ERO 026-0310 – Proposal to reform site plan control under the Planning Act and the City of Toronto Act, 2006

 May 14, 2026

Hon. Rob Flack

17th Floor

777 Bay Street

Toronto, Ontario, M7A 2J3

Re: ERO 026-0310 – Proposal to reform site plan control under the Planning Act and the City of Toronto Act, 2006

Dear Minister Flack,

The National Farmers Union-Ontario (NFU-O) is an accredited farm organization representing sustainable farmers in Ontario and has advocated for farmers across Ontario since 1969. Members work together to achieve agricultural policies that ensure dignity and income security for farmers, while protecting and enhancing rural environments for current and future generations.

While the NFU-O recognizes the need for development to accommodate population growth, we reaffirm our advocacy for holistic development solutions that protect Ontario’s prime agricultural land and the conservation activities on these lands, stewarded by farmers, Indigenous communities, and local conservationists. We believe that responsible land use planning does not come from a top-down, development-led approach, but by ensuring municipalities have access to the right tools to manage growth sustainably. 

NFU-O is opposed to removing or further weakening site plan control as a municipal land use planning tool under the Planning Act and the City of Toronto Act, 2006. Site plan control is an essential tool initiated at the municipal level to exercise site-specific controls over development. It enables municipalities to ensure recommendations from Agricultural Impact Assessments (AIAs) are adequately integrated into land use planning. While AIAs identify high-level impacts, site plan control is the legal, site-specific mechanism that enforces design solutions like buffers, fencing, and drainage to protect farm operations and manage land-use conflicts. Site plan control provides a land use planning mechanism to protect prime agricultural land, and support farm businesses in functioning efficiently. Removing or limiting site plan control to functional aspects pertaining only to health and safety would weaken local decision-making autonomy, and would systematically diminish protections for agriculture, environment, and rural communities. 

Additionally, the NFU-O is opposed to legislation that erodes protective planning mechanisms for farmland and natural heritage lands, and that diminishes local, democratic decision-making. As the ERO post mentions, Bill 23, More Homes Built Faster Act, 2022 and Bill 109, Protecting Ontario’s Food Independence Act, 2026 already limit what municipalities can apply a site plan control to for residential developments, and remove decision making power from municipal councils or committees. The culmination of these pieces of legislation threaten to completely overhaul municipal decision-making autonomy and expertise for fast-tracked, short sighted development schemes, compromising long-term public wellbeing.

NFU-O continues to call on the government to advance responsible density and affordable development within existing urban boundaries, instead of diminishing critical municipal land use planning tools to push for quicker urban sprawl, compromising our ability to provide healthy, local food for future generations. We reiterate our position that development must not come at the expense of Ontario’s finite prime agricultural land. Class 1 soil takes thousands of years to form and is the highest quality of agricultural land, having no significant limitations for crop production. Shifting to a top-down, development-led land use planning approach is detrimental to democratic accountability, ecological resilience, food-producing capacity, and the chance to develop responsibly. 

Sincerely, 

Josh Suppan
President, National Farmers Union – Ontario
Region 3 Coordinator, National Farmer Union
(705)738-3993 ext 2