Please accept the following…

Please accept the following comments on behalf of the Planning & Development Commission for the Niagara Region, relative to the proposed Amendment 1 to A Place to Grow: Growth Plan for the Greater Golden Horseshoe (Growth Plan) and the associated Land Needs Methodology. A formal letter with additional information is attached.

Technical Report Correction

The Technical Report for Greater Golden Horseshoe: Growth Forecasts To 2051, June 16, 2020, contained an error for Niagara Region: the employment forecasts by type was incorrect.

After alerting Hemson Consulting and the Ministry of Municipal Affairs and Housing, the error was acknowledged and a revised memo, dated June 30, 2020, was issued by Hemson Consulting. That memo provides the correct forecasts by type and is attached as Appendix 1.

The memo notes that the corrected forecasts will be included in a final consolidated version of the Technical Report, to be released after the Environmental Registry Office consultation period ends on July 31, 2020.

Recommendation: The final version of the Technical Report should reflect the employment forecast by employment type as set out in the Hemson Consulting June 30, 2020 Memo.

Growth Forecasts

Proposed Amendment 1 provides three growth forecast scenarios for each Upper- and Single-tier municipality within the GGH, including a Low Scenario, High Scenario and Reference Scenario.

Comparing the three growth scenarios against recent population growth rates suggests the High Scenario is the appropriate population and employment forecast for Niagara Region.

The Region’s population has increased an average of 6,640 people per year (1.45% annual growth rate) since 2016, which is a growth rate we support for forecasting purposes. The High Scenario estimates a similar 6,880 people per year to 2051 (1.50% annual growth rate).

We also support the High Scenario employment forecasts. Niagara is the only GGH region with direct access to the International Boarder with United States. The Growth Plan recognizes this with specific policies for the Niagara Economic Gateway Zone and Centre in recognition of the economic importance of cross-border trade. Given the importance of economic recovery from the COVID-19 pandemic, the Niagara Economic Gateway Zone and Centre should be a priority area for Provincial investment and employment growth.

Recommendation: Amendment 1 should assign Niagara Region the High Scenario population and employment forecasts.

Land Needs Assessment

In addition to Amendment 1, the Ontario Growth Secretariat released an accompanying Land Needs Assessment (ERO 019-1679).

Niagara Region staff generally support the simplified approach to land needs assessment, allowing for greater flexibility and consideration of local conditions.

However, there is concern with the elimination of a standardized approach to land needs assessments across the GGH. The benefit of the standardized methodology is consistency for municipalities, developers and Province when assessing land needs. The revised methodology, as presented, could lead to varying approaches across the GGH, impacting understanding and confidence for developers and consultants who have initiatives in multiple jurisdictions.

Recommendation: The land needs methodology should continue to provide a standardized framework as established in the 2018 methodology. The methodology should be accompanied with guidelines for modifying inputs and process for local conditions, including where simplified calculations may be appropriate.

Once an Upper- or Single-tier has approved its land needs methodology through a Regional Official Plan (and had that approved by the Province) that methodology should not be appealable. In its current draft form, the proposed LNA does not prevent other parties from using alternative methodologies. This prolongs the development approval process and ties up resources in LPAT Hearings.

The Provincially-approved Regional methodology should be identified as the authoritative source for assessing land needs. This methodology should be regularly updated to ensure it remains current and adaptive to changing market and employment conditions.

Recommendation: The Growth Plan should recognize Upper- and Single-tier land needs assessments as the authoritative source of quantifying land needs beyond Growth Plan conformity. Municipalities should be directed to update land needs assessment, at a minimum, every 5 years based on updated Census data and changing market and employment conditions.

The Community Area Land Needs Assessment requires population and employment forecasts contained in Schedule 3 be used for planning and managing growth, as a minimum.

Amendment 1, however, proposes municipalities may plan for forecasts greater than Schedule 3 if determined through a municipal comprehensive review. It is unclear if the land needs assessment is referring to the forthcoming Schedule 3 forecasts as a minimum or if an alternative forecast identified in a municipal comprehensive review would still represent a minimum target.

Recommendation: Clarify how population and employment forecasts act as minimums in the final Amendment and under what circumstances land need assessments may consider higher targets.

The methodology suggests housing needs to 2051 use a Housing Needs Analysis based on age-specific household formation rates. However, age-specific household formation rates do not take housing affordability, intraprovincial migration or non-permanent populations into consideration. Niagara’s population growth is driven entirely by intraprovincial migration and non-permanent residents who are either working or studying in Niagara.

Alternative data sources must be considered for the identification of housing needs in Niagara.

Recommendation: Allow for alternative housing forecasts based on local context, drivers of growth and housing affordability objectives to be utilized.

Alignment with Provincial Policy Statement, 2020

Regional staff support the inclusion of the new definition “impacts of a changing climate” to the Growth Plan to be consistent with the Provincial Policy Statement (2020).

Recommendation: Staff recommend the following sections be changed to use the phrase ”impacts of a changing climate” rather than similar language such as "climate change”, “climate change impacts” and “changing climate”. The use of different terms may imply a different meaning that is not intended.

Additional nuances in terminology exist between the Growth Plan and PPS related to “market demand”, “market-based” and “market-ready”.

Given the emphasis on “market demand” within the proposed Land Needs Assessment, the Province should provide better clarity and consistency of these terms in the Growth Plan and PPS to help inform the Land Needs Assessment process.

Recommendation: Establish a definition for “market demand” and revise references to similar terminology to create clarity and consistency across policy documents.

Implementation and Interpretation

Regional staff welcome the strengthened language around coordination of Plan implementation; however, clarification should be provided for specific terminology in Section 5.2.3 relating to what is meant by “engage” and “informed involvement”.

Recommendation: Use standard definitions for interpretative terms to offer opportunity to build constructive and cooperative relationships with all interested stakeholders and Indigenous communities. Planning staff look forward to the Province’s qualification and/or standardization of these terms so that the Provincial land use vision may be successfully coordinated and implemented by planning authorities.

Transition

Amendment 1 does not propose an extension to the Growth Plan conformity date of July 1, 2022. Given the impact of extended planning horizons and increased growth forecasts, the Province should revise and approve Amendment 1 as soon as possible.

Recommendation: Finalize Amendment 1 by September 2020.

Schedule Options

Multiple versions of Schedule 3 are presented in Amendment 1 for consultation.

Since the Growth Plan and PPS are focused on the end planning horizon year (2051), there is no need to include additional horizon years within Schedule 3. The Province does so in its “Mock B” versions of the draft forecasts.

Recommendation: That only the Mock B Schedule 3 layout and including forecasts (households, population and employment) within the final version of the Technical Report, Greater Golden Horseshoe: Growth Forecasts to 2051 be implemented.

Technical Report, Greater Golden Horseshoe: Growth Forecasts to 2051

The Technical Report produced by Hemson Consulting provides relevant information for establishing the land needs assessment and monitoring progress of growth and policy objectives.

However, the commentary within the Technical Report and ERO postings are contradictory. Specifically, the Technical Report provides a consistent footnote for each municipal summary page:

The housing forecast does not replicate/predict the housing mix that would be determined through each municipality’s APTG conformity work. Planning housing mixes will continue to be decided by municipalities through their local planning processes.

The proposed land needs assessment refers to housing forecasts by type as a baseline. Housing forecasts, however, are not included within Schedule 3 and only found within the Technical Report – contradicting the stated purpose of the forecasts in the Technical Report and implementation of the land needs.

Recommendation: Provide clarity on how and where the Technical Report may be used for land needs purposes and when municipalities should rely on their own forecast work.

Local Municipal Comments

Niagara Region includes 12 local municipalities. In preparing these comments, we invited local municipalities’ planning departments to provide Regional staff with comments for inclusion with this submission.

We received comments from the Town of Lincoln and the Town of Pelham, each of which are included as Appendix 2 for your consideration. We are not aware of comments from any other local municipality.

Conclusion

We appreciate the opportunity to provide comment on Amendment 1. We view the changes as a positive step in implementing longer term growth management principles and forecasts while providing greater flexibility.

Feel free to contact me should you have any questions about our submission or wish to discuss further.