural land is located2. Despite this abundance, Ontario only uses about 7% of its best quality (class 1) farmland, with the remainder increasingly being converted to urban development . In total, Ontario saw a 7.2% reduction3 in
the available farmland between 2006 and 2016 , which is a yearly rate of loss equal to a quarter the size of Toronto45. Ontario is also seeing a decline in farmland accessibility, where socioeconomic pressures of agricultural production (i.e. farm debt, input costs, commodity prices, and farmland values) are increasingly rendering farmland inaccessible to farmers6. The challenge of keeping farmland in agricultural production requires addressing both the protection of farmland from conversion as well as ensuring that farming on such land remains viable.

Farmland loss and inaccessibility are problems because a sustainable local food system in Ontario requires an adequate land base and farming population for production. In addition, the stability of rural communities rely on availability of prime agricultural land, and sustainable farming practices have the promise of fulfilling ecosystem services for all Ontarians that developed areas cannot provide.

Losses in the already limited supply of prime agricultural land therefore have negative consequences on food security, the stability of rural communities , and ecological sustainability789.

Farmland Loss Pressures

There are five main political and economic pressures that have resulted in farmland loss in Ontario. The primary social force resulting in farmland loss is urban expansion, which emerged as a problem in the post-war housing boom. Increasing rates of population growth in urban centres have resulted in the expansion of housing development at the peripheries of cities, which is where most of Ontario’s prime agricultural land is located10.

The second pressure is the practices of land consolidation and severance on agricultural properties. The consolidation of farmland is when an individual or business purchases a number of agricultural properties to combine into one larger property. Often what follows are severances—when the owner of a farm property has their land broken up into smaller properties, often done to remove surplus
housing from the property. The detachment of residential structures in agricultural areas results in a gradual fragmentation of farmland that are converted to non-agricultural uses, such as non-agricultural housing and cottage properties. The land use conflicts that then arise from fragmentation tend to place prohibitive restrictions on farming practices to reduce the sights, sounds, and smells of production11.

The third pressure is a process of financialization that is occurring throughout Canada’s food system. This is where the inputs into the production and distribution of food increasingly become owned by financial entities investing for the purposes of speculative profits. Cases in Saskatchewan have demonstrated that financial investment firms and sovereign wealth funds are increasingly buying farmland to hold for decades, and profit off of the rents of production and increased property values12. In Edmonton, one company was documented buying a large area of class 1 farmland and then pressuring the municipal government to expand the urban boundary to eventually profit from its sale to real estate developers13. Companies are known to be buying farmland throughout southern and eastern Ontario for
this purpose14. Financialization, as demonstrated above, has the effect of facilitating farmland conversions15.

The fourth pressure is farm viability. Farmers are increasingly faced by mounting debt, input and equipment costs, market uncertainty, and property values. These factors make the already diminishing supply of farmland inaccessible to farmers . Farmers facing this price-cost squeeze find themselves increasingly in competition with affluent land buyers seeking rural property for recreational purposes16. This
has the effect of greater farmland conversion away from agriculture and towards cottages and hobby farms.

The final pressure on farmland is public expropriation, which can either contribute to farmland preservation or result directly in its loss. The Federal Government and the Province of Ontario both have powers to compel owners to sell their farmland for purposes deemed to be in the public interest. This power has been exercised in ways that were intended to preserve farmland, such as with the National Capital Commission (NCC) in the establishment of the Ottawa Greenbelt and the Central Experimental Farm (CEF), or Parks Canada with the Rouge National Urban Park . Alternatively, it can be exercised at the cost of compromising agricultural viability, through stewardship that neglects the needs of the farming communities on their lands, or encourages soil mining through short-term lease arrangements1718. For instance, the loss of publicly-owned agricultural facilities is apparent with the recent approval to develop a non-farmland section of the CEF containing agricultural research facilities for new medical facilities . This has similarly been the case on the ‘Airport Lands’ near Pickering, expropriated over 45
years ago for a future airport and leased year-to-year until 20171920.

Regional Differences
The loss of farmland in Ontario is experienced differently in different regions. Its governance also varies based on differing ecological/climatic/geological, socioeconomic, and political contexts in which farmland is located. Effective policy that protects farmland in Ontario must therefore take these geographic differences into consideration and coordinate levels of governance . Biophysical and climatic regional diversity produces substantial differences in agricultural practices and challenges21. Measures for farmland preservation needs to take into consideration the diversity of climates, soil-types, pest and wildlife pressures, and water and precipitation in determining the types of agricultural practices and land use designation. The value of farmland most suitable for dairy production in Northern Ontario for instance cannot be measured-up against prime agriculture land in the Niagara region capable of supporting fruit production.

Socioeconomic regional differences in Ontario–as they relate to agriculture–have been categorized by Troughton into three geographic zones: the exurban fringe surrounding cities, the hinterland which constitutes Ontario’s traditional rural-agricultural territory, and the periphery expanding into remote unincorporated areas . A category for the recently increasing amount of urban agriculture
should also be noted22. Categories of land use governance are then determined by the legal jurisdiction of Canada’s various levels of government. The great majority of farmland in Ontario is already surveyed, legally enclosed, privately-owned, and located within an incorporated municipality. These lands are therefore subject to Ontario’s Planning Act, which is detailed further in the next section. There are also Provincial Crown Lands, which are subject to the Public Land Act, which are mostly conservation areas and sanctuaries. Federal Crown Lands are subject to various Acts of Parliament and federal institutions, such as the Department of National Defence (DND), Transport Canada, or the NCC. Finally, there is farmland in Ontario that is unceded and unsurrendered (i.e. Algonquins of Ontario) or subject to Canada’s treaty relationships with First Nations (i.e. reservations and the Numbered Treaties). It is important to note that the definition of some of these lands are currently in a process of treaty negotiations with the Federal and Provincial Governments, as with the Algonquins of Ontario in eastern Ontario.

Existing Policy Framework

Ontario has historically trailed behind other provinces in terms of implementing measures to preserve farmland. In fact, to this day, what exists in Ontario is a patchwork of policies governing land use, relying on municipal initiatives and interpretations in the implementation provincially-directed priorities. There isn’t
an explicit imperative to preserve prime agriculture land throughout the province.

Ontario once attempted to legislate a relatively weaker version of B.C. and Quebec’s system of farmland protection zones and councils in 1978, which would have been called the Land Use Guideline, but it was never legislated. Rather, Ontario adopted a Foodland Guidelines policy statement in 1978, which was replaced 1997 by priorities given in Provincial Policy Statements, updated periodically since23.

Farmland preservation in Ontario is governed through the land-use planning process. The process of land use planning is established in law through The Planning Act which empowers municipal governments to implement land use priorities in a local context through Official Plans (OPs), Zoning Bylaws (ZBLs), plans of subdivision, and minor variances. Municipal land use decisions, however, are
subject to appeals by an independent provincial tribunal called the Ontario Municipal Board (OMB), which has the power to approve, refuse, or modify decisions in the case of a conflict. The province establishes the land use priorities to be administered by municipalities through Provincial Policy Statements and
regional legislation governing specific land use, agricultural practices, urban expansion, infrastructure, and conservation priorities. Ontario has numerous regional land use and growth policies, such as: the Places to Grow Act, 2005; the Niagara Escarpment Planning and Development Act, 2017; Local Food Act, 2013; the Greenbelt Act, 2005; and the Oak Ridges Moraine Conservation Act, 2001. All of these policies are accompanied with implementation plans that inform specific land use priorities in their application. The Local Food Act, 2013 also provides some policy support for local food production that impacts land use decision making with recommendations outlined in the Local Food Strategy.

Ontario’s existing patchwork of legislation surrounding farmland preservation is currently undergoing review and consultation. The Province recently drafted the Places to Grow Plan, 2017 for the Greater Golden Horseshoe. This plan is an update on the Growth Plan, 2006, corresponding to the Places to Grow Act, 2005. It situates the Plan within current growth trends, the context of the various other regional land use plans, and the most recent Provincial Policy Statement, 2014.

Provisions included in the Plan are greater mapping and identification of prime agriculture land, stricter criteria for how development on farmland is permitted, and the requirement for agricultural impact assessments in the approval of development. Consultations have also taken place surrounding the implementation of the proposed Farms Forever Program, where the Province has detailed farmland protection as one of its policy objectives24. It recognizes that the province’s land use planning strategy is not adequately preventing farmland loss and calls for policy to strengthen farmland protection policies. However, this priority area remains almost entirely focused on the Greater Golden Horseshoe region, with little discussion on addressing farmland loss in southwestern, eastern, and northern Ontario25.

The Provincial Government has recently tabled Bill 139, Building Better Communities and Conserving Watersheds Act, 2017, which is intended to amend the Planning Act to include significant reforms to the current appeals process. The bill, if passed, would create a Local Planning Appeal Tribunal to replace the OMB, supported by a Local Planning Appeal Support Centre. It would also weaken the
board/tribunal’s ability to interfere in municipal land use decisions, offering planning suggestions rather than overturning rulings (except in the case of a failed second appeal). The bill would also limit the ability to appeal “major planning decisions”, such as upper-tier municipality or provincial land use plans (i.e. PPSs or the Places to Grow Act). The reforms would strengthen Ontario’s policy framework to preserve conservation and watershed areas, which includes provisions for farmland protection26.

Other policy tools exist in Ontario that are less directed at province-wide farmland preservation, but are worth considering. Farmers in Ontario have ability through the Conservation of Land Act, 2005 to place a Conservation Easement on their agricultural property, which is an agreement made between property owners and a conservation body or land trust organization. The terms of the easement then
determine permissible forms of land use, which are tied to the title of the property. This form of conservation is very effective, especially at raising public awareness around the need to preserve farmland. However, it requires the owner and conservation body to incur the cost and labour of preservation and monitoring, and relies of the voluntary submission of individual parcels rather than
broader groupings of land27.

There are also regulations on agricultural practices governed by the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA), such as Minimum Distance of Separation (MDS) standards, which requires an easement distance for residential areas from agricultural production facilities to prevent land use conflicts. Such policies are effective at preventing conversion around existing agricultural production facilities28. However, these regulations have tended to work against farms located close to residential areas when they seek expansion. They also privilege conventional agricultural practices and MDS standards may sometimes work against the preservation of small-scale, alternative, or specialty production farms that do not conform to their conventions. OMAFRA also has an impact in defining standard agricultural practices and secondary uses for farmland (i.e. agro-tourism operations or processing facilities) that have an effect on how agricultural zoning bylaws are determined and enforced2930.

OMAFRA is currently in consultations for an Agricultural System policy that would integrate standard practices existing land use policies surrounding the Greater Golden Horseshoe area implemented to contribute to the preservation of prime agriculture land . Finally, there are property and income tax incentives that impact farmland preservation31. In Ontario, agricultural landowners can receive benefits from favourable land value assessments. They can also receive a property tax at 25% of rate set by their local municipality. Charitable tax receipts can also gained by the owners of farmland if they choose to donate land or an easement to a credible conservation organization . However, these tax-based policies only incentivize agricultural uses of any kind for farmland32. They do not compel farmland owners to preserve farmland. Furthermore, such policies can act as an incentive for the investment and consolidation of farmland by financial institutions for speculative gains.

The federal government also has some impact on farmland preservation beyond their ownership of Crown Lands. The national agriculture framework–currently known as Growing Forward 2–is a program administered in cooperation between Agriculture and Agrifoods Canada (AAFC) with the provinces and territories. It administers risk management tools, and innovation and business development funding. The federal government has within its powers the ability to include policy instruments or funding requirements that could promote farmland preservation.

Consultations for the new Canadian Agricultural Partnership framework is ending soon, however it is not likely to include any direct provisions contributing to the preservation of farmland. More recently, AAFC has announced the creation of a nation-wide Food Policy for Canada which is currently in consultation for the drafting of a bill to see legislation in the Spring.

Options for Policy Change
There are a broad varieties of possible policy change that can impact farmland preservation that range from minor amendments to major overhauls. The following section details possible policy options categorized by their correspondence to existing policy. The policy options are listed within the categories in order from least to greatest magnitude of change.

Stand-Alone Municipal Policy Initiatives

A – Promoting greater public awareness for the need to preserve farmland3334.

B – Conduct robust soil mapping studies that take into account a holistic approach to food production, such as the Land Evaluation and Area Review (LEAR) study conducted by the City of Ottawa35.

C – Formation of Agricultural Advisory Committees in municipalities to consult local farmers on farmland use planning36.

D – Urban temporary-use permits & interim control bylaws so that arable urban land that is currently not in use can be used for food production37.

E – Review urban animal control policies to permit livestock production on urban land38.

F – Urban neighbourhood risk-management policies to more easily facilitate the development of urban agriculture on arable urban lands39.

G – Update ZBLs to reflect modern agriculture practices and conform to contemporary Official Plans. Greater definition is needed in ZBLs and OPs regarding “small-scale”, “minor”, and “farm” in order to avoid challenges for small-scale producers to attain approval for their operations40.

Changes to the Planning Act and Growth Plans
A – Revise exemptions to categories permitted for severance41.

B – Requiring provincial approval for farmland conversion, rather than just municipalities42.

C – Establish alternative system of small-scale land tenureship, such as easements, farm incubators, and lease arrangements, to transition new farmers into land ownership43.

D – Incentivise good municipal practices with financial assistance in planning and awards44.

E – Adoption of a province-wide development plan similar to Places to Grow including funding for development of necessary infrastructure45.

F – Greater policy and financial support for near-urban farmers to ensure their viability, including funding for the rehabilitation of degraded land46.

G – Revise policies on the development of mining for aggregates addressing where it is most appropriately located and the need for more recycling of minerals47.

H – Expansion of Permanent Agricultural Districts (PAD) throughout Ontario: Involves planning controls, farming support, and property tax incentives similar to the Greater Golden Horseshoe Greenbelt. Combination of measures needs to be well-coordinated. Protects entire regions for agricultural production48.

I – Institute local ownership capital controls on farmland: Currently used in Quebec and formerly in Saskatchewan. Places limits on the quantity of farmland that can be owned by individuals or entities located outside of Ontario49.

J – Institute a system of Agricultural Land Reserves (ALR): Currently administered in British Columbia and Quebec. Entails the formation of a public commission or council to govern lands in the reservation with a mandate of promoting agriculture as the primary use50.

Federal Policy
A – Inclusion of the preservation of farmland as a national priority within a National Food Policy, and inclusion of farmland preservation civil society groups and farmer
organizations in any food policy councils responsible for its governance.

B – Inclusion of farmland preservation as a condition for the availability of funding and access to risk management tools in any future inter-governmental agricultural frameworks.

C – Consultation (directed primarily at First Nations in a manner respecting the provision set out in the RCAP and UNDRIP) and accompanying order-in-council for the prioritization of agricultural use of prime agricultural Crown Lands.

D – National capital controls for the ownership of farmland.

E – Public expropriation of farmlands under the management of financial investment firms and sovereign wealth funds for the establishment of a national ALR.

Easements, Land Trusts, & Tax Incentives

A – Expansion of urban agriculture tax credits to municipalities throughout Ontario51.

B – Provide financial support and raise awareness for land trusts & agricultural easements52.

C – Incentivise the preservation of farmland for its public provision of ecosystem services53.


D – Develop system of Purchase of Development Rights (PDR): Generally used by
municipalities throughout the United States. Entails public compensation to farmland owners for the placement of conservation easements54.

Agricultural Monitoring and Standards
A – Greater support for the monitoring and analysis of farmland in Ontario. Including studying the impacts of development in proximity to farmland.

B – Revise MDS standards to include different approaches to smaller-scale and alternative mixed-production categories55.

C – Multiple agricultural land designations should have categories that use firm-scaled setback for small-scale and mixed-use agriculture as an alternative to MDS formula for large-scale livestock production56.

D – Municipalities could form mixed-use clusters that are exempt from MDS formula57.

E – Formula could be created to determine minimum farm size appropriate for a series of different categories of agricultural production. Needs to balance the need to keep parcels large enough and in agricultural production in order to prevent development58.

Read the original research paper HERE

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