I have the following…

I have the following comments on some of the proposed changes

1. Increasing the Plan Horizon Year to 2051

The Proposal to extend the plan horizon year in the Growth Plan from 2041 to 2051 not justified – there is no real land demand that necessitates this change. Extending the Plan Horizon Year will only facilitate more urban boundary expansions – especially in municipalities that are not striving to intensify the built up area and increase the density in greenfield areas. We know from studies that the existing "white belt" around cities provides significant additional untapped areas for development. Other studies of "the missing middle" has shown there are other strategies to provide additional housing. The Ministry should not be succumbing to developer pressure which stems from a desire to convert cheaply acquired agricultural land into high value residential housing lands. This further causes expensive build out of infrastructure (water, sewer, schools, rec centres, ) that municipalities can ill afford and leads to congestion causing urban sprawl.

2. MMAH is also proposing that municipalities be allowed to use higher forecasts through the municipal comprehensive review process.

Using higher forecasts suggests that the forecasting is being played to serve developer needs. MMAH should use accurate forecasts that take into consideration of distribution of jobs and population in a manner designed to promote sustainable, inclusive, climate-resilient communities across the Greater Golden Horseshoe region. Individual municipalities should not be enabled to use their own "higher" forecasts which will encourage more sprawl. They should instead follow proper regional-wide forecasts which are more likely to have balanced regional growth.

Overall, MMAH should be looking deeply into the the ways in which housing needs can be met in the face of Government (Fed & Provincial) commitments to meet greenhouse gas reductions and the impact on our food systems on climate change. These suggest the essential needs of preserving agricultural lands and limiting sprawl which impacts those lands and encourages additional vehicle emissions by driving up commuting distances.