The proposed changes to the…


The proposed changes to the Growth Plan need to be modified or withdrawn for the following reasons.

1. The changes promotes sprawl driven planning – by weakening the ‘standardized’ land needs assessment methodology recently put in place by the province in early 2018.

2. The changes make Urban Boundary expansions easier & less planned by allowing urban boundary expansions in 40 hectare increments outside of the land needs assessment done in the municipal comprehensive review process.

There appears to be no limit on the number of 40 ha expansions allowed, so this makes the Urban Boundary vulnerable to death by a thousand cuts. It is unclear who can initiate these expansions - is it the municipality or is it any developer? If the latter, developers can overwhelm Planning Departments with multiple successive requests. Once again this undermines the municipal comprehensive review process.

3. The changes weaken greenfield density targets through the density target being reduced from minimum of 80 people & jobs per ha down to minimum of 60 people and jobs per ha of land. Once again, this encourages sprawl.

4. While the proposed changes are to be commended for facilitating higher density at transit stops,
it is also easier for municipalities to argue for for lower density requirements within these zones.

5. The changes protects some employment lands yet makes others vulnerable. The establishment of Provincially Significant Employment Zones confers stronger protections on these lands which is a good thing. However the changes make employment lands that don’t have these designation more vulnerable to conversion to mixed use or residential.

6. A major platform of the government was to make housing more affordable. The changes do not contain any tools to create more new affordable housing. The proposed changes simply imply that increasing supply’ will address housing issues. Affordable housing, including rental property, has not yet resulted from decades of developer driven growth and sprawl around the Greater Golden Horseshoe, and these changes do not solve that.

7. At a time when the impacts of climate change are becoming increasingly obvious, the changes remove all references to Climate Change. We are in a climate crisis and municipalities need to address the many impacts of climate change today and in the future by planning and building compact, complete communities – communities that are resilient, inclusive and sustainable - while at the same time protecting our valuable local food producing farmland. Planning regulations should both promote and require significant changes in the face of the impacts of climate change.


In summary, the proposed changes fail to address the Greater Golden Horseshoe’s affordable housing problem and favour costly low-density sprawl. What the region needs are more housing options for renters and owners, within our cities, close to where people want to live, work and play. We do not need more sprawling subdivisions on farmland, forests and the source of our drinking water.