Many of the changes create…

Many of the changes create increased local municipal flexibility in the planning system that indirectly increases uncertainty and therefore causes increased risk for the development industry. Many of the proposed wording changes give increased flexibility for local municipalities to interpret government policy in accordance with local contexts. This increased flexibility gives the appearance of greater local autonomy for planning decision making in a policy framework where consistency with provincial government policy is still required. In effect a situation is created where planning policy ‘smoke and mirrors’ intent is evident.

Background rationale for proposal - the PPS proposal background documents are quite up-front that the proposed amendments are associated with implementation elements to the government’s current agenda: Bill 108, More Homes, More Choice Act; Bill 66, the Restoring Ontario’s Competitiveness Act; and the Province’s new “A Made in Ontario Environmental Plan”. The PPS policy amendment proposals appear more as political ideology implementation mechanisms rather than being based on scientific research supportive of long-term sustainability goals for the province.

Comments on General Proposed Policy Amendments - To limit the length of this comment sheet, the following criticisms of the proposed policy changes are associated with three general topics: 1) weakening environmental protection for natural heritage features; 2) providing for additional development sprawl in various locations across the province; 3) diminishing the planning effort directed at the current climate change crisis in the province.

1) Weaken environmental protections -
a) A change is made in the aggregate ‘long term resource supply’ section that outlines that natural heritage feature areas can be removed (outside of the Greenbelt Area?) subject to planning considerations where NHS features may be re-instituted in the future (at least illustrated somehow in a plan). There is a very poor record of NHS feature restitution, and the section is oddly written in exempting one small area of the province for this, the Greenbelt, i.e., a political deal in recognition of the close access to aggregate supply and aggregate need in the GTA?

Reference Proposed Policy 2.5.2.2

2) Greater opportunities for sprawl -
a) Planning authorities are to plan and provide for the full gambit of “housing options”, a proposal that is poorly defined, i.e., a place in which to reside?

Reference Proposed Definition – housing option is proposed to be defined as “a range of housing types such as, but not limited to,” any form of place to reside including living in employment, institutional or educational areas.

Reference Proposed Policy 1.7.1 b) – Planning authorities are to encourage “residential uses to respond to dynamic market-based needs and provide necessary housing supply and range of housing options for a diverse workforce;”

Reference Proposed Policy 1.4.3 – Planning authorities shall provide for . . . housing options . . . to meet market-based needs . . .

b) Proposed amendment will permit sprawl to continue in GTA suburban/rural/northern Ontario communities. Uneconomic non-settlement-focused development over the long term adds to the cumulative infrastructure deficit in the province, and also creates conditions for negative environmental impacts. The proposal adds many ‘conditional words’ that permit development outside of settlement areas, i.e., local jurisdictions can decide what is appropriate for their specific areas.

Reference Proposed Policies 1.6.6.1 – 1.6.6.5

3) Weaker consideration to climate change impacts –
a) PPS policy proposal downplays impacts of climate change – instead of “planning authorities shall support . . . climate change adaptation”, the proposal reads to a more nebulous need to plan for a “changing climate”.

Reference Proposed Policy 1.8.1

b) Proposal adds a definition of ‘impacts of a changing climate’ to outline positive implications of climate change to Ontario. Unsure of what is the justification and rationale for this form of wording in a provincial policy document. Does this mean that greater economic activity can occur with the rebuilding of devastated rural/urban communities through wildfires, floods, windstorms, etc.? i.e., economic generation is manifested in growing the insurance industry and GDP in the province?

Reference Proposed Definition of ‘Impacts of a changing climate’.

c) Wording on fighting the climate crisis from the existing PPS has been diminished to municipalities beginning to think about the impacts of climate change. Wording has been inserted to downplay the climate crisis, i.e., planning authorities are to give consideration to the changing impacts of climate change in a local context; climate change impacts will vary from region to region; mitigation of greenhouse gases is not a priority.

Reference Proposal Preamble in Part IV – Vision for Ontario’s Land Use Planning System