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Dear Ms. Bickford

I am writing to you on behalf of Environment Hamilton to share our views on the proposed amendments to A Place to Grow - Growth Plan for the Greater Golden Horseshoe. We are deeply concerned about the on-going trend we have observed where modifications to the Growth Plan are concerned. The Greater Golden Horseshoe Growth Plan must place priority on an intensification first approach in order to curb sprawl, protect prime agricultural land and natural areas, and to create urban communities that are sustainable, inclusive and climate resilient.

But this latest set of proposed changes will only serve to further unravel the progress that had been made to manage urban growth in the GGH. Instead we are seeing a frightening shift towards facilitated outward growth into rural areas. We are particularly concerned about what we are already facing here in Hamilton. The municipality is pursuing a very large urban boundary expansion into rural Elfrida. But now we are also facing the possibility of several private urban boundary expansion applications that are proceeding outside of the city's municipal comprehensive review process and as a direct result of policy changes made by the provincial government in 2019.

For so many reasons, Hamilton cannot afford to continue to expand into rural areas. We will lose more prime agricultural land, the cost to build infrastructure will be borne on the shoulders of current urban residents to a substantial degree, outward expansion will only increase our carbon footprint through the creation of more car-dependent suburban neighbourhoods - the list of concerns goes on and on. And this approach simply will not address our city's urgent need for more social housing, and more affordable housing for residents.

We have more specific concerns about the proposed changes:

1) We are deeply concerned about the proposed changes that would permit aggregate extraction within the natural heritage system even in the habitat of threatened and endangered species. We must at least commit to protecting these critical habitats!

2) We do not believe the 10 year extension of the Plan Year Horizon is justified – there is no real land demand. 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.

3) Getting Population & Employment Growth Forecasts right is incredibly important. MMAH must ensure that municipal forecasts are as accurate as possible and that consideration of distribution of jobs and population is done in a manner designed to promote the emergence of sustainable, inclusive, climate-resilient communities across the GGH. We also do not support allowing municipalities to use higher forecasts as this could facilitate more sprawl and undoes the benefits that a region-wide approach to growth forecasts brings.

4) Regarding the proposed land needs assessment methodology, we support target-based (versus purely market-based) land needs assessments that are carefully chosen, closely monitored, and that are supported by other effective policy measures designed to facilitate the desired change in how urban areas in the Greater Golden Horseshoe evolve and grow.

We thank you for the opportunity to comment on this proposal.

Lynda M. Lukasik, PhD
Executive Director

Environment Hamilton
TEL :(905) 549-0900
llukasik@environmenthamilton.org