• Through the Provincial…

• Through the Provincial consultation sessions, it was revealed that Health Departments had not been consulted in the preparation of the proposed guideline. It is recommended that Health Departments be extensively consulted and provided with adequate opportunity for input prior to the finalization of this guidance document.

• Many municipalities lack resources to collect and maintain the necessary data to inform local planning decisions related to land use compatibility. MECP should provide municipalities and planning authorities with the necessary data and training to assist with implementation of the Land Use Compatibility Guidance. An online mapping portal, similar to the one developed by OMAFRA to assist planning authorities and development proponents with the preparation of Agricultural Impact Assessments, should be contemplated.

• Completion of Land Use Compatibility Assessments would require co-operation from major facility owners or agencies (such as railways) to disclose information about their operations. Staff request clarification on what mechanisms are in place to ensure that the necessary information is provided, in a timely manner, in order to properly assess impacts.

• Staff have concerns around “demonstration of need” considerations in relation to reducing minimum separation distances between major facilities and sensitive land uses. While flexibility is appreciated, there is a risk that arguments on the basis of “need” may be used to circumvent siting criteria. No criteria, economic or otherwise, should ever take precedence over the health and safety of the public. Further to this, the provisions around “where no alterative exists” should be revisited and MECP should consider recommending a Regional scale evaluation of alternatives rather than a municipal.

• Staff recommend clarification be provided with regard to the use of holding symbols. Where a municipality deems it appropriate to use a holding symbol, these should only be in cases where the principle of development has been established. It would not be appropriate to apply holding symbols where the outcome of a Land Use Compatibility assessment may preclude development of the lands for the zoned uses altogether.

• Many municipalities are currently undergoing Municipal Comprehensive Reviews to meet the legislated deadline for implementing A Place to Grow next year. It is therefore imperative that further details be provided by MECP, in consultation with the Ministry of Municipal Affairs and Housing, as soon as possible on when these guidelines are anticipated to come into effect as there are implications for Land Needs Assessments and evaluation of other matters, such as employment land conversion requests.

• Staff have concerns around the implementation of monitoring by municipalities, and whether municipalities will have the resources/expertise to conduct monitoring on an on going basis. Accordingly, it is requested that further details be provided.

• Staff recommend that consideration be given to including an expiry date for Land Use Compatibility Studies to ensure the findings of the report reflect the current landscape at the time of approval.