Comment
Thank you for reviewing these comments.
I find it hard to believe the creators of this policy statement have any idea of how badly our communities are affected by it. Though well intended the process of implementation makes the worst of all worlds. You are not creating mix use vibrant transit supportive communities. You are transforming many areas into endless rows of generic condos all car based. This while displacing local services into ever more concentrated commercial centers away from population. This is not transforming transportation, but just packing every more cars in a tighter areas that were never designed to support them. You have invented the �high-rise� car based subdivision.
One of the main theoretical advantages of the PPS is shifting away from cars. However, Far from making cars less needed, they are every more needed and in every more traffic. Municipal implication of �Places to Grow� and this PPS is little more than declaring commercial and employment space that previous generations of planners localized all around, should now just be re-declared �high-density� to make way for high-density condos. They can do nothing else as many of the planning areas are already build out. The PPS/PtG does not distinguish what the area actually is, it just insists more people is better. This replaces previous high-quality and flexible commercial spaces used by the local community and associated parking into a couple 10 by 10 offices with one parking space out front. Displaced services then just move into larger car focused mega-power centers away from almost everyone. There is no aspect of the PPS that retains real commercial zoning, it just throws commercial zoning into competition with residential zoning. This is devastating to local business.
Previous planners attempted to create a local mix of population, employment and business in an area. However the the PPS just insures �high-density� residential is considered superior to commercial and employment at the LPAT. Game set match for city staff planners � they now plan for nothing but how fast there community can be nothing but high-density condos.
The PPS in practice operates totally opposite to it's stated goals.
The Problems:
1) In practice there is no due process or consideration of anything but �site optimization�.
The Provincial Policy Statements sets out a set of principles E.G. �infill, efficient user of resources� that are considered �good� in a one way direction with no upper bound. Since no offsetting factors are emphasized � none are considered. It's read as if more people in an area are always better than less and developers and consultants have simply come to �site optimization�. Which is just as may people as you can possibly fit on any piece of land ignoring if it makes sense or not. Thus the planning process, municipal councils, public consultations, public comments and planning staff are all involved in an elaborate farce.
The actual decisions are made by LPAT tribunal judges (often with no knowledge of the local area) going off the single dimensional principle �more is better� written into the PPS. Staff then endlessly replicate this decision by informing council that this is the only decision or factor that represents �good planning.� Thus councils decision is limited to if they want to give up now or spend a lot of money and loose at LPAT. The opinion of the public is not considered �expert opinion� and only �land user planners� may testify what is �good planning.� There is no way in practice for council or the public to affect anything. We might as well dispense with all of these municipal staff positions and replace them with a single staff trained in the use of the greater than sign. It needs written so municipal staff and council can leverage local knowledge and balance multiple factors against density. It's written as if PPS knows whats better in all cases; more population groping mindlessly for some supposed density that will make transit work in some unknowable time frame.
2) No differences between communities.
Overly prescriptive PPS edicts are making every community exactly the same as the one next door. There is only one way that �good planning� can occur. From Tobermory to Toronto developers can use the exact same �theory of development� to override local authorities. Tobermory does not have transit supportive densities so we should probably build a 50 story condo on the lake. Though the developer uses the idea of �transit supportive densities� as a rationalization for the building � really it's just about producing �views� for a few people.
Natural landscape, charming down towns and historic villages get butchered wholesale. There is only �one� ideal community as set out but the restrictive PPS. The vision is a generic �world design� glass condo trench everywhere. Once even one high building gets built developers use that height to justify it on neighboring properties. Local official plans just get overridden. This is happening in small communities all over the province in places that will never be near significant transit. The �theory� that applies to communities near rail; the PPS imposes on communities near no transit as all. Communities should be able to keep charming historical areas, open sky, lake views and escapement views as a central feature of the community.
3) There are no offsetting quality of life concerns.
In practice green space, trees, parks, open space are just getting removed wholesale. Treed and green areas are now refereed to �underutilized space.� Green and open areas are not even mentioned in the PPS as of value. If you are forcing people into high-density condos then you would think public open green space would replace back yards for families. As it does in places like New York. Quite the opposite in our case the next generation of families apparently plays on balconies or in 10 by 10 mini parks. You are simply running down the quality of life Ontario wide. How long it takes to work seriously impacts people lives. However the PPS makes no note of this or other quality of life factors at all.
4) The structure allows all deflection of responsibility.
As problems mount up local staff and Councilors are always blame less. The �Provincial Policy Statement� is to blame and the terrible conditions you see now were �moderated� by us. It would have been �much worse� if we had not stepped in and negotiated a �horrible� deal down to a �terrible� deal for the community. I realize this lets PPS creators hide how terribly this plan affects communities, but it also stops from you receiving reality. I suspect higher levels can always just look at a spread sheet showing greater densities an declare victory.
5) Promoting racism.
At meeting after meeting when people ask why they can't keep the local grocery store or pub or shopping plaza the answer it the same; �We need room to build apartments for immigrants.� Your local down town, businesses and houses need bulldozed to make way for generic glass condos. Seems pretty straight forward why Canadians view of immigrants is becoming less positive. It's because of the refusal in the PPS to just provide housing types wanted by the market and just insisting that high-density apartments will be where people now live �like it or not.�
Suggestions:
1) Remove the LPAT mechanism entirely. Trust that the massive amount of money going into localized land use planning professionals know what they are doing.
2) Loosen the language to provide flexibility. Setting the same �top priority� for every community across Ontario is insane.
3) Restore the primacy of local �Official Plans� in matters of height, lot coverage and density.
4) Allows towns to �lower heights� on existing plans and prevent tall buildings in official plans in historical areas and small towns away from rail hubs.
5) Intensification projects should not be be done at the expense of compatibility testing with residential properties.
6) Allow municipalities to require 100% commercial first floors with commercial venting and flexible unit sizes in buildings. This is particularly needed in down town areas.
7) Remove trading park land for a cash payment. All new builds funding should be pooled into and only usable to expand public green space.
8) Allow municipalities to place height restrictions where buildings will impact historic down towns, block water or escarpment views.
Submitted October 21, 2019 2:35 PM
Comment on
Provincial Policy Statement Review – Proposed Policies
ERO number
019-0279
Comment ID
35602
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