SFAS Advocates to Protect ALR Land. Our OCP Response

November 29, 2024
ACTIONS
ALR, OCP, protect farmland, Salmon Arm

With our newest ACTION of creating this new space to share perspectives, we introduce the Shuswap Food Action Blog.

We’ve grown leaps and bounds in the last number of years and our programs have grown as well as our connections to and contacts with farmers, producers, social agencies, government and the public at large.

These connections have created meaningful conversations, brainstorming sessions and also, at times, GRIPE sessions where we share some of the challenges and frustrations of the broad — and so very massive topic — of food security.

But where can these conversations go? Where can these thoughts and perspectives be shared?

Shuswap Food Action not only wants to create wonderful programs to nourish and help educate our community, but we want to be change makers and policy advocates.

Shuswap Food ACTIONS is a space to share the advocacy our Society is working on, the strides we’re taking and the conversations we’re having.

A recent ACTION we’d like to share with you is our letter to the City Council and Mayor Alan Harrison outlining our OCP Response:

Download Letter

City of Salmon Arm
Mayor Alan Harrison and City Council
Box 40 500 2 Avenue NE
Salmon Arm, BC V1E 4N2

November 15, 2024Re: Shuswap Food Action Society – OCP Response: Protect Salmon Arm’s Agricultural Land and Invest in our Downtown

Dear Mayor Harrison, Salmon Arm City Council and Planning Staff,

Thank you for your commitment to Salmon Arm through a renewed vision for our city as outlined in the draft Official Community Plan (OCP). We are writing to provide our input on this draft 2024 document, to ask explicitly that you remove the two proposed ALR exclusion sites, including the 146-acre block around the airport and the 118-acre area stretching from Foothill Road to 10^th Ave SW and from Shuswap Street to 10^thStreet SW near Piccadilly Mall (the “ALR Island”), and to suggest that you expand your vision of food and agriculture to include other key aspects of community food security as outlined below.

Planning for future disruptions

In this era of climate change, global pandemics, geopolitical conflicts, and growing inequality, disruptions to the global food system are occurring more frequently. Many of these disruptions have the potential to impact food access on a large scale, a reality that communities need to be ready for through preparation to mitigate impacts. Removing ALR land from within the Urban Containment Boundary (UCB) seems like a short-sighted decision in these times.

Agriculture in BC contributes $1.7 billion dollars toward provincial GDP. Farmland supports community resiliency by providing opportunities for local food production and processing, flood control and fire suppression, and when managed sustainably, supports biodiversity and ecosystem services like clean drinking water, carbon sequestration and wildlife habitat. The ALR comprises just 5% of BC’s total land base and is a finite and valuable resource that is directly tied to the economic wellbeing of our communities.

“ALR Island” near Piccadilly Mall

The exclusion area proposed near Piccadilly Mall is flat, open land similar to the size of our historic downtown. If successfully removed from the ALR, the OCP notes it will be zoned high density residential and commercial/mixed use. Once the land is removed from the ALR and rezoned it becomes available to developers. The need for more housing, the ability to build roads, and to “keep our options open” have been cited as reason from City staff to apply for land removal from the ALR. While certainly more (affordable) housing is needed in most communities across BC, the city does not seem to be considering available non-ALR sites it currently owns for residential/commercial development, including, the land behind the school district office or the

Ross Street parking lot. Both of these options would allow for further densification in our city, support existing commercial/business areas, and support many objectives outlined in the 2024 Draft OCP (i.e. to support the Downtown as the principal commercial, business, cultural, and administrative centre – page 4).

We believe that the “ALR Island” presents amazing potential to feed the growing, urban population of Salmon Arm, and would contribute to strengthening the City’s local food economy such that it can both withstand future shocks and provide an increasing level of the core dietary needs of City residents.

Removing land from the ALR has negative ripple effects

One argument that has been made for removing ALR land around the airport is that farmland is considered class 5-6 land, deemed unsuitable for crop cultivation. While this may be true, marginal agricultural land often provides opportunities for supporting agriculture infrastructure or “closed systems” like: poultry barns, mushroom farms, greenhouses, composting or for forage use.

More importantly, taking any land out of the ALR drives a speculative market that can ultimately affect values and use of agricultural land in our area, making it cost prohibitive for farmers to acquire farmland. Farmland in our area has historically been quite affordable, and it needs to be for farming to be economically viable in light of cheap food made available via global/corporate food supply chains. Yet the cost of agricultural land in Salmon Arm has risen substantially in the last two decades, particularly in areas where there is competition in the form of urban or light industrial development. Even the perception that land might be removed is driving the price of small acreages in Salmon Arm beyond the reach of farmers. Speculators continue to own and acquire farmland in Salmon Arm as a secure investment that may eventually yield a windfall profit from non-agricultural uses/development. Some of this land is leased to farmers, which can be a disincentive for the operator to maintain soil quality and invest in improved productivity. However, in some cases, non-farming owners are simply not farming at all (essentially removing their land from production, impacting soil quality over time).

Questioning the City’s need for more light industrial land (near “airport exclusion zone”)

In 2011, the city commissioned a report called “The Retail and Industrial Land Use Market Study and Impact Analysis” to inform the previous (2011) Official Community Plan, which questions the need for more designated industrial land in Salmon Arm. While this report is not referenced in the 2024 DRAFT OCP, neither is there new data to provide an overview of our current industrial land-use. For this reason, we are concerned that there is little analysis going into the assessment that ALR land exclusions for industrial use are indeed needed.

Anecdotally, there is very little industrial development taking place in Salmon Arm and there are industrial sites that have been for sale for months and some for years. This begs the question, why apply to remove such a large tract of ALR land at this time and all at once?

The “airport” ALR exclusion area was endorsed (for removal) by the ALC in 1988 but this should not be the basis for the City’s ongoing reasoning for exclusion zones. Over the last several decades the Agriculture Land Commission (ALC) has approved many contentious applications from municipalities for residential, recreational, industrial, and commercial development which has led to a groundswell of concern among farmers and citizens across the province. Our concerns over the protection of ALR land are not isolated to our community.

Invest in Smart Growth

Furthermore, from an urban planning perspective, we are concerned how ALR exclusion zones will impact our downtown businesses and opportunity for smart growth and densification. If development (at the scale 118 acres could support) is directed outside of Salmon Arm’s downtown, we believe this would render its businesses unviable. This has occurred in cities like Nanaimo, Kamloops and Prince George where commercial development elsewhere pulls tenants from downtowns causing crime rates to proliferate, negatively impacting the town as a whole.

Instead of looking to remove farmland from the ALR for development, our city’s growth strategy should be forward thinking – to promote supporting small businesses downtown, improve and increase walkability and bike-ability to reduce greenhouse gas emissions, increase walkable access to nutritious food, and aim to create a healthier, more vibrant, economically diverse, connected, and sustainable city. This would require the City to be a strong advocate for new development downtown and adjacent to downtown to strengthen from what we have and what we know to be best practice in smart growth/complete communities.

Expanding the vision

While the City’s vision is to maintain the agricultural character of areas outside the Urban Containment Boundary (UCB), we believe that the ALR exclusion zones act in contradiction to OCP objectives that seek to: “incorporate urban agriculture in the community” and “protect farm land and farm operations” (Draft OCP, page 11); “Encourage… incentives and support for new farmers to obtain land” (Draft OCP, page 13); “preserve and protect current and future food production within the City boundaries” (Draft OCP, page 94); and ensure that ALR land continues to be a “source for local food and employment in the community” (Draft OCP, page 12).

These OCP objectives are great to see in the Draft! However, not only do we want to see the ALR exclusion zones removed, we would like the vision for food systems, food security and agriculture to be expanded to ensure a more well-rounded perspective, including the following objectives to:

Promote “Complete Communities”, with walkable access to healthy food for every neighbourhood.
Support food security programming and initiatives.
Increase cultural food activities and events in the community.
Strengthen regional emergency planning and preparedness for food.
Strengthen urban-rural linkages through access to locally produced food retail (e.g. support for independent grocery stores and farmers markets).
Support the creation of a food policy council.
Incorporate ethics and values of Indigenous Food Sovereignty, including to: protect traditional foodlands, support traditional stewardship and harvesting practices with leadership of First Nations; consider opportunities for land back.
Reduce and recover food waste through regional coordination, community efforts and/or private sector initiatives.
Support the use of industrial lands for post-production activities, such as food processing, to strengthen the local food economy.
Establish and enact local food procurement targets as a dimension of social procurement and means to strengthen the local food economy.
Collaborate with the development industry to identify opportunities to provide food production in new multi-family developments (e.g. develop a Food and Agriculture Checklist or guidelines that establish a framework to facilitate functional and accessible growing space).
Encourage food production activities in visible and suitable public places to foster a connection between people and the process of growing, harvesting and eating fresh produce.

Please note, each of these recommendations are either taken directly from municipal OCP’s in BC or are policy recommendations outlined by Food Policy Councils in BC (i.e. Comox Valley Food Policy Council). These objectives are a part of the vision for growth in BC communities like ours.

Why is this Important

The decisions we make concerning our agricultural land will impact current and future generations – once the land is gone, we cannot get it back. Protecting our farmland and soil health is an investment in our immediate future, an investment in our business community and smart growth development, and a long-term investment in our community, our region, our province and beyond. This decision will have major ripple effects. And so, we implore Mayor and Council to stand up for our agricultural land, to prevent future encroachment, and stop land swapping and speculation on ALR land. Shuswap Food Action Society would love nothing more than to endorse the new Official Community Plan and support OCP objectives and a vision for growth that see ALR remain intact, and remain within the City (within the Urban Containment Boundary).

We thank you for considering our input on this matter. We look forward to continued dialogue and collaboration with the City to ensure both farmland and local food businesses are protected and amongst our strongest community assets.

Sincerely,

Shuswap Food Action Society – Executive Director, Staff, and the Board of Directors

References

Brynn, Abra & Robert Naomi. (2024) “BC’s Provincial Election 2024: Building Resilient Communities Through Food System Policy” Policy Brief. FarmFolk CityFolk and KPU Institute for Sustainable Food. https://farmfolkcityfolk.ca/wp-content/uploads/2024/05/Policy-Paper-BCs-Provincial-Election-2024.pdf

BC agriculture Council (2024). Farm Facts. https://bcac.ca/farm-facts/