ERO 026-0383 – Addressing Growth and Housing Needs in South Simcoe

May 8, 2026

Hon. Rob Flack

17th Floor

777 Bay Street

Toronto, Ontario, M7A 2J3

Re: ERO 026-0383 – Addressing Growth and Housing Needs in South Simcoe

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.

The NFU-O is deeply concerned about the development plans outlined in ERO 026-0383 – Addressing Growth and Housing Needs in South Simcoe, and the trend of overhauling local plans to expand urban boundaries onto prime agricultural land for fast-tracked, short sighted development schemes. The plans for South Simcoe deviate from best practice planning methodologies, and threaten foundations of public wellbeing like local decision-making, responsible housing development, prime agricultural land protection, and environmental protection.

Densification & Protecting Prime Agricultural Lands

While the NFU-O recognizes the need for housing accommodations for population growth by 2051, we reaffirm our advocacy for sustainable, affordable housing that protects Ontario’s prime agricultural land and the conservation activities on these lands, stewarded by farmers, Indigenous communities, and local conservationists. Class 1 soil takes thousands of years to form and is the highest quality of agricultural land, having no significant limitations for crop production. It would be unthinkable in economic and public interest terms for other essential non-renewable resources to be paved over in this short-sighted manner. By choosing to develop prime agricultural land instead of realizing complete communities in existing built-up areas, the province is failing to account for long-term best practice land use planning, and generating short-term economic benefits that do not reflect the holistic needs of Ontarians. 

Overriding Local Decision Making

NFU-O is opposed to the top-down, development-led approach in South Simcoe and other municipalities targeted in supportive legislation, like Bill 100, Better Regional Governance Act, 2026. In this legislation, it is clear that the government is providing a legal mechanism to influence local decision making by allowing the Minister to appoint or remove municipal heads of council to push through provincial plans and priorities. By overriding municipal official plans in South Simcoe and expanding urban boundaries further than designed by local experts and governments, the province is prioritizing short-term economic gain over long-term public  wellbeing. This strategy has a proven track record of failure, forcing municipalities to rapidly plan for expanded infrastructure and services, with costs passed down to residents instead of developers. For example, in Pickering, the consequences of this approach are already visible as parts of the Seaton community lack schools, adequate waste services, roads, sidewalks, and other essential infrastructure. 

Conclusion

We call on the government to halt current plans to pursue selected development sites in South Simcoe, and advance responsible density and affordable housing construction within existing urban boundaries, instead of paving over finite prime farmland that is essential to our collective wellbeing. By overriding municipal plans and targets, and selecting project development sites on prime agricultural land instead of investing in densification within existing urban boundaries, Ontarians lose more than soil. We lose democratic accountability, ecological resilience, food-producing capacity, and the chance to build housing responsibly. 

Sincerely, 

Josh Suppan
President, National Farmers Union – Ontario
josh@nfuontario.ca
(705)738-3993 ext 2