THE VOICE OF ONTARIO'S FRUIT, VEGETABLE
AND GREENHOUSE PRODUCERS FOROVER 150 YEARS

OFVGA response to Guidelines on Permitted Uses In Ontario's Prime Agricultural Areas

Strawberry Farm
A strawberry farm gets ready for the annual picking season. Photo provided by Rosalind Mitchell, Creative Commons

Executive Summary

  • Clarify the impact of these guidelines, how they are to be implemented, and the relationship to municipal policies and regulations.
  • Clarification of the impacts on taxation (in particular, tax classification) is required.
  • Grandfathering of current operations is essential.

 
OVERVIEW

It is clear that there have been challenges between agricultural producers and municipal policy. In particular, the inconsistent application of policies across the province of Ontario has led to angst in the rural community. Inconsistencies have led to farmers in one area subjected to different regulations than others from a separate area that produce the same product. Further, the development of value added production on-farm has led to many diversified practices, which must be supported as they enhance the value of the agricultural operation and in many cases are necessary for the sustainability and viability of the farming operation.

This set of guidelines is important to members of the OFVGA and the feedback that we provide is intended to provide clarity, direction, and support for policies that favourably impact the agricultural sector.

CONTEXT

The Ontario Ministry of Agriculture, Food, and Rural Affairs (OMAFRA) released Guidelines on Permitted Uses in Ontario’s Prime Agricultural Areas to bring clarity to the Provincial Policy Statement (PPS) on uses that are permitted in prime agricultural areas. As members of the agricultural community, horticultural farmers will be directly impacted by directives impacting the use of agricultural land and therefore offer the following commentary on the guidelines.

The OFVGA supports a stakeholder-led, business and science-based approach to agricultural land use. In particular, OFVGA encourages guidelines that will provide the opportunity for farmers to extract more value from their operations, which is consistent with agricultural diversification. This relates primarily to the discussion surrounding the “Agriculture-related” and the “On-farm Diversified” uses.

A concern to OFVGA members is the inconsistency of municipal regulations across the province of Ontario.  The guidelines reported herein are an attempt to bring cohesion to how municipalities view agricultural land use.  The OFVGA is supportive of guidelines that are farmer friendly and support the goals and objectives of horticultural production.

Clarity

Having multiple designations for agricultural land means clarity is key in the classification of land use.  There are numerous scenarios from horticulture where classification is unclear. For example, in these guidelines, cherry pitting is considered both an agriculture-related use as well as an on-farm diversified use. In the guidelines, cherry processing was considered farming, while on the same page, the pitting of cherries was considered diversified.  These designations need to be concise and clear.

The OFVGA requests that the guidelines be made consistent, so that value-added and value-retention activities are not unintentionally shifted to commercial taxation.  While consistency across municipalities is an admirable goal for the province, care must be taken that any new guidelines be farming friendly and not lead to strained relations between municipalities and farming operations.

There are also questions regarding agricultural operations on non-agricultural land: will this land revert back to agricultural use?  This will lead to questions about the development of urban agriculture as well as the repurposing of land previously classified for a different use (e.g. industrial land being repurposed for greenhouse production).   

Questions concerning repurposing or replacing current buildings must be addressed. Do new buildings have to have the same footprint as previous operations (e.g. what happens when a fire destroys a current building?).

What is the minimal lot size? Specialty agriculture appears to be designated at 40 acres, however this used to be 25 acres. What is the impact on certain horticultural uses (greenhouse, tender fruit, berries, grapes, pick your own crops), which would be less than the 40 acres.  The 25 acres includes the footprint of the whole property.  Clarity is required around this issue. 

There remain some farming activities related to value retention that seem to fall between the definitions as illustrated on pages 28-31.  For example, a vegetable cold storage and packing shed is considered an agriculture-related use when it services farms in the area and can be either on- or off-farm and is not limited in size.  However, that same operation, when packing non-regional vegetables, would be considered a diversified use and would be size restricted if located on-farm. The question arises as to how a shed is classified if it accommodates both regional and non-regional vegetables? And how taxation is impacted by the various classifications? It would be our position that a shed that handles a majority of regional product should be considered an agriculture-related use and not be size restricted.

Taxation

With these proposed guidelines for agricultural land use, clarification of taxation is a concern to the OFVGA.  To what rate will it be taxed?  Taxation must remain supportive of the farming sector, be it agricultural, agriculture-related or diversified use. To do otherwise would threaten the competitiveness of the sector and inhibit our ability to meet the Premier’s challenge to the Ontario Agri-food sector. The OFVGA recommends that the government of Ontario continue to adhere to its internal policy of providing an economic impact assessment of the proposed guidelines.

Grandfathering Current Uses

The OFVGA supports the development of a “grandfathering” guideline to address current operations that may engage in activities beyond the defined specifics of the proposed guidelines.

Agriculture Related Uses

The OFVGA agrees with the Provincial Policy Statement that all agricultural-related uses may be of any type, size or intensity and respect normal farming practices.

Conclusions
The Ontario Fruit & Vegetable Growers Association (OFVGA) appreciates the opportunity to comment on these proposed guidelines. The OFVGA applauds the government of Ontario in attempting to enhance the profitability of horticultural farmers and to provide clarity to municipalities on the use of agricultural land.

The OFVGA is supportive of the government as it moves forward with policies that are comprehensive, science-based and economically sound. Policies that are brought forward must keep each of these things in mind for Ontario to have a stable, secure supply of locally produced food.

ABOUT THE OFVGA

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.

For more information, please contact: 

Dr. John Kelly, Executive Vice President
Ontario Fruit and Vegetable Growers' Association
105 – 355 Elmira Road North
Guelph, Ontario.  N1K 1S5
johnkelly@ofvga.org
519-763-6160 x115

Jason Verkaik, Chair of the Board of Directors
Ontario Fruit & Vegetable Growers Association
105 – 355 Elmira Road North
Guelph, Ontario  N1K 1S5
jason@carronfarms.ca
905-775-2432


Craig HunterResearch & Crop Protection
Ontario Fruit & Vegetable Growers Association
105 – 355 Elmira Road North
Guelph, Ontario.  N1K 1S5
Research@ofvga.org
519 763 6160 x119


Brian GilroySection Chair
Ontario Fruit & Vegetable Growers Association
105 – 355 Elmira Road North
Guelph, Ontario.  N1K 1S5
nighthawkorch@brucetelecom.com
519-270-3032

Charles Stevens, Section Chair
Ontario Fruit & Vegetable Growers Association
105 – 355 Elmira Road North,
Guelph, Ontario.  N1K 1S5
charles@wilmotblueberries.com
905-987-5279

Dr. Justine Taylor, Energy and Environment Co-ordinator
Ontario Greenhouse Vegetable Growers
32 Seneca Road
Leamington, Ontario. N8H 5H7
jtaylor@ontariogreenhouse.com
519-326-2604 x205

Adrian Huisman, CHC Representative
Ontario Fruit & Vegetable Growers Association
105 – 355 Elmira Road North,
Guelph, Ontario.  N1K 1S5
huismanadrian@gmail.com
905-328-0354

To download a copy of the response, click here.