Region 8 | Letters

NFU BC Submission to the Agricultural Land Reserve Processing Changes

 
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Undermining the 50 percent rule threatens Food Sovereignty in British Columbia

Dear Minister Popham,

The National Farmers Union (NFU) is a voluntary, direct membership organization of farmers and farmworkers working together democratically to represent the interests of Canadian farmers and advocate for policies that strengthen food sovereignty.1 The NFU is home to significant expertise in agricultural policy, and is respected for conducting in-depth research and producing reports on agricultural issues that are free from corporate influence.2 British Columbia NFU members are grateful for the opportunity to bring the NFU voice into this important discussion about agricultural land in BC.

We hope that this consultation regarding the proposed changes to the “50 percent rule” for food processing inside the Agricultural Land Reserve will mark the beginning of a long-overdue public dialogue about the relationships between land governance and food systems. The financialization of farmland poses a significant threat to the future of food production in BC. The NFU is a leading expert on this topic nationally, and we formally request that NFU BC be included in any future round table, advisory committee, task force, or review of agricultural land policy in British Columbia.

At the NFU, food sovereignty is the lens through which we evaluate any new policy proposal. We have carefully read the Ministry of Agriculture and Food’s Discussion Paper on encouraging food processing inside the Agricultural Land Reserve and considered how the proposed changes might impact the capacity for food sovereignty in British Columbia. We fear that if the proposal is implemented, it will undermine local agriculture and hand land, markets, and power over to international companies which have no stake in our local economies, environment, or community well-being. We strongly oppose this proposal on the basis that it undermines food sovereignty in British Columbia.

Understanding Food Sovereignty

The NFU is a founding member of La Via Campesina, the international coalition of food producers that developed the concept of food sovereignty and introduced it at the World Food Summit held by the Food and Agriculture Organization of the United Nations in 1996. The principle of food sovereignty was introduced to international policy spaces to complement the objective of food security. Food Sovereignty is essential because it expresses those aspects of food systems which are consistently overlooked by a paradigm that focuses primarily on the volume and “efficiency” of food production.3

“Food Sovereignty is the right of peoples to healthy and culturally appropriate food produced through ecologically sound and sustainable methods, and their right to define their own food an agriculture systems. It puts the aspirations and needs of those who produce, distribute and consume food at the heart of the food system rather than the demands of markets and corporations. It defends the interests and inclusion of the next generation.”

The Nyéléni Declaration

Throughout the 1980s and ’90s, trade liberalization pushed farmers around the world into poverty and destroyed their local capacity to feed themselves.4 On every continent, place-based agrarian communities have been dispossessed of their ancestral territories, seeds, and food cultures, and reshaped into commodity-exporting regions to support highly financialized global food chains in the name of feeding the world and making food cheap. This narrow understanding of food security, achieved through higher yields and more efficiency, has provided cover for major international corporations to consolidate markets and power while extracting wealth from food producers and consumers, transgressing multiple planetary boundaries, and exposing agricultural workers – and all of us – to sickness causing chemicals.

To acknowledge this reality does not mean that the NFU is naive about the need for industrial-scale food production. Nor does it mean we shun so-called conventional farmers who use tools or inputs sold by these major firms to stay afloat within the “get big or get out” paradigm. Our membership includes these farmers, alongside many organic, small and medium scale, diversified, and/or new-entrant farmers and farm workers, and our understanding of systemic problems in agriculture is strengthened by our diversity. Food production is highly skilled, knowledge- and infrastructure-intensive work. We need every farmer that we’ve still got, with all of their different knowledge and skill sets, and we need them to be in a position where they are able to make their own decisions and work together with their communities to address shared problems without corporate interests dictating what is possible. Food security looks at whether food is available. Food sovereignty insists that governments and policies must ensure the objective conditions required for people to be able to feed themselves.5

Food Security and Sovereignty in BC

The discussion paper states that the proposed changes will strengthen food security in BC, and implies that they will strengthen “our ability to stand on our own two feet”. We are in agreement with the Agricultural Land Commission, in that we are “not satisfied that the discussion paper demonstrates how allowing industrial development opportunities on ALR land with such limited reliance on B.C. agricultural products would materially increase agricultural production, strengthen farm viability, or improve food security within the province of BC.”6

The backgrounder provided to inform the consideration of this new policy proposal lists the revenues generated by food processing and farming in BC, as well as the value of processed food and beverage exports for 2024. It does not lay out the status of food security in BC: what portion of their income British Columbians are spending on food, how access to different types of food differs regionally, to what extent budget considerations are shaping diets and health, or what portion of our nutritional requirements we can meet with current food production levels in BC. It also does not detail who is benefiting from the current food system or who would be left out if the new rule went into effect. Achieving food sovereignty means putting people’s needs before export revenue or gross domestic product (GDP). The more that market forces, rather than human needs and contextual realities, are allowed to shape food and agriculture policies, the further away food sovereignty becomes.

We believe these proposed changes would further erode the necessary conditions for British Columbians to be able to feed themselves and their communities. The changes would limit our ability to conduct trade on our own terms, in ways that make sense for our local economies and landscapes. They would increase our economy’s dependence on importing and exporting food and reduce the market power of farmers and small-medium businesses in BC. They would further open BC up to the power of the global financialized food system, including greater consolidation, debt, price pressures, worker exploitation, and environmental harms.

“A new geopolitics of food is reshaping global food security. Trade wars, conflicts, climate change, aid cuts, and political tensions are fuelling price volatility, worsening hunger, and strengthening corporate control. This turmoil is exposing just how fragile food systems built on global dependence and just-in-time supply chains have become.”

The International Panel Of Experts on Sustainable Food Systems

The new form of US imperialism demands localization, not handouts to global corporations

The proposal is right to point out that the trade context is changing. If we don’t change our approach, BC residents will pay higher and higher prices for food while supply chains become less reliable. However, we question the proposal’s logic of responding to new conditions by doubling down on strategies from the old paradigm. The proposed changes would make our food system more beholden to foreign actors and more vulnerable to external shocks, not less. The new 5 percent rule would create new opportunities for highly capitalized, large-scale businesses from outside of BC to throw pennies at our local farmers while importing the remaining 95 percent of ingredients. The profits generated will probably not stay in BC, unless invested in land grabbing, and certainly won’t be spread around to the working people of our province. While it may increase GDP, it will not strengthen rural economies, advance sustainability, or achieve food security or sovereignty.

The International Panel of Experts on Sustainable Food Systems (IPES Food) argues that the ‘new geopolitics of food”, characterized by increasing uncertainty around trade, climate, and migration, demands that all countries and regions shift toward food and agriculture policies that cultivate “resilient self-reliance: strengthening domestic and regional food systems, reducing dependence on volatile global markets, and investing in agroecology, public food infrastructure, and fair, cooperative trade.”7

As much of BC’s farmland exists in narrow valley bottoms and is divided into relatively small parcels, the volume and uniformity of primary products required for industrial-scale food processing will be difficult to source in BC. It is unlikely that a facility which starts out using 5 percent BC ingredients will increase its use of BC ingredients over time. Rather than aiming to emulate industrial food systems from elsewhere, BC must use its own unique characteristics to build self-reliance. Trading the 50 percent rule for a measly 5 percent provincial requirement entrenches BC farmland in international industrial food hands rather than building local self-reliance.

The idea that BC ought to be able to feed itself to the greatest extent possible is very popular in this province,8 and our communities have what it takes to cultivate resilient self-reliance. We have farmers of every kind, hunters and fisherpeople; Indigenous foodways are being revitalized and Indigenous people are providing important leadership in areas such as land and water stewardship, relationality, systems thinking, pluralism, and governance; there are numerous universities doing agriculture and food systems work; and despite slim chances of financial success, there are numerous first-generation new entrant farmers leasing land and giving everything they’ve got to chase the dream of feeding themselves and their communities. We have high hopes for what could be achieved in a supportive policy environment, if our government were to focus on food sovereignty rather than a narrow set of business interests.

“Dependence on external food producers could pose several long-run problems for the province. It will be highly vulnerable should external political, economic market competition, or physical factors cause a reduction in the reliability or availability of imported agricultural products, or drastically raise their prices.”9

The First Annual Report of the BC Agricultural Land Commission

Democracy cannot be rushed

The principles of democracy are very important to the NFU, and are central to the concept of food sovereignty. People and communities must have agency to shape the systems in which we produce, distribute, process, and consume food. We strongly second the BC Agriculture Council’s assertion that “any amendments to the Agricultural Land Reserve Use Regulation requires meaningful and transparent consultation.” Given that changes to the 50 percent rule have been debated for years, and that both the Premier and the Minister of Agriculture and Food have spoken publicly of these changes as if they have already been decided on, the timing of this announcement leads us to question the Ministry’s commitment to hearing farmer voices. The decision to open public consultation about this new policy during the busiest and most stressful stretch of the year for many farmers, while a significant portion of us deal with wildfires, restrictions on movement, water shortages, and smoke, appears to have been made by someone who does not want farmers to be part of the conversation.

We are in agreement with the positions taken by the Agricultural Land Commission and the BC Agriculture Council regarding these proposed changes. We thank them for their clear and informative submissions and wish to recognize the work and the dedication that went into putting their pieces together so promptly after having the task dropped on their desks by surprise. The research required for the ALC to thoroughly address many of the finer details of the proposal, and the legwork required for BCAC to meaningfully consult with their membership are significant. Many of the people involved in putting these submissions together, including from the NFU, are farming right now, and this work added strain to their season. Food sovereignty describes food systems that are shaped by and for the people who produce and consume food. Farming is a seasonal endeavour, and it is entirely possible to adopt a more cyclical schedule of policymaking that values the participation of the people who will be most impacted by the decisions that get made.

It seems that neither BCAC nor the ALC were involved in bringing this proposal forward. While the NFU’s desire for transparency and democratic decision-making would not be satisfied if one or both of these organizations had been included in planning these changes behind closed doors, these bodies are understood to represent the interests of BC’s agriculture sector and agricultural land base, respectively. Drawing on the knowledge held by the BCAC and the ALC would be the minimum expectation to design policy changes that claim to serve the interests of BC agriculture and fit the purposes of the Agricultural Land Reserve. The NFU believes that the public is entitled to transparency regarding who these changes are designed to serve and why they are being framed as an initiative to help farmers, if farmers are not asking for them.

The changes are not necessary to achieve the stated goals of the proposal

Currently, farmers who wish to diversify their businesses by growing their food processing operations beyond the scale at which the host farm (and its fellow coop or association members) can supply 50 percent of ingredients are able to do so after making an application and receiving approval from the ALC. The majority of such applications are approved. The discussion paper does not clearly explain why a new 5 percent rule for class 5-7 (and sometimes 4) land is necessary to facilitate food processing within the ALR that strengthens BC agriculture, since there is already an established pathway for projects which do not meet the 50 percent threshold but do support food production in BC. These simple facts undermine the basis of the proposed changes.

If the issue is that applications are processed too slowly, then the clear remedy would be to adequately fund the ALC so that staff are able to review all applications in a reasonable time frame. Rather, it seems that this proposal is written to accommodate projects that would not be approved under the existing “in the interest of BC agriculture” criteria.

Strengthening agricultural land governance in the public interest

The NFU BC agrees with BCAC10, the Premier’s Task Force on Agriculture and Food Economy,11 Jared Qwustenuxun Williams,12 and the many others who have stated that the ALR and the ALC are due for a comprehensive reevaluation and update. If the existing policies are preventing us from strengthening food sovereignty in BC by processing more of the food that we produce, then we should absolutely undertake an inclusive and transparent review process, informed by data and a diverse range of experts, to understand exactly what needs to be changed and how.

The ALR and the ALC were created in the spirit of food sovereignty. Thousands of farmers, eaters in urban areas, academics and activists recognized the dangers of allowing ourselves to become increasingly dependent on imported food and squandering our ability to grow food here in BC by allowing poorly planned urban sprawl to continue unchecked. People came together to form a shared understanding and a shared vision, and gave their government a mandate to do something that would be considered quite radical today: impose some limitations on private property rights in order to protect the essential conditions for BC to be able to feed itself.

From the beginning, there was an understanding that there could be no one size fits all solution, case-by-case decisions would have to be made according to agreed upon core values. Recognizing that the connections between land use planning and food systems are not black and white, and would be localized and contextual, the Commission structure was established so that the authority would be shared amongst a group of qualified people with diverse backgrounds, perspectives, and priorities, with the belief that this would generate the most informed, measured and holistic decisions. Since its formation, the intention was that the Commission would have to pivot, evolve and respond to changing conditions and new information.

Unfortunately, funding for the Commission was clawed back only a few years after it was created. Programs designed to bolster agriculture in BC, such as land banking, income supports, experimental infrastructure pilots, and more were abandoned before there was time to observe their impacts and refine them. The scope of ALC operations were restricted to cover only part of its legislative mandate, and the Commission has had to make do with repeated budget losses since. It should also be acknowledged that the ALC has not yet had the resources or the mandate to address Indigenous peoples’ land rights, or had the Act amended in accordance with DRIPA, and recognized this fact in a recent decision.13 In order to keep up with the volume of applications submitted and preserve the integrity of the protective agricultural land zoning, the Commission has had to standardize and streamline. Its abilities to consider the nuances of specific cases, negotiate, experiment, influence the conditions in which people are farming, learn, debate, and change its approach were central to the design of the ALC as the ongoing steward of the ALR.

“The establishment of the Land Commission was in response to a clear need for shared decision-making in the land planning process. It was only through the spirit of cooperation which emerged from joint efforts of the general public and local, regional and provincial governments that the ALRs were established in so short a period of time. The Commission will continue to encourage such participation in the ongoing administration of the ALR.”14

The BC Land Commission, 1975

Numerous Commissioners over the years have publicly lamented that economic conditions have restricted the ALC from being able to function as intended. People involved in the system have given it their all to ensure that there will still be land we can farm in the future, and repeatedly warned us that this is a necessary but insufficient condition for ensuring BC’s capacity to feed itself in the event that imported foods become less accessible or affordable due to the predictable effects of climate change and the global financial system. To have food when the supply chains stop flowing, we need to have invested in local production, planted seeds, and been tending that food long before the shock.

Updating our public policy approach to agricultural land governance and strengthening the capacity of the Commission to be able navigate grey areas on a case-by-case basis does require significantly more investment than simply exempting some projects from regulatory oversight, but food, water, and healthy environments are necessary for survival. That is why the ALR was created, to limit the influence of short-term thinking based on balance sheets on land use decisions that could impact future generations’ abilities to feed themselves.

It is our opinion that the risks of creating a blanket entitlement for development on agricultural land, so long as the site meets subjective criteria, are too great. It is better to ask permission than to beg forgiveness, when the consequences of building an industrial processing facility in an inappropriate location include: ensuring that the soil in that location will never again be used to produce food; impacts to neighbouring farms such as stress on animals, pollution, and pressure on water supply; driving the cost of farmland even further out of reach for farmers and impacting surrounding property value assessments; and increasing the speculative value of the property for its owners, such that the economic benefits of building a facility somewhere they shouldn’t might outweigh the costs even if they are caught.

The mechanisms laid out in the discussion paper for monitoring compliance and enforcing the 5 percent rule do not seem adequate to ensure that new developments on ALR land resulting from these proposed changes would be limited to projects that are appropriately located and legitimately support primary production in BC. To begin, proponents only need to have an assessment by a professional agrologist confirming that the site meets the soil classification requirements on file if asked. The discussion paper does not indicate that they would need to provide this before construction, in order to obtain permits from the local government. In addition, soil classification alone is not a reliable metric of agricultural value. As explained by Katarina Glavas, the Senior Agrologist of the ALC, soil classifications are subjective assessments and can be changed significantly by land management practices, and there is already a pattern of privately commissioned soil capability assessments underestimating the agricultural potential of parcels that are submitted with applications to the ALC. Finally, the discussion paper states, “The ALC, upon complaint, already has the authority to verify rules are being adhered to and assess penalties if not”. The ALC can assess penalties, but can it levy them? Can it compel payment? Is there an existing fine schedule, and where would this new type of violation fit within it? Have fine amounts been adjusted to inflation and are they sufficient to outweigh the potential financial gains from developing farmland? The BC NFU echoes BCAC’s insistence that “It is critical that efforts be made to address ongoing non-compliance within the ALR before pursuing any major regulatory changes.”

It is concerning that this proposal would explicitly state that no new compliance or enforcement mechanisms are necessary to ensure that only projects which support the intended purposes of this new development entitlement occur as a result of this policy change, because the ALC already lacks the capacity to handle the existing volume of violations. This claim indicates that the authors of this proposal are either uninformed about the current enforcement capacity of the ALC, or making their case in bad faith. Do the proponents of these changes really mind if they lead to new developments that don’t meet the criteria? If the true motivations behind this proposal are to encourage more food processing within the ALR to support BC farmers and strengthen food security in BC, and not simply to advance a piece-wise “opening up” of the ALR for private economic gain, then the government should consult with producers and ask them what would be needed to get more of their products processed.

To conclude

We encourage the Ministry to reflect on the long-term outcomes of rushing through policy changes that have not been given adequate technical or economic analysis, particularly given its potential effects on BC’s farmland base and the agriculture sector’s future capacity. We strongly feel that more in-depth, democratic consultation with producers, small processors, and the broader agricultural industry is necessary before any changes are made. BC’s agricultural capacity is finite, constrained by our provincial topography. Losing farmland to processing activities that could instead be sited on non-agricultural land would pose a direct threat to the province’s ability to build food sovereignty.

The Government of British Columbia can be assured that food sovereignty, resilient self-reliance, and regional economic development are policy goals that the people of BC overwhelmingly support.

To achieve food sovereignty, we are calling for a return to the initial spirit of the ALC and the ALR: we don’t quite know, but we have to figure it out as we go and do the best that we can, for the good of us all. It is time for a renewed collective effort to ensure that our land policies support food sovereignty now and for the future, with the information and awareness that we have today, a sincere commitment to human rights for all, and a fair and honest reckoning with the rights of Indigenous Peoples. Everyone living in BC stands to gain by living in a place with more Indigenous governance, more localized and democratic decision making, and more local food production. The extraction agenda has had a chance, it did not deliver prosperity for all. It is time to reorient towards a cooperative, democratic, and regenerative economy, with food system policies that are designed to enable the people to achieve food sovereignty – we can do it.

In order to process more of the food that we grow, strengthen the agriculture sector, and bolster food security in BC, we need policies that are meaningfully shaped by the people who produce and consume food. These proposed changes are not conducive to achieving their stated intentions. We look forward to collaborating with the Ministry of Agriculture and Food and the rest of the agricultural community to craft solutions that will truly protect and enhance our ability to feed British Columbia for generations to come.

Thank you,
National Farmers Union BC

  1. National Farmers Union. (2026). Food Sovereignty. National Farmers Union. https://www.nfu.ca/learn/food-sovereignty/ ↩︎
  2. Hannay, J. (2026). Fair Food Prices? The Declining Farmers’ Share and Food Inflation. National Farmers Union. https://www.nfu.ca/wp-content/uploads/2026/04/Fair-Food-Prices-2026.pdf; Qualman, D. (2022, August 30). Nitrogen Fertilizer: Critical Nutrient, Key Farm Input, and Major Environmental Problem. National Farmers Union; Qualman, D. (2019, November). Tackling the Farm Crisis and the Climate Crisis: A Transformative Strategy for Canadian Farms and Food Systems. National Farmers Union; Holtslander, C. (2015). Losing Our Grip Update. National Farmers Union. ↩︎
  3. La Via Campesina. (2007). DECLARATION OF NYÉLÉNI. https://viacampesina.org/en/wp-content/uploads/sites/2/2024/04/Nyeleni-Declaration_Food-Sovereignty_EN.pdf ↩︎
  4. La Via Campesina. (1996). Food Sovereignty: A Future Without Hunger. https://viacampesina.org/en/wp-content/uploads/sites/2/2021/11/1996-Rom-en.pdf ↩︎
  5. La Via Campesina. (2025, July). What is Food Sovereignty? [Video]. https://vimeo.com/1103656933?fl=pl&fe=sh ↩︎
  6. Re: Response to Discussion Paper on Encouraging Food Processing Inside the Agricultural Land Reserve – Agricultural Land Commission, August 21, 2006. ↩︎
  7. IPES Food. (2026). The New Geopolitics of Food: Navigating policies for resilient self-reliance. https://ipes-food.org/report/the-new-geopolitics-of-food/ ↩︎
  8. BCLC (British Columbia Land Commission), The Annual Report of the Provincial Land
    Commission: 1973–1974. ↩︎
  9. R.A. Malatest & Associates Ltd. (2018). Revitalizing the Agricultural Land Reserve and the Agricultural Land Commission: What We Heard Report. https://www2.gov.bc.ca/assets/gov/farming-natural-resources-and-industry/agriculture-and-seafood/agricultural-land-and-environment/agriculture-land-reserve/minister-advisory-committee-what-we-heard-report-alr.pdf ↩︎
  10. BC Agriculture Council. (2025, April 15). Letter on Amending the ALR Use Regulation “50% Rule” [Letter]. https://bcac.ca/wp-content/uploads/2025/07/2025-04-15-Letter-on-Amending-the-ALR-Use-Regulation.pdf ↩︎
  11. BC Ministry of Agriculture. (2025, November 24). Premier’s Task Force on Agriculture and Food Economy. https://www2.gov.bc.ca/gov/content/industry/agriculture-seafood/premier-s-task-force-on-agriculture-and-food-economy ↩︎
  12. Trottier, K. (2025, September 9). We Wont Stop. Culturally Committed. https://www.culturallycommitted.com/post/We-Wont-Stop?utm_source=social+media&utm_medium=linkedin&utm_campaign=teaching+tuesday&utm_content=teaching+tuesday ↩︎
  13. Provincial Agricultural Land Commission. (2025, August 11). Reasons for Decision—ALC Application 69827 [Letter]. https://portal.alc.gov.bc.ca/document/6241bfe1-2149-4089-bc39-ddd36df604a6 ↩︎
  14. The B.C. Land Commission. (1974). Keeping the Options Open. Agricultural Land Commission. https://www.alc.gov.bc.ca/assets/alc/assets/library/living-in-the-alr-information/keeping_the_options_open_booklet.pdf ↩︎
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