October 21, 2019 Planning…

October 21, 2019

Planning Consultation
Provincial Planning Policy Branch
777 Bay Street
13th floor
Toronto, ON M5G 2E5

Dear Planning Consultation staff,

Re: Region of Peel Comments on the Proposed Changes to the Provincial Policy
Statement - ERO # 019-0279

The Region of Peel received the proposed changes to the Provincial Policy Statement (PPS)
available on the Environmental Registry of Ontario posted July 22, 2019. This letter with
detailed comments in Appendix A represents our response to the modifications, which was
presented to Regional Council on October 10, 2019 for endorsement. The Council resolution
is attached. In reviewing the proposed changes to the PPS, Peel staff are supportive of
several proposed changes which promote integrated planning and growth management,
preparing for impacts of a changing climate, increasing housing supply, protecting
employment lands, and creating complete, transit-oriented communities.
Changes or deletions which present concerns for Peel’s planning and provision of services
are summarized below. As Peel staff are in the midst of conducting the Peel 2041 Regional
Official Plan Review, staff request to work with the Ministry of Municipal Affairs and Housing
to minimize implications to Peel’s work plan achieving the intent of the PPS. In several of the
comments in Appendix A, additional information or guidance is requested to ensure
implementation is clear and consistent.

Key Implications of the Proposed changes to the Provincial Policy Statement
Inconsistencies between the PPS and Provincial Plans
There are several instances of inconsistencies in language and policies between the PPS
and other provincial plans which may complicate interpretation and implementation. It is
recommended that defined terms and similar policies remain consistent throughout the
various provincial documents. Please refer to comments on PPS 2019 policies 1.1.3.9., 1.2.4,
1.3.2.5.

Strength of Language in Certain Policies
There is a softening of the language of several policies throughout the PPS by changing
some instances of “shall” to “should”. This change has been made in several key policies that
the Region relies on for support of key programs and strategies. It is recommended that the
term “shall” be kept to ensure policy strength is maintained and that the PPS continues to
direct the planning of compact, complete communities. Regional staff are also concerned that
the strength of a number of implementation and interpretation policies have been reduced, as
they have been relocated to the preamble. It is recommended that these policies are kept in
the implementation section to ensure they are recognized as policies and not descriptive statements. Please refer to comments on PPS 2019 policies in the preamble, section 4.0,
and subsections.

Permissions for Partial and Communal Services
The servicing hierarchy of the PPS 2014 gave municipalities flexibility to provide municipal
servicing, then contemplate permitting communal services, and individual on-site services in
that order, based on feasibility in the local context and in consultation with other policies and
guidelines (i.e. D-Series). The revised language gives preference to communal servicing,
which has proven to introduce significant financial, environmental, and public health risks in
the Region of Peel. The Region has been required to intervene to take corrective measures
in multiple private communal systems in Caledon and does not support the construction of
new communal systems. It is recommended that existing policy in the PPS be maintained to
allow municipalities the discretionary ability to approve servicing with the appropriate
consideration of the above-noted risks. Further, these do not align with the Region’s
supported servicing options in the Palgrave Estate Residential Community. Regional staff
also have suggested revisions to the partial servicing policies to ensure that additional
unintended development in rural areas does not rely on partial servicing. Please refer to
comments on PPS 2019 policy 1.6.6. and subsections.

Housing Policy
Regional staff are supportive of policy and initiatives which increase the supply of housing to
meet the needs of all residents. However, some of the modifications present in the PPS 2019
may not contribute to this goal as anticipated.
Regional staff are concerned with the new term “market-based,” as it could present an
opportunity for justification of residential development types contribute less to intensification
targets. If the term “market-based” is to be included, it is recommended that a definition be
introduced which clearly includes an assessment of tenure, unit mix, size mix, and
affordability.

There are references to “fast-tracking” and “prioritizing” applications in support of housing and
job-related growth and development. Given the recent changes to the Planning Act
municipalities are facing significant pressures to meet reduced application processing
timelines, and additional prioritization can further compromise the ability to meet legislated
timelines for other applications. If it is expected that municipalities are required to fast track
specific applications, guidance is requested on what types of applications should be
prioritized and supports should be made available to share the burden on resources.

Extended planning horizons and an increase to the years in which municipalities must have
minimum residential supply have also been introduced. If new population forecasts are
introduced beyond 2041, it is recommended that municipalities be given the option to either
use the new forecasts or to complete their current Municipal Comprehensive Review
processes that are underway as this change could necessitate significant revisions to
completed work in achieving conformity with current requirements. Clarification is requested
on if additional lands are required to accommodate residential development for the additional
two years (a total of twelve years) and there is concern that Provincial financial tools that can
be used to enable municipalities to collect infrastructure funding will not be sufficient to provide additional years of supply. Additionally, provincial support in data acquisition and the
provision of standardized definitions, methodology, and tracking across municipalities is
requested. Please refer to comments on PPS 2019 policies 1.1.1, 1.1.2, 1.1.3.8, 1.4.1., 1.7.1,
4.7, definitions, and subsections.

Please accept detailed comments from Regional staff in Appendix A, as attached. Regional
staff wish to continue to be circulated on future updates to the PPS 2019 and look forward to
receiving further information or consultation opportunities.

Regards,

Adrian Smith, MCIP, RPP
Chief Planner and Director (Acting)
Regional Planning and Growth Management

(Please refer to the supporting documents for full comments, the character maximum does not allow for all comments to be entered here.)