November 20, 2025
Ontario Ministry of Municipal Affairs and Housing
Via email: PlanningConsultation@ontario.ca
Subject: Submission on Bill 60 – Fighting Delays, Building Faster Act, 2025 (ERO 025-1097)
Dear Minister Rob Flack and Members of the Ministry of Municipal Affairs and Housing,
Please accept this submission in response to ERO 025‑1097: Proposed Changes to the Planning Act (Schedule 10 of Bill 60 – the Fighting Delays, Building Faster Act, 2025), on behalf of Ontario Dietitians in Public Health (ODPH). ODPH is the official voice of Registered Dietitians working in Ontario’s public health system. As public health professionals guided by evidence and committed to equity and the upstream determinants of health, we work to advance food systems that are healthy, just, and sustainable.
In this capacity, we are writing to express serious concern about Bill 60’s unintended consequences for farmland protection, local food production, and equitable access to nutritious food. While we support the government’s goal of increasing housing supply, several provisions risk undermining Ontario’s long term food system resilience by weakening agricultural land protections, reducing local food production capacity, and limiting our ability to adapt to climate change and sustain strong rural economies.
Agricultural Land Loss
Bill 60 proposes new regulatory powers that make land-use designations more permissive and allow “as-of-right” deviations from zoning standards. Without strong safeguards, these streamlined approvals could accelerate the conversion and fragmentation of prime agricultural lands (e.g., Canada Land Inventory Classes 1–3), disrupt the peri-urban agricultural base that supplies regional food markets, and reduce local food self-reliance.
Loss of farmland is a growing concern. Between 2016 and 2021, Ontario lost over 319 acres of farmland per day (Statistics Canada Census of Agriculture). These losses are typically permanent, and pressure is highest in the Greater Golden Horseshoe and surrounding peri-urban corridors, where much of Ontario’s food-system infrastructure is concentrated.
Robust agricultural land protections within the Planning Act must exclude prime agricultural areas and specialty crop regions from new regulatory flexibilities to prevent further encroachment.
Weakened Alignment with Provincial Policy
Bill 60’s proposed standardization of Official Plans and expanded of permissive land-use designations threaten local food system planning. While a distinct Agricultural Areas designation could support farmland protection and on-farm diversified uses, broader mixed-use and rural designations risk fragmenting agricultural lands and weakening local food system resilience.
The Bill allows “as-of-right” zoning deviations (i.e., building height and lot coverage) with reduced municipal oversight and empowers the Minister to make or approve Planning Act decisions outside the Greenbelt without Provincial Policy Statement (PPS) compliance. This undermines PPS 2024, which requires designation and protection of prime agricultural areas, including specialty crop lands, with permitted uses limited to agricultural, agriculture-related, and on-farm diversified activities.
By weakening consistency requirements with the PPS, Bill 60 risks eroding agricultural protections and limits municipalities’ ability to integrate food system goals (e.g., urban agriculture, equitable access to food retail, and support for local food production) into planning frameworks.
Policy Recommendations
To ensure that efforts to accelerate housing delivery do not compromise Ontario’s ability to produce food, sustain rural economies, and build resilient communities, ODPH offers the following six policy recommendations to strengthen Bill 60:
1.Uphold Indigenous rights and ensure free, prior, and informed consent
Require that all decisions enabled under Bill 60 respect the Crown’s duty to consult and adhere to the principles of the federal UN Declaration on the Rights of Indigenous Peoples Act, which requires making Canadian laws consistent with UNDRIP, especially regarding free, prior, and informed consent (FPIC) for projects on their lands. Development on Indigenous lands without free, prior, and informed consent (FPIC) undermines these obligations and risks further eroding trust, land stewardship, and reconciliation efforts.
2. Strengthen agricultural land protection
Require all land-use decisions under Bill 60 to comply with the Provincial Policy Statement, 2024 (PPS 2024), especially policies protecting prime agricultural areas and specialty crop lands. Reinstate or clarify ministerial oversight for development applications affecting these lands and mandate Agricultural Impact Assessments (AIAs) for any proposal that affects agricultural land or farm clusters.
3. Direct infrastructure growth to appropriate areas
Link expedited approvals and servicing incentives to designated settlement areas, brownfields, and industrial or employment lands, avoiding active farmland. Prioritize infrastructure investments that support agri-food processing, distribution hubs, and local food logistics within existing industrial zones to strengthen the food system without compromising farmland.
4. Support municipal agricultural land preservation tools
Adopt or expand agricultural system mapping, urban growth boundaries, and farmland trusts at the municipal level. Provide guidance and funding for programs such as Agricultural Land Reserve-style models or municipal farmland banks to prevent farmland loss and maintain long-term agricultural productivity.
5. Ensure equitable water and wastewater policy for farms
Apply consistent environmental and cost-recovery standards for on-farm wastewater systems to avoid unfairly burdening small and medium-sized farms. Consult agricultural stakeholders before restructuring local water or wastewater governance that could affect farm operations.
6. Embed food-system resilience in provincial planning frameworks
Integrate food production, processing, and access infrastructure into provincial and municipal planning under PPS 2024’s goal of building complete, sustainable communities. Track and publicly report farmland conversion rates and agri-food sector employment impacts and monitor as-of-right variance applications affecting agricultural lands to ensure transparency and protect critical farmland.
Just and sustainable food systems start with secure access to land. Protecting Ontario’s farmland is essential to ensuring access to fresh, nutritious, and affordable food. ODPH urges the Ontario government to balance housing and growth objectives with the long-term protection of Ontario’s food system. Embedding food-system resilience within Bill 60’s framework supports both the health of Ontarians and the sustainability of the food systems that sustain them.
We request that this submission be considered as part of the official consultation and made publicly available through the ERO posting.
Thank you for considering our comments.
Sincerely,
Luisa Magalhaes, RD, MHSc Sharmini Balakrishnan, MPH, RD
Chair, Ontario Dietitians in Public Health Co-Chair, ODPH Food Systems Workgroup
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
Greenbelt Foundation, Namgyal Dolker, Office of the CEO, ndolker@greenbelt.ca
Marit Styles, Leader of the Official Opposition, mstiles-qp@ndp.on.ca
John Fraser, Leader Third Party, jfraser.mpp.co@liberal.ola.org
Leader of the Ontario Green Party, Guelph MPP Mike Schreiner, mschreiner-co@ola.org
Canadian Public Health Association, Dolores Gutierrez, Communications & Marketing Officer, communications@cpha.ca
References:
Ministry of Municipal Affairs and Housing. (2024). Provincial Planning Statement, 2024 (Under the Planning Act). King’s Printer for Ontario.
Ontario Dietitians in Public Health. (2024). Rapid Review: Municipal Land Use Planning Policies that Promote Equitable and Sustainable Food Systems. Ontario: Ontario Dietitians in Public Health
Ontario Federation of Agriculture. (2024) Agriculture Matters: A guide for municipal councillors and staff.
Statistics Canada. (2022) Table 32-10-0156-01: Farms classified by total farm area, Census of Agriculture historical data.
