Examples of ALR Regulation survey

Bulletin, August 19: The BC Food Systems Network has finally come up with an analysis of the survey that is discussed in this article. Have a look at BCFSN’s systematic and insightful analysis.


I’m being asked for directions about how to fill out the survey about changes to B.C.’s ALR Regulation. After saying “That isn’t going to happen,” I’ve given in a bit. At the bottom of this article, I’ve now indicated what my ratings for the eleven questions would currently be.

If that’s all you want, skip to it. If you wish to go into depth, there’s lots between here and there.


Jane DoeFirst, here are two examples:

1. Jane Doe’s. It is similar to my completed survey, and it could be a way to get started with one’s thinking about the survey. I think it’s worth a look.

Pat Pimm2. Pat Pimm’s. It is in report form, an acceptable way to respond. Along with Bill Bennett, Pimm was behind Bill 24, which I call the bill to kill the ALR, so in my view his answers are more likely to show what to avoid than what to imitate.

The actual survey is here.

The consultation paper is here.



Thomas Loo has been adding some comments on Facebook that are well worth including and considering here. Thomas was a compliance officer with the Agricultural Land Commission for six years, and he lived in Richmond. He is now bylaw officer for Central Kootenay. His insights are always valuable. Here are two of them and my responses.

Thomas Loo, Comment 1: I just want to point out that by lowering the current 50% produced on farm to whatever number can be problematic. While the regulation and it’s “intention” may be altruistic, as an Ex-Compliance Officer, I can tell you that measuring that 50% was tough enough. Look at all the “non-farm composting” facilities and processing facilities that are already in the ALR and non-compliant with the 50% rule! Imagine someone buying a property and then running a large fruit processing facility 24/7/365. The noise would be horrendous.

My response: Furthermore, if the large fruit processing facility is really great for the purposes of the ALR and is acceptable from other standpoints, it is already entirely possible, because the Agricutlural Land Commission would approve the application. The obvious example is Ocean Spray’s $26 million Richmond plant. The large cranberry processing plant on ALR land that was completed and opened in Richmond in 2012. If I recall correctly, the large plant is not on a particularly large parcel, and it is owned by Ocean Spray. The Garden City Conservation Society had no objection to that use of ALR land, and the City of Richmond and the Commission approved too. One has to understand the whole story to realize why there was agreement that the large fruit processing plant was an appropriate use of ALR lands.

Thomas Loo, Comment 2, posted before I had posted a response: True farmers would also not be able to compete against corporate interests to purchase the land, since they don’t have the ability to access the kind of capital. I believe the whole intention of the Non Farm Use Application was to solve those issues where maybe a third party creates an “industry” to support the farmer – in this case fruit processing. ANY industry that locates in the ALR but supports the Ag industry should get some support from the ALC, but the fundamental question the Commission also answers is “does the industry really need to be located in the ALR?” or are they just doing it to get “cheap land.”

My response: I agree. Furthermore, we currently have a situation where City of Richmond parks staff appear to be contemplating a huge farmers market on the Garden City Lands. It would not only require a huge market area and huge parking area on farmland but also compete with produce stores that pay business taxes. When the Agricultural Land Commission reviews these matters, that provides a needed safeguard for the protection of farmland. I’m increasingly thinking that the need is not to loosen the regulation but instead to support the ALC’s excellent efforts toward efficiency so that the valuable step of application to the ALC does not cause long delays.



I did the ALR Regulation survey a while ago. Since then, I have become more cautious after learning from other informed people. Mainly because of the need for greater caution, my ratings for the 11 questions would be lower now. For what’s it’s worth, these are my ratings now:

Questions 1–4, Farm Use:

1. The 50% parameters: Disagree

2. Allowing breweries, etc.: Agree

3. Footprint of consumption areas: Neutral

4. Selling alcohol from elsewhere: Disagree 

Questions 5–7, Permitted Use:

5. Anaerobic digesters: Disagree

6. Combined heat and power: Neutral

7. Non-agriculture businesses: Disagree

Questions 8–9, Subdivision without application in Zone

8. Quarter section: Disagree

9. “Obstructions”: Disagree

Question 10, Agri-tourism: Agree (Would strongly agree if it went further)

Question 11, Leasing: Neutral (Would agree if it were for the whole ALR)

Reminder: Also have a look at BCFSN’s systematic and insightful analysis.


Ready to do the ALR Regulation survey? Great!


1 Comment »

  1. 1
    Thomas Loo Says:

    Last comment – as long as the ALC remains “underfunded” and there are only 2 C&E Officers, the Local Government Bylaw Officers / Planners will not investigate issues relating to the 50% rule. LG’s have often stated that the rule is under the ALCA and they do not have the ability / jurisdiction to do ALC work. Although, personally, I think that the local government does have the right to ask questions in order to fully understand a use, to determine how it relates to the Zoning designation.

RSS Feed for this entry

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s