HOUSING The draft PPS…

ERO number

019-0279

Comment ID

35365

Commenting on behalf of

City of Mississauga

Comment status

Comment approved More about comment statuses

Comment

HOUSING

The draft PPS proposes several policy changes intended to address housing challenges across Ontario, including:
• A new focus on a market-based range and mix of housing types and market-based considerations for where growth should occur (intensification or new settlement areas) (policy 1.1.1 and 1.4.3).
• Housing options has been introduced as a new term which means: “a range of housing types such as, but not limited to single-detached, semi-detached, rowhouses, townhouses, stacked townhouses, multiplexes, additional residential units, tiny homes, multi-residential buildings and uses such as, but not limited to life lease housing, co- ownership housing, co-operative housing, community land trusts, affordable housing, housing for people with special needs, and housing related to employment, institutional or educational uses” (policy 1.1.3.3, 1.4.3, and 1.7.1).
• Aligning housing targets with housing and homelessness plans (policy 1.4.3 (a)).
• Requiring transit-supportive development and prioritizing intensification including potential air rights development in proximity to transit (policy 1.4.3 (e)).
• New policy that requires planning authorities to streamline, fast-track and reduce time needed to process priority applications (policy 4.7).

Staff support provincial aims to create more housing, a greater mix of housing and efforts to make home ownership and renting more affordable. However, it is not clear on what is meant by “market”, and what data would be used to identify market needs. This PPS language seems to run counter to policies in the Growth Plan intended to shift the market to more dense forms of housing.

The proposed PPS also includes a new term housing options (replacing housing types), which encourages a broader range of housing types and tenures. Staff recognize the importance of encouraging an innovative range of housing and are exploring gentle forms of infill and other housing options as part of the City’s Housing Strategy Action Plan. Staff would encourage the Province to add detailed policies in the Planning Act so that municipalities have more legislative tools to increase the supply of affordable units, rental and co-op housing, and dwellings for people with special needs.

Staff support greater alignment between housing targets and actual housing being built. The City has already aligned its targets with Regional targets and is looking for the Province to go further and provide municipalities with an expanded set of tools to create affordable housing. Additional tools could include simplified inclusionary zoning city-wide, conditional zoning and provincial tax incentives.

New policies supporting transit oriented development are aligned with City priorities as we are working to advance the planning for major transit station areas. However, clarification is required regarding the intent and use of air rights. Air rights involve planning permissions above existing buildings or infrastructure, such as a rail corridor. In some jurisdictions, unused air rights can sometimes be purchased and transferred between adjacent sites (e.g. a condominium developer may purchase the air rights above a place of worship). Air rights have not been an issue in Mississauga in the past. It is recommended the Province release more guidance on how to plan for air rights including: transfer of air rights; application processes for air rights; and implementation of air rights over long term. Overall, air rights can be workable as long as they are regulated in a way that does not drive property speculation, and proposed development aligns with policy direction contained in the Official Plan.

The proposed policy changes also require planning authorities to streamline, fast track and reduce timelines to process priority applications. Further fast tracking is not required given the already reduced timelines introduced through Bill 108. Further, the City, through its development liaison and planners, work with applicants and commenting agencies to resolve issues as expeditiously as possible.

URBAN SETTLEMENT EXPANSIONS

The draft PPS proposes several amendments to urban settlement area expansions including:
• Changes to the maximum planning horizon for developable land, infrastructure, public service facilities and employment areas from 20 years to 25 years (policy 1.1.2 and 1.3.2.7).
• Extending the minimum number of years required to maintain the ability to accommodate residential growth from 10 years to 12 years (policy 1.4.1(a)).
• Upper- and single-tiers may choose to provide 5 years supply of serviced land within regional market areas (policy 1.4.1).
• Allowing less detailed agricultural assessments for smaller or less complex settlement expansions (policy 1.1.3.8 (e)).
• Allowing potential settlement boundary expansions outside of a Municipal Comprehensive Review, provided there is no net increase to the municipal-wide settlement area (policy 1.1.3.9).
• Requirement to consider market demand in existing growth areas when contemplating settlement area boundary expansions (policy 1.1.3.8).

Mississauga has the capacity to absorb a significant amount of growth and development that would optimize existing infrastructure and services. The proposed policy changes are similar to prior amendments to the Growth Plan that allow more low density greenfield development to occur. The proposed urban settlement policies are not expected to impact Mississauga directly, however they could impact future growth allocations. Initial discussions with Regional Staff indicate they are not planning on adjusting their current Municipal Comprehensive Review process to a 25 year horizon.

EMPLOYMENT

The draft PPS proposes several policy changes relating to employment planning and employment area protections, including:
• A new policy that permits the development of sensitive land uses adjacent to existing or planned industrial, manufacturing or other uses when no reasonable alternative locations are available (policy 1.2.6.2).
• A new policy that allows for non-provincially and/or regionally significant employment areas to be converted to non-employment uses prior to a Municipal Comprehensive Review (policy 1.3.2.5).

The proposed policies may reduce employment area protections.

The proposed changes could result in residential development encroaching on the City’s employment areas. Specifically, new policy proposes the development of sensitive land uses adjacent to existing or planned industrial uses where no alternative exists. The Province needs to clarify what an assessment of an alternative location would entail, and how the City would determine if this requirement has been met.

The proposed PPS policies, in conjunction with the amended Growth Plan, expand the role of the Province in the planning of employment areas. The Province has identified provincially significant employment zones where land-use use conversions are not permitted. However, the PPS will enable the conversion of non-provincially or regionally significant employment areas outside of a Municipal Comprehensive Review. The proposed changes will only affect a small land area of Mississauga. After accounting for natural areas and roads, approximately 97% of Mississauga’s employment areas are identified as provincially significant and therefore only 3% of the City’s employment area land base could be subject to increased conversion pressure. Please see Appendix 2 for a map of the City’s provincially significant employment zones, relative to its employment areas.

INDIGENOUS ENGAGEMENT

The draft PPS proposes that planning authorities shall engage with Indigenous communities and consider their interests:
• When identifying, protecting and managing cultural heritage and archaeological resources (policy 2.6.5).
• When coordinating on land use planning matters (policy 1.2.2).

The proposed updates strengthen the language for Indigenous engagement. The proposed policies align to Mississauga’s ongoing engagement with Indigenous communities on land use planning, cultural heritage and archaeological matters.

ENVIRONMENT, ENERGY, NATURAL AND CULTURAL HERITAGE

The draft PPS proposes several policy changes relating to the environment, energy, natural and cultural heritage, including:
• The word climate change has been replaced with impact of changing climate through the PPS.
• A new policy allows for the management of non-significant wetlands (policy 2.1.10).
• Removal of language related to opportunities for renewable and alternative energy systems throughout the PPS (policy 1.6.11.2, 1.7.1(j), and 1.8.1).
• A new policy that proposes excess soil be re-used on-site where feasible (policy 3.2.3).
• Changes to definitions related to cultural heritage and archeology.

Staff request that the Province maintain strong language to support environmental protection and respond to climate change throughout the PPS. The proposed policy changes in some areas of environmental management have a greater focus on mitigation though this is not expected to impact Staff’s review of studies and development applications. Staff support proposed policies on wetlands and the promotion of on-site soil re-use.

Municipalities look to the Province for leadership in the promotion of clean and renewable energy sources. The PPS should retain and integrate previous language that encourages alternative energy systems.

The proposed PPS policy changes impact provincially applied heritage protections, and will work with the significant changes proposed as part of Bill 108. Until the regulations are released, it is not possible to understand the full impact of changes under Bill 108. However, in the interim it is recommended that the Province consider a formal process allowing municipalities to pass heritage by-laws which allow for similar protection applied to locally significant resources.

Please see detailed comments in report attached.