Friends of the greenbelt, Dufferin-Caledon; Grand(m)others Act to Save the Planet; Mr. Keith Emiry
Ms. Victoria Creese
My name is Victoria Creese and I am co-chair of GASP, Grand(m)others Act to Save the Planet, a grassroots climate action and advocacy group with more than 170 members across Ontario. We are committed to creating a sustainable environment for future generations. Thank you for the opportunity to speak today on Bill 109. My remarks will focus specifically on schedule 3, the Farmland Security Act. Farmland is a non-renewable resource that forms the foundation of Ontario’s food security. It supports rural economies, sustains biodiversity and strengthens environmental resilience. As climate change, population growth and global supply chain disruptions place increasing pressure on food production, protecting Ontario’s most productive farmland has never been more important. Every acre of farmland permanently lost today reduces the province’s ability to feed future generations. There is broad agreement that Ontario is losing farmland at an alarming rate. According to figures based on the 2021 census of agriculture, an average of 319 acres is lost every day. That is a staggering number and one that demands meaningful action. We commend the government for recognizing this issue as schedule 3 provides the framework to regulate foreign and other designated persons from speculating on Ontario farmland. However, the proposed legislation does not go far enough. If the objective of Bill 109 is to protect Ontario’s food independence, it should address all major sources of speculative pressure, not only foreign ownership. GASP therefore recommends that both foreign and domestic speculators be explicitly identified as designated persons in the act itself rather than left to future regulation. Doing so would provide greater transparency, permanence and certainty. Much of the farmland being removed from agriculture production is owned by domestic investors and developers who purchase land for speculation rather than farming. The Ontario Farmland Trust has identified domestic speculation as a growing threat to the long-term viability of Ontario’s agricultural sector. Speculative purchasing inflates farmland prices beyond what working farmers can afford, making it increasingly difficult for the next generation of farmers to acquire land. The limitations to schedule 3 become clear when we consider farmland that is already under threat from domestic speculation and development decisions. An example is the proposed Highway 413 corridor and the lands adjacent to it. In anticipation of the highway and the development opportunities it is expected to create, developers have purchased large areas of farmland, all of it class 1 and class 2, with the expectation that it will eventually be rezoned for development. The highway itself is projected to pave over 2,000 acres of prime farmland. This raises an important public policy question: How do we balance the need for transportation infrastructure and housing with the equally essential need to protect prime farmland and ensure long-term food security? Research has consistently shown that Ontario can build the affordable homes it needs within existing urban boundaries through more efficient land use and higher-density development. Protecting farmland and meeting housing needs are not mutually exclusive goals. Similarly, in the case of the 413, multiple transportation experts, including the government’s own analysis, call into question whether the highway will provide meaningful long-term congestion relief. Fortunately, alternatives to Highway 413 exist, such as making greater use of the 407 for truck traffic and investing in public transit. Thus, the permanent loss of Ontario’s best farmland can be avoided. When alternates to development exist, protecting prime agricultural land must take precedence over decisions that would result in its irreversible loss. Bill 109 provides an opportunity to ensure that future decisions better protect Ontario’s farmland, regardless of whether pressures come from foreign ownership, domestic speculation or infrastructure development. The decision to build Highway 413 should be reviewed through the same lens to ensure it aligns with the act’s objectives of safeguarding Ontario’s agricultural land for future generations. It is not too late to change course on this highway, as the design phase has not yet been completed and federal permits have not been granted. GASP respectfully recommends that schedule 3 be amended to include the following additional protections: —introduce stronger protections within the act itself against all speculative pressures, both foreign and domestic; —require a transparent and fully accountable agricultural impact assessment process before any farmland is removed for development or infrastructure projects; and —require an assessment of alternatives to determine whether the proposed project can be delivered in a way that avoids the loss of agricultural land. As a long-term solution, GASP supports the creation of a food belt as proposed in Bill 21, introduced by MPPs Mike Schreiner and Bobbi Ann Brady. Ontario’s farmland is not just land—it is our food, our resilience against climate change, our legacy for upcoming generations. Once it is paved over, it is gone forever.