Submission on Food Processing in the Agricultural Land Reserve

The Business Council of British Columbia (BCBC) is a non-partisan organization comprised of B.C.’s largest and leading companies, post-secondary institutions, and industry associations. We are dedicated to promoting prosperity through thought leadership and fostering cross-sector collaboration.

This submission responds to the Government of B.C.’s August 18, 2026 proposal to expand food-processing opportunities in the Agricultural Land Reserve (ALR). The stated purpose of the proposed regulatory changes is to “allow food processors to build food-processing plants on Class 5-7 soil (and Class 4 if the parcel is serviced by the date this rule is implemented) in the ALR, so long as 5% of the primary product used in the processing is grown or raised in the province.” The proposal would cap the land eligible for this new food processing pathway at 0.25% of privately owned ALR land, approximately 5,250 hectares province-wide (or 0.006% of the total British Columbia land base) and up to 1,000 hectares of land in the Lower Mainland and Fraser Valley.

BCBC supports the proposed changes as a first step towards modernizing agricultural land-use policy, including this shift to a rules-based approach rather than relying principally on individual applications to the Agricultural Land Commission (ALC) for land-use change. The Province should implement the changes promptly and build in a mechanism to expand eligible agriculture land and permitted uses on agricultural land as experience with the new approach is gained.

Disruptions in the Canada-U.S. trade relationship make this a timely opportunity for B.C. to strengthen its domestic food-production and processing capacity. Agri-food supply chains in Canada and the United States are highly integrated. While this has created a larger market for sourcing and processing food, benefiting consumers through price, variety, and availability, the experience of the past year has demonstrated the vulnerabilities from this tight market interconnection. All manner of goods, including food, may be less predictably available and more expensive, making the proposed changes both a resilience measure for B.C.'s food supply as well as a longer-term competitiveness issue for B.C.’s agricultural sector. Greater flexibility to source inputs from other provinces would also help processors operate at a viable scale and serve more Canadian customers. Combined with work to remove interprovincial trade barriers, this would support a stronger domestic food market while retaining access to international suppliers and customers.

More Flexible Sourcing for Food Processing

In terms of the current rule, requiring processors to source half of their agricultural inputs from B.C. producers creates barriers to investment by limiting a processor's ability to secure the volume of inputs needed to operate at an economically viable scale. McCain Foods' $600 million expansion of its existing Coaldale, Alberta facility announced in 2023, illustrates the opportunity cost associated with this type of constraint. McCain Foods had considered locating a potato-processing facility in B.C. but was unable to use land within the ALR. The alternative use of more expensive and scarce industrial land undermined the economics of the investment. McCain ultimately chose Alberta over B.C. While a single investment decision in the past does not determine the development of an agricultural sector in the future, processing capacity can create demand around which primary B.C. production can develop. The experience illustrates the risk of requiring a large domestic supply base as a precondition for attracting the processing investment that can help that supply base grow.

The Province's Look West strategy sets goals of $200 billion in major-project investment and 25% growth in agriculture and food exports by 2035. A policy framework that supports those ambitions must give food processors access to suitable land, reliable servicing and predictable approvals.

Processing Land Cap

The proposed 0.25% cap builds on a recommendation made by the Province's Food Security Task Force in 2020. However, the current proposal is more constrained because it applies only to privately owned ALR land and has narrower eligibility for Class 4 parcels. The Task Force proposed allocating up to 0.25% of the total ALR to agricultural-industrial uses, subject to soil, location and servicing criteria. Whether the estimated up to 1,000 hectares of private land potentially available in the Lower Mainland and Fraser Valley is sufficient to accommodate the region’s food processing potential will depend on the location, parcel sizes and commercial viability of eligible sites. The Province's estimate already excludes protected riparian zones and land without required services, so further work should identify which sites can realistically accommodate investment.

The Lower Mainland and Fraser Valley are particularly important locations for food processing because of their proximity to agricultural production, major population centres, and transportation infrastructure, including highways, rail, ports and airports. These advantages cannot necessarily be replicated by making land available elsewhere in the province, making the amount and location of eligible land in this region particularly important to the effectiveness of the proposed reform. We continue to support the broader allocation proposed by the Food Security Task Force, as reflected in our 2021 analysis in A Perspective on Agriculture: How We Feed Ourselves. This would mean removing the private ALR constraints, doubling the available land to 11,700 hectares across the total ALR. This should remain a longer-term benchmark for suitable public and private land.

Recommendations

BCBC recommends the following steps to support a more productive and integrated agri-food economy:

1. Implement the proposed new processing pathway, within the 0.25% cap on privately owned ALR land, approximately 5,250 hectares.

2. Publish clear guidance explaining which lands and food-processing activities are eligible, how the five per cent B.C. sourcing requirement will be calculated, and how land will be counted toward the overall cap. The Province should also coordinate the different approvals that may be required and provide clear and reliable timelines for decisions.

3. Over the next three to five years, consider expanding the amount of land available for agriculture-related food processing and technology using the 2020 Food Security Task Force recommendation of up to 0.25% of the entire ALR as the longer-term benchmark for a total of 11,700 hectares.

4. Conduct continuous reviews thereafter with a view to increasing ALR land available for processing beyond the 0.25% benchmark as experience is gained and demand for food-processing land grows