Ministry of Municipal…

Ministry of Municipal Affairs and Housing

RE: ERO Number: 019-0279
Provincial Policy Statement Review – Proposed Policies
Notice type - Policy
Act - Planning Act, R.S.O. 1990

The Hamilton Industrial Environmental Association (HIEA) is a not-for-profit association of 14 leading industrial companies located in Hamilton, Ontario. We are committed to operating their facilities in a safe and responsible manner, and in a way that does not adversely impact neighbouring communities. We help improve the local environment — air, land and water — through joint and individual activities, and by partnering with the community to enhance future understanding of environmental issues and help establish priorities for action.

We appreciate this opportunity to help shape the Provincial Policy Statement in a manner that protects jobs, healthy communities and the environment. Below are our comments and recommendations in response to 2 questions posed in the EBR posting.

Question 1: Do the proposed policies effectively support goals related to increasing housing supply, creating and maintaining jobs, and red tape reduction while continuing to protect the environment, farmland, and public health and safety?

• The proposed policies encourage intensification that may bring sensitive land uses closer to the heavy industrial centres like Hamilton’s industrial core. If sensitive land uses encroach on industrial areas additional environmental mitigations may be imposed through existing environmental regulations (e.g. O. Reg. 419) that will affect the economic viability of some industries.
• HIEA supports appropriate separation and transition between any proposed new non-employment areas (sensitive land uses) and where industrial and manufacturing facilities and uses exist.

Question 2: Do the proposed policies strike the right balance? Why or why not?

• The balance of proposed policies may be improved by maintaining separation to better protect public health and safety, as described below.
• 1.1.3.3 requires intensification and redevelopment including brownfield sites. These actions have the potential to locate sensitive land uses and industrial/manufacturing land uses closer together. This proximity is a concern for established industries. If air quality (1.1.3.2-c), noise and industrial traffic concerns cannot be minimized then risks to public health and safety may not be mitigated (1.1.3.4). We anticipate there may be pressure to intensify development because minimum targets are required (1.1.3.5).
• We recognize and appreciate that some protection from adverse effects is provided in 1.2.6.1 where major facilities and sensitive land uses must be planned to avoid or minimize adverse effects. However, in the case of existing major facilities (1.2.6.2) encroachment may be allowed and resulting potential impacts must be minimized or mitigated. This encroachment may trigger the need for additional environmental controls that could affect the operational economic viability of some facilities. HIEA recommends that if avoidance is not possible then no sensitive land uses should encroach or develop adjacent to existing industrial or manufacturing land uses. This recommendation would further support the preservation of employment areas required in 1.3.2
• HIEA supports the provisions for separation (1.3.2.2) and transition (1.3.2.3) between industrial and manufacturing land uses and non-employment areas.
• HIEA recommends that conversion of employment areas to non-employment uses (1.3.2.4) only be allowed if adequate separation and transition areas are maintained. Furthermore, for employment areas where there are operating industrial and manufacturing uses the “notwithstanding” provision (1.3.2.5) should not be allowed without the comprehensive review (1.3.2.4).

HIEA appreciates this opportunity to comment on this important new planning policy initiative. We would be happy to discuss these issues further with you. Please contact Karen Logan at 905-662-2131 or communications@hiea.org to set up a meeting or phone call.

Regards,

John Lundrigan
Chair, HIEA Board