Submission on 2026-2029 Draft Federal Sustainable Development Strategy, May 2026

May 11, 2026 

The Honourable Julie Dabrusin, P.C., M.P.

Minister of the Environment, Climate Change and Nature  

Via email: SDO-BDD@ec.gc.ca

Subject: Submission on 2026-2029 Draft Federal Sustainable Development Strategy

Dear Minister Dabrusin, 

Please accept this submission on behalf of Ontario Dietitians in Public Health (ODPH) in response to the 2026-2029 Draft Federal Sustainable Development Strategy. ODPH is the official association of Registered Dietitians working in Ontario’s public health system. We are commenting on two goals included in the draft SDS: Goal 1.3 Reduce poverty in Canada and Goal 2.2 Strengthen the resilience and sustainability of Canadian agriculture.

Goal 1.3 Reduce poverty in Canada

As public health professionals guided by evidence and committed to health equity and the upstream determinants of health, we support Goal 1.3, which aligns with efforts to improve the conditions that enable healthy eating and overall well-being. We recommend strengthening the Strategy through a more explicit focus on advancing a national Guaranteed Livable Basic Income (GLBI).

Since 2015, ODPH has strongly supported the concept of a GLBI as an effective policy lever to reduce household food insecurity (HFI) in Canada (1). HFI, defined as inadequate or insecure access to food due to financial constraints, is a serious public health issue, a marker of material deprivation, and a matter of public policy (2). It ranges from compromised diet quality to missed meals and, in severe cases, going days without eating.

In 2025, HFI in Canada remains near its highest level since national monitoring began nearly 20 years ago, affecting one in four Canadians (24%), or approximately 9.8 million people, including 2.4 million children (3). These figures exclude First Nations communities and the territories, where rates are often even higher. Provincial rates varied significantly, ranging from 19.8% in Quebec to 30.9% in Alberta, highlighting the need for a coordinated national response (3).  

HFI is fundamentally an income issue. In 2023, 70% of households relying on social assistance experienced HFI, and notably, 58.6% of food-insecure households reported employment as their main source of income (3). This reflects a growing prevalence of low-wage, precarious employment, unstable hours, and a lack of essential benefits that undermines financial stability (5). At the same time, the cost of living continues to rise, with substantial increases in the cost of shelter, food, and transportation since 2021 (4).

The health impacts of HFI are profound. Canadian research consistently shows strong associations between HFI and poorer physical and mental health outcomes, including increased risk of hospitalization, longer hospital stays, and premature mortality (6). The likelihood of depression, anxiety, and other mental health conditions increases with the severity of HFI (6). These outcomes place significant strain on Canada’s publicly funded healthcare system (7), underscoring the importance of income-based interventions that can both improve population health and reduce public expenditures. These savings must be considered with a national GLBI. 

Despite decades of reliance on charitable responses, food banks are not a solution to HFI. In March 2025 alone, food banks across Canada recorded over 2 million visits—a nearly 100% increase compared to 2019 (4). Yet, only about one-quarter of food-insecure households use food banks, and for those who do, food insecurity typically persists (8). Recent declarations of food insecurity emergencies by municipalities[1] across Ontario further highlight the scale and urgency of this issue.

Evidence is clear that policies which improve income adequacy such as public pensions, child benefits, and minimum wage increases, lead to reductions in HFI (8). The most compelling example is Canada’s public pension system, where eligibility has been shown to reduce food insecurity among low-income seniors by nearly 50% (10). Extending this approach to working-age adults through a GLBI would establish a consistent income floor, ensuring individuals and families can meet basic needs regardless of employment status.

According to the Parliamentary Budget Officer, a national GLBI would reduce poverty by up to 34% for nuclear families and 40% for economic families, based on the Market Basket Measure (11). The National Advisory Council on Poverty has also highlighted the potential of a targeted basic income to ensure all individuals reach at least Canada’s Official Poverty Line (12).

Given the scale of household food insecurity and its significant health and economic impacts, Canada requires coordinated, income-based policy solutions. Advancing a GLBI would directly address the root causes of poverty, strengthen financial resilience, reduce inequalities, and improve health and social outcomes across the population.

[1] City of Mississauga; City of Toronto; City of Kingston; City of Brantford; Town of Smiths Falls;  City of Brockville; Town of Cochrane; City of Orillia 

Recommendation:

To strengthen Goal 1.3, ODPH recommends the following:

Include a new implementation strategy to advance a national guaranteed livable basic income. For example: Implementation strategy 1.3.1.5: Develop and implement a national framework for a guaranteed livable basic income, such as that proposed in Bill S-206 (13), to ensure all individuals can meet basic needs, reduce poverty, and improve health and social outcomes.

Goal 2.2 Strengthen the resilience and sustainability of Canadian agriculture

ODPH works to advance food systems that are healthy, just, and sustainable. In this capacity, we express our support for Goal 2.2, which aligns with public health objectives to support healthy eating. We also recommend strengthening the Strategy through a more explicit focus on protecting Canada’s prime agricultural lands as a foundational element of a resilient and sustainable food system.

Agricultural Land Loss 

The loss of prime agricultural land poses a significant and growing threat to Canada’s long-term food security and sustainability. Prime agricultural lands comprised of the highest capability soils, are a non-renewable, finite resource essential to the existence of a healthy, sustainable food system. Class 1, 2 and 3 are considered prime agricultural soils that have the highest capacity for agricultural production.

Only 5.4% of Canada’s land base is free of severe constraints for agricultural production with the largest share located in Ontario (14). Loss of farmland is a growing concern.  In Ontario alone, more than 319 acres of farmland were lost per day between 2016 and 2021 (15).  Once developed, these lands are effectively lost forever. Protecting them is critical not only for food production but also for the long-term health of our economy, communities, and ecosystems.

The conversion and fragmentation of prime agricultural lands disrupt the peri-urban agricultural base that supplies regional food markets and reduces local food self-reliance. In the context of rising inflation, supply-chain disruptions, and global trade instability, protecting farmland is critical to strengthening Canada’s food system, supporting domestic food production and maintaining economic resilience.

Land use planning decisions directly influence access to nutritious, affordable, and locally produced food. As such, protecting agricultural land is not only an environmental or economic priority—it is a public health imperative. Sustainable land use planning is essential to advancing community food security and enabling healthier populations.

Without explicit federal recognition and measurement of agricultural land loss, Goal 2.2 cannot fully deliver on its aim to strengthen the resilience and sustainability of Canadian agriculture.

Food Sovereignty

Recent global disruptions have underscored the importance of food sovereignty and the risks associated with over-reliance on imported food and complex global supply chains. Food supply chain weaknesses and heavy reliance on imports and processing capacity render Canadian communities vulnerable.

Canada currently imports approximately 30% of all food and beverages, including 80% of fruit and 60% of vegetables. This reliance increases vulnerability to external shocks and limits national and regional resilience (16).

Canada depends on foreign ports, global shipping routes, intercontinental trucking networks, and just-in-time distribution models to feed its residents, which assumes uninterrupted energy, transportation, and communications infrastructure (17). To strengthen resilience, Canada’s Sustainable Development Strategy must go beyond domestic production and export growth by leveraging existing community infrastructure and capacity and investing in agri-food resources that improve access to affordable, nutritious food while supporting economic stability for agricultural producers.

Achieving food sovereignty requires a strong policy foundation that protects the essential resource underpinning the food system: agricultural land. Without safeguarding prime agricultural lands, efforts to build resilience, sustainability, and self-reliance will be fundamentally constrained.

Addressing the interconnected challenges of climate change, community food security, and population health requires integrated, cross-sectoral approaches that consider environmental, economic, and social factors. Collaboration across all orders of government—federal, provincial, territorial, municipal—and with Indigenous partners is essential to ensuring that agricultural viability, community well-being, and long-term sustainability remain central to policy development.

Recommendations: 

To strengthen Goal 2.2 and support a resilient, sustainable, and equitable food system, ODPH recommends the following:

• Explicitly recognize the protection of prime agricultural lands as a core component of agricultural sustainability and community food security within Goal 2.2.
• Support policies and investments that enable diversified production of nutritious foods, while strengthening local and regional food supply chains to improve access to healthy food and enhance farm viability.
• Introduce a measurable target (e.g., Target 2.2.2) to track and report on the annual percentage of agricultural land loss across Canada.
• Include a corresponding implementation strategy to support action on this target. For example, Implementation strategy 2.2.2.1: Support the protection of prime agricultural lands by collaborating with provinces, territories, municipalities, and Indigenous partners to strengthen land use planning policies, and establish consistent national monitoring and reporting on farmland conversion, including the loss of high-capability agricultural soils.

Just and sustainable food systems begin with secure access to land. Protecting Canada’s prime agricultural lands is essential to ensuring long-term access to fresh, nutritious, and affordable food. Embedding strong farmland protection measures within the Federal Sustainable Development Strategy will advance food system resilience, support food sovereignty, and promote the health and well-being of Canadians.

We respectfully request that this submission be considered as part of the official consultation process. 

Thank you for your consideration. 

Sincerely, 

Luisa Magalhaes, RD, MHSc                       

Chair, Ontario Dietitians in Public Health  

Cc. 
Ontario Federation of Agriculture (OFA), Drew Spoelstra, OFA President, drew.spoelstra@ofa.on.ca 

National Farmers Union of Ontario (NFU), Max Hansgen, NFU-O President, president@nfuontario.ca 
Ontario Farmland Trust, Martin Straathof, Executive Director, info@ontariofarmlandtrust.ca 

References: 

1. Ontario Dietitians in Public Health (ODPH). Position Statement and Recommendations on Responses to Food Insecurity. (2020). Available at: https://odph.ca/section/food-insecurity/
2. Food Insecurity Policy Research (PROOF). Understanding Household Food Insecurity [webpage online]. Available at: https://proof.utoronto.ca/food-insecurity/
3. Food Insecurity Policy Research (PROOF). (2025) New Data on Household Food Insecurity in 2025. Available at: https://proof.utoronto.ca/2026/new-data-on-household-food-insecurity-in-2025/
4. Food Banks Canada. (2025). Hunger Count 2025. Available at: https://content.foodbankscanada.ca/wordpress/2025/10/FBC_HungerCount_EN_2025.pdf
5. Martin JC and Lewchuk W. (2018). The Generation Effect: Millennials, employment precarity and the 21st Century workplace. Available at: https://pepso.ca/documents/the-generation-effect-full-report.pdf
6. Food Insecurity Policy Research (PROOF). (2023). What are the implications of food insecurity for health and health care? Available at: https://proof.utoronto.ca/food-insecurity/what-are-theimplications-of-food-insecurity-for-health-and-health-care/
7. Tarasuk V. (2017). Implications of a basic income guarantee for household food insecurity. Northern Policy Institute – Research Paper No. 24. Available at: https://proof.utoronto.ca/wpcontent/uploads/2017/06/Paper-Tarasuk-BIG-EN-17.06.13-1712.pdf
8. Li T, Fafard St-Germain AA, Tarasuk V. (2023). Household food insecurity in Canada, 2022. Toronto: Research to identify policy options to reduce food insecurity (PROOF). Available at https://proof.utoronto.ca/
9. Food Insecurity Policy Research (PROOF). What can be done to reduce food insecurity in Canada? Available at: https://proof.utoronto.ca/food-insecurity/what-can-be-done-to-reduce-food-insecurity-incanada/
10. McIntrye L, Dutton D, Kwok C et al. (2016). Reduction of food insecurity in low-income Canadian seniors as a likely impact of a Guaranteed Annual Income. Canadian Public Policy. 42(3), 274-286. Available at: https://utppublishing.com/doi/10.3138/cpp.2015-069
11. Office of the Parliamentary Budget Officer. (2025). A Distributional Analysis of a National Guaranteed Basic Income – Update. Available at: https://www.pbo-dpb.ca/en/publications/RP-2425-029-S–distributional-analysis-national-guaranteed-basic-income-update–analyse-distributive-unrevenu-base-garanti-echelle-nationale-mise-jour
12. Government of Canada. (2025). 2025 Report of the National Advisory Council on Poverty. Available at: https://www.canada.ca/en/employment-social-development/programs/poverty-reduction/nationaladvisory-council/reports/2025-annual.html
13. Parliament of Canada. Bill S-206 (45-1): An Act to develop a national framework for a guaranteed livable basic income [Internet]. Ottawa, ON: Parliament of Canada; 2025 May 26. Available from: www.parl.ca/LegisInfo/en/bill/45-1/S-206
14. Ontario Farmland Trust. (March 19, 2026). Farmland Forum: Municipalities and Farmland Protection. Webinar.
15. Statistics Canada. (2022). Table 32-10-0156-01: Farms classified by total farm area, Census of Agriculture historical data. Available at: Farms classified by total farm area, Census of Agriculture historical data
16. University of British Columbia. Resource, Environment and Sustainability (IRES) and School of Public Policy and Global Affairs (SPPGA). Available at: The Story of Canada’s Fruit and Vegetable Supply
17. The Functionary. Kathryn May. (2026) Available at: Community food systems are critical to Canada’s national security