Please accept our comments…

Please accept our comments regarding the proposed amendments to the Growth Plan.
While we are thankful that the Schedule 10 of Bill 66 was withdrawn, we remain deeply concerned and disappointed with the province’s attempts to erode the Greenbelt and our environmental laws. In reviewing the Growth Plan amendments with the “strikethroughs”, the concerns with the amendments start almost immediately with the proposed removal of the following sections as seen below:

“Its communities will be supported by a strong economy, a clean and
healthy environment, and social equity and an approach that puts people first.” (the words, "a clean and healthy environment and social equity" has a strikethrough and "an approach that puts people first" has been added.)

“There is a large supply of land already designated for future urban development in the GGH. In some communities, there may be more land designated for development than is required to accommodate forecasted growth to the horizon of this Plan.” (the entire paragraph has a strikethrough)

The first removal indicates this lack of understating regarding the connection between a healthy environment and the health of communities and the people in those communities.

The second section of strikethrough, ignores facts or rather aims to erase them. This is perhaps the most concerning-the fact that significant changes are being proposed with no hard evidence to support their necessity and further that municipalities would be permitted to make changes to their settlement boundaries outside of necessary, evidence based “municipal comprehensive reviews”. This is contrary to best practices in planning.

We support the Ontario Greenbelt Alliance submission regarding the Growth Plan amendments and wish to draw particular attention to the following excerpt:

“ If urban boundary expansions proceed when there is excess land then land use is not maximized resulting in inefficiencies, such as lost revenue for municipalities from vacant land and costs for infrastructure expansions resulting in higher taxes. Of additional note is that exempting 40 hectare settlement boundary expansions from an MCR is a recipe for many smaller, unserviced settlements to expand incrementally and a signal for the development industry to speculate on farmland around these small settlements given this exemption.”

We support all recommendations contained in the Ontario greenbelt Alliance submission and would like to draw further attention to the following recommendations:

“Recommendation:
a) Clarity is required to understand 1) who can make a request for a boundary expansion, 2) the number of boundary expansions that can be requested outside of an MCR process and 3) how can there be an adjustment to a settlement boundary if there is to be no net increase in land within the settlement area?
b) Hold the line on urban boundary expansions to support intensification to prevent sprawl, farmland loss and maximize the efficiency of existing infrastructure.
c) No rounding out to rural settlement boundaries or the boundaries of towns and villages or hamlets in the Greenbelt Plan.
d) Do not proceed with allowing settlement boundary expansions of up to 40 hectares (the size of Yorkdale) or multiple expansions.

Regarding density targets, we wish to support and draw further attention to the following excerpt from the OGA submission:

“Density makes housing, schools, road and servicing infrastructure more affordable and sets the land-use stage for providing the diversity of housing that people want. In the Greater Toronto Area 81% of respondents to a home-buyers survey prefer a smaller house or condo in a walkable transit friendly neighbourhood over a large house and a long commute.

The Growth Plans (2006 and 2017) have always allowed Regional and County governments to account for variations and infrastructure capability of lower tiers when allocating growth – and all have utilized this ability. Also 75% of the forecasted growth is in greenfield areas that are contiguous to urban areas and most areas are supported by the regional transportation plan. Allowing all municipalities to lower growth targets is contrary to the principals of compact transit supportive growth in the Growth Plan and will make it difficult to ever be able to provide appropriate levels of transit to low density areas in both the inner and outer ring. This particularly true for Durham and Halton Regions. While we support maintenance of the existing targets – should the Government proceed, Durham and Halton should have a density target of 60 pjh so that the entire GTHA has the same target – and a better opportunity to support our $50 billion regional transportation plan.

Recommendations:
a) Keep the 2017 Growth Plan density and intensification targets and make them mandatory, there is already flexibility with expansion criteria through MCR process. Hold the line on density targets to develop the type of housing supply needed.
b) Do not allow alternative density or intensification targets for any municipalities within the inner ring or in municipalities with UGCs in the outer ring (ie. maintain the existing policy framework).
c) Provide clearer policies for outer ring municipalities that may seek an alternative target and require an increase for the 2031-41 period than they were permitted in the first round of Growth Plan conformity to 2031.
d) Clarity and transparency is needed to improve monitoring and reporting on implementation to better understand problems and find the best solution.
e) Update growth projections based on the census and Ministry of Finance projections.

We also would like to state that we support the “Housing Submission” by Environmental Defence (ED) and suggest that there can be no acceptable rationale for the Growth Plan amendments proposed in light of the evidence shared in the ED Submission. The following excerpt from the Submission is provided as an example of evidence based information leading to an evidence based conclusion.:

“2.1 Housing Supply Case Study - York Region
A 2016 Housing report from the Region of York identified a good supply of housing with 15,930 registered and 26,980 draft approved units by structure type in the Region as of mid-year 2016. Together, the Region’s registered and draft approved supply is an estimated 42,910 units. The forecast demand is (9,000 units/year) indicating a five year supply of housing ready to be built.

York Region has regional water and wastewater capacity for 227,700 people or 82,600 units. Given that the Region’s 42,910 units of registered and draft approved supply account for only 52% of this total, there is sufficient servicing capacity at the regional level to accommodate more than the five years of registered and draft approved units for future growth. Housing supply today is clearly not an issue in York Region.”

We request the proposed amendments to the Growth Plan be withdrawn and that the province ceases to continuously attempts to erode sound and evidence based environmental regulation and policy. Similar to Schedule 10 of Bill 66, these amendments bring us back, not forward. They are regressive. They are contrary to best practices in planning and do not have any real regard for the agricultural lands or natural heritage lands they propose to erode.

Respectfully submitted.