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April 30, 2014
Hon. Christy Clark, Premier
PO Box 9041
Stn Prov Govt
Victoria, BC V8W 9E1
Dear Premier Clark:
Re: BILL 24, the AGRICULTURAL LAND COMMISSION AMENDMENT ACT, 2014
The National Farmers Union (NFU) is deeply concerned about the changes to the Agricultural Land Commission Act that your government is proposing through BILL 24, the AGRICULTURAL LAND COMMISSION AMENDMENT ACT, 2014. We have prepared the following brief which we urge you to consider before taking any further steps to change BC’s farmland protection legislation.
The NFU represents thousands of farm members in Canada, from coast to coast. NFU members believe that the problems facing farmers are common problems, and that farmers producing diverse products must work together to advance effective solutions. The NFU works toward the development of economic and social policies that will maintain the family farm as the primary food-producing unit in Canada.
The NFU is a founding member of La Via Campesina, the world-wide small farmer and peasant movement established in 1993. Food sovereignty, a term coined by members of La Via Campesina in 1996, asserts the right of people to define their own food systems. As advocates of food sovereignty we seek to put the individuals who produce, distribute and consume food at the center of decisions on food systems and policies, rather than the corporations and market institutions that have come to dominate the global food system.
As British Columbia’s, Canada’s and the world’s population grows and becomes increasingly urbanized, protecting farmland is more important than ever. Small and medium-sized farms are more efficient than large industrialized farms in terms of food produced per acre, and still grow and raise well over half of the world’s food. In BC 98% of farms are family farms. Thanks to the ALR, BC has maintained a fairly steady number of farms and nearly three-quarters of BC’s farms are less than130 acres. Canada, by contrast, has lost about one-third of its farms since BC’s ALR was implemented.
BC has great diversity in its agricultural land – including the unique vegetable and fruit-growing land in the Okanagan, Kootenay and Similkameen valleys, the rangelands of the Chilcotin, the grain farms of the Peace River, the dairies and year-round vegetable production of Vancouver Island, the small mixed farms that provide food in more isolated areas such as Powell River and Bella Coola and the specialized livestock production and intensive market gardens of the lower mainland. BC has a rich heritage of farming and a vibrant culture of agriculture. Many young people in BC aspire to make farming their life’s work and if there is accessible, affordable land, they will grow healthy, nutritious food to feed BC’s — and Canada’s — future residents. All of these values and aspirations depend on ensuring that the continuing existence of BC’s farmland is a top priority.
The NFU opposes the amendments to the Agriculture Land Commission being proposed in Bill 24. We would like to provide you with our input on this important matter. We urge you to abandon Bill 24 and instead strengthen farmland protection in BC and also strengthen protection for farmers so that they can afford access to farmland in BC.
At the most recent NFU National Convention held in November 2013, the following resolution was passed:
BRITISH COLUMBIA AGRICULTURAL LAND RESERVE (ALR)
WHEREASthe Agricultural Land Reserve (ALR) was set up to protect viable farm land in BC, and
WHEREAS the current provincial government has initiated a process to dismantle or weaken the ALR and allow agricultural land to be further developed and mined,
THEREFORE BE IT RESOLVEDthat the NFU publicly acknowledge the Agricultural Land Reserve (ALR) is a model that should be replicated across Canada and maintained and strengthened in BC.
Bill 24 would change the BC Agricultural Land Commission Act by:
- Establishing and defining six geographic areas called “Panel Regions” – Interior, Island, Kootenay, North, Okanagan, and South Coast.
- Establishing six Panels and defining their form – Each panel would have at least two members including the Vice Chair from the Panel Region plus all other members of the Commission who reside in the Panel Region. These few people would have full authority to make final decisions in their own Panel Region.
- Establishing Zones. Zone 1 would include the Island, Okanagan, and South Coast Panel Regions. Zone 2 would be the Interior, Kootenay, and North Panel Regions.
- Adding “economic, cultural and social values; regional and community planning objectives; and other prescribed considerations” as factors that must be considered when making decisions regarding lands in Zone 2. These new considerations may well conflict with the existing purposes of the Commission which are “to preserve agricultural land; to encourage farming on agricultural land in collaboration with other communities of interest; and to encourage local governments, first nations, the government and its agents to enable and accommodate farm use of agricultural land and uses compatible with agriculture in their plans, bylaws and policies.”
- Authorizing the Lieutenant Governor in Council (Cabinet) to make new regulations that add other factors that Panels must consider when making decisions regarding lands in Zone 2.
The NFU would also draw attention to the undemocratic manner in which this Bill has been brought forward. The ALR is a long-standing institution in BC, one that helps define the province’s character as well as its land use and economy. Any change to such an important element calls out for a comprehensive and inclusive public process. Farmers should be at the forefront of any discussion about the future of farmland since without land, it is not possible to farm. Yet there have been no public consultations – BC farmers and other BC residents have not had a proper opportunity to be involved in a full public debate on this matter of vital interest.
The NFU opposes the creation of Zones and the permanent Panel structure. All farmland in BC is important and needs to be protected, regardless of location or the type of development pressure placed upon it. The ALR was set up as an institution for the benefit of the whole province, and thus the overall farmland protection values need to be reflected in decision-making regardless of location. By delegating the Agricultural Land Commission’s full jurisdiction to the small regional panels (as few as two individuals) who reside within the region, there is clear danger that local development pressures could influence the panel members and that the overall vision of the Commission would be diluted and/or fragmented over time. Local interests need to be balanced by broader interests and there is a high risk of losing that balance when the full power of the Commission can be exercised by so few people.
Furthermore, the NFU is concerned that all criteria to be considered when decisions are made in Zone 2 are not being revealed in the proposed legislation. Bill 24 would empower the government to add new criteria simply by passing new regulations, a process that occurs without public debate in the Legislature. Thus these new criteria would be adopted through a process that lacks transparency.
When the ALR was established over four decades ago, it was understood to represent a long-term vision of BC as a place that takes care of its land and people by protecting the province’s limited and valuable farmland from urban and industrial encroachment. BC was visionary in this regard, and the ALR has enabled BC to retain and even increase its farmland area, while Canada as a whole has seen a net decrease, as illustrated in the graphs below. (see PDF)
In 1973 little was known or understood about global climate change, but today we are seeing its impacts in the form of erratic weather patterns and crises such as the severe drought that is currently affecting California’s agricultural production. The pressures on farmland from urban developers and resource extraction industries in BC have only increased since the ALR was established. The effects of climate change locally and globally make it all the more imperative that existing farmland in all regions of BC be maintained, nurtured and enhanced.
Development during the last century has drastically increased world population and related food production and trade in food. In many cases, intensified and specialized agriculture methods along with economies of larger scale have been promoted to increase food supplies. The common thread in this approach has been a steady increase in the use of fertilizers, labour saving mechanization, processing, transportation and distribution of food, all with increased reliance on fossil fuels.
These technological advancements have their dark side as well – agriculture is one of the largest emitters of the greenhouse gases that drive climate change. People in BC, across Canada and around the world recognize the need to build more resilience into our farming practices, rely less on fossil fuels and to provide more food within our local areas. BC residents recognize this need, and according to a 2008 Ipsos Reid Poll, 91% want to increase local food production and reduce dependence on imports.
It is thus ironic, or perhaps simply tragic, that the proposed changes to the ALR not only would make it easier to remove farmland from the Reserve, but would do so apparently to make way for increased oil, gas, fracking, mining and other extractive industrial activities that would make our climate even less hospitable for food production.
The proposed change in structure of the ALR under Bill 24 shows that the farmland that would lose its current level of protection is located in precisely the areas of BC that have potential for oil, gas and coal development, as illustrated by the two maps below. It has been said that “structure is strategy in slow motion”. Thus, the proposed amendments suggest BC is poised to adopt a strategy based on advancing the petrochemical industry at the expense of BC’s farmers, the food they produce and the people who eat it. (See PDF for maps)
BC has become more dependent on imported food as a result of policies based on economic globalization. The theory — that we will all be better off if rather than producing all we need, we specialize in making what we are good at and trade for what we don’t produce – does not stand up to reality. In fact, Canadian farmers have lost more than they have gained through export-oriented agriculture policy, with farm debt increasing faster than ever. (see PDF for graph)
Canadian consumers have become much more dependent on imported food that may rapidly become more expensive, or even unavailable, due to erratic weather events, transportation problems or political upheaval elsewhere. The more our food and agriculture economy operates within our own borders the less vulnerable farmers and consumers are to uncontrollable outside forces, and the more stable our own economy will be. People need to eat every day. In this ever-more uncertain world, maintaining the ability to produce our own food is increasingly important. To do that, we need to protect our farmland.
If Bill 24 passes, it is farmers who will be most severely affected. Good farmland will be taken out of production. Some will be removed from the ALR altogether, and other land will become more difficult or impossible to farm due to conflicting uses on neighbouring land. The remaining farmland will become more expensive to purchase or rent, reducing or even eliminating access to land for younger farmers. Those who start or continue farming under these circumstances will have to take on larger debts, making it harder to survive as a farmer, reducing the amount of income available for investment in working capital or for spending in the local economy.
Where conflicting uses exist on neighbouring land – such as industrial development or suburban development – crop rotations or livestock herds often must be adjusted, crop yield and animal health may be compromised, product prices may be discounted or more complicated farming methods required. These all add costs and could result in the farm becoming non-viable, exacerbating BC’s vulnerability to food security problems due to the loss of farmland. Farm families that are forced to deal with new, difficult and expensive problems may find that their children are less interested in taking over the farm in the future, resulting in the loss of all the knowledge and skills they would have contributed as the next generation of family farmers.
The combination of the extended farm income crisis, loss of farmer-run marketing institutions, and increasing debt loads puts farmers at a disadvantage when seeking access to land in the marketplace. This is a trend that exists not only in BC, but across Canada and in other countries as well. The pressures on farmland in BC are intensified by the province’s geography. Without legislated protection, large areas of rural BC risk becoming either a scenic playground for the wealthy or a sacrifice zone for the benefit of (largely foreign-owned) resource extraction industries.
BC can pursue a much better vision. Properly protecting farmland will create policy space that also supports biodiversity, sustainable food production, economically viable farms and vibrant rural communities. BC can become a leader in Canada by ensuring that young people who want to farm and ranch can afford the land they need, and by implementing support mechanisms to ensure these young farmers can succeed. Food sovereignty can become a reality for BC residents if the Province recognizes that farmland is the foundation of its future prosperity. We will still need to eat every day, even after the oil and gas money runs out.
Respectfully submitted by,
[orginal signed by]
Jan Slomp, PresidentNational Farmers Union
c.c. Hon. Norm Letnick, Minister of Agriculture
c.c. Hon. Mary Polak, Minister of Environment
c.c. Hon. Steve Thomson, Minister of Forests, Lands and Natural Resource Operations
c.c. Hon. Bill Bennett, Minister of Energy and Mines