Thank you for the…

Thank you for the opportunity to comment on the government's proposed methodology for calculating land need within the Greater Golden Horseshoe (GGH). The methodology is a simple trends analysis forecast of projecting market demand for new development in the area. There is also an allowance made that promotes the availability of surplus lands to allow a benevolent party to create affordable housing, i.e., based on simple economics theory that more supply equals lower costs for a product.

The method treats land throughout the GGH as a simple commodity. It does not deal with the more subtle dimensions of the space for creating healthy and resilient communities. The 'bigger is better' mantra embedded in the methodology is not borne out with objective evidence to large communities around the world. The need for affordable housing is an insatiable requirement in any large growing area, and providing more land does not equate to providing more affordable housing opportunities - it is an income and cost societal redistribution issue, not a land supply issue.

It is uncertain also why the Government is locking in the numbers as targets for growth; since when is the Government able to see the future and accurately predict where/when/how/why growth should occur. The proposal being put forward provides a consistent based for land calculation, but the Government is proposing to add policy layers (dictating a minimum land supply) that is NOT warranted.

Thanks for reading.