We, the undersigned at the…

ERO number

019-6216

Comment ID

78755

Commenting on behalf of

Centre for Urban Research and Land Development, Toronto Metropolitan University

Comment status

Comment approved More about comment statuses

Comment

We, the undersigned at the Centre for Urban Research and Land Development at Toronto Metropolitan University, support the proposed redesignation of about 7,400 acres of Greenbelt lands ripe for residential development with development at or above the minimum densities for greenfield lands specified in the Growth Plan for the Greater Golden Horseshoe. It is important to recognize that these lands will be replaced with other lands being added to the Greenbelt, resulting in a net increase to the size of the Greenbelt.

Developing these lands and replacing the lost Greenfield acreage with environmentally significant lands elsewhere is a smart move to bring much-needed new housing to the marketplace quickly. The Province's intention is for the construction of new homes to begin on these lands no later than 2025.
Generally, as conditions change, plans come under periodic review and are revised to address changing conditions. This is why the Planning Act has provisions for a five-year review of municipal Official Plans. The Greenbelt Plan was first approved as a containment policy in 2005. The U.S. literature on containment policies, such as the Portland application, indicates a need to monitor land and housing markets to mitigate undesirable market impacts.

The alternative to the proposed redesignation is for municipalities to accelerate the planning and servicing of greenfield lands designated for development during 2021-2051 as part of their Municipal Comprehensive Review and Official Plan updates. However, the timeline for transforming designated greenfield lands into approved and serviced buildable sites is lengthy:

- York Region, for example, added four new community areas (greenfields) to accommodate forecasted residential growth when it updated its Official Plan in 2010. However, only one of these community areas was ready for new housing to be built eleven years later, in 2021.

- Our Centre will soon release a case study of two large greenfield community areas designated in Halton Region's Official Plan in 1999. It took 12 and 20 years to build the first housing on these lands.

We suggest it is important for the Greenbelt lands designated for residential development to be "ripe" for development. Therefore, objective criteria should be applied to identify these lands. Two relevant “ripeness” criteria are (1) lands located adjacent to the existing built-up urban area of a municipality and (2) lands where major infrastructure is available or readily available to service the lands (sewer, water, regional roads, transit).

The Province wants to increase the housing supply as quickly as possible. The inclusion of a "performance standard" on the timing of new home construction on the lands proposed for removal from the Greenbelt is a way to achieve this objective. This is a much more proactive approach than accepting the "status quo" planning process, which, as demonstrated by the York and Halton Regions cases above, have not led to timely increases in the housing supply.

Frank Clayton
Senior Research Fellow, CUR
Toronto Metropolitan University

David Amborski
Director, CUR
Toronto Metropolitan University