The update of the…

The update of the Projections Methodology is a positive change - especially as it includes consideration of factors such as suppressed household formation, market focus, a vacancy factor, and a market contingency factor.

However, there are numerous changes still required in order for the to the proposed methodology to reflect Provincial Policy Announcements, such as that of May 12, 2025. Changes are also required to the Provincial Planning Statement to support and implement the proposed Projection Methodology, and to eliminate contradictions and inconsistencies.

Overall, a more market responsive approach is overdue. The adverse effects of some previous policies - especially of the Growth Plan for the Greater Golden Horseshoe and its associated Land Needs Assessment Methodology - have contributed to the severe housing shortage Ontario faces today, and will take many years, if not decades, to correct. Foremost among those errors was the transfer of intensification from where it properly belongs (a question of urban form and urban design) into a step in calculating land need. This has been severely damaging, by attempting to dramatically modify family preferences, and market forces. This has been a serious error, successful only in limiting the supply of housing, while being unable to alter market forces and consumer preferences. The result is a housing shortage - especially of the grade-related housing that families prefer - and unaffordability due to a lack of housing supply overall.

The proposed methodology includes a distorting intensification step in calculating housing needs. This should be eliminated from the calculation of land needs, and returned to a policy consideration when shaping and designing the form of complete communities.

The attached submission more completely sets out suggestions for change to the proposed Methodology.