The City is supportive of…

The City is supportive of the goal of building housing that is affordable and attainable through increasing supply, however this cannot come at the detriment of creating and supporting the enhancement of complete communities, including the critical supports that are necessary (parks, community centres, jobs, public service facilities, etc). While there are opportunities to streamline the current policy framework, any new framework must still address the wide range of matters of provincial interest enshrined in the Planning Act, the PPS and the Growth Plan. Planning policy frameworks and the resulting decisions need to keep all of these critical considerations in balance. From health and safety – not just from environmental and hazard lands perspective but compatibility with the introduction of sensitive land uses to economic viability and protection of employment areas and mix of employment opportunities.

Thinking about the exercise overall staff provide the following high-level points for consideration:

-Staff note that it is very challenging to focus on a single-issue review (Housing) of documents that, by their nature, are meant to consider and have regard to balancing a wide range of policy matters including matters of provincial interest.

- Staff want to reinforce the importance of the PPS and the Growth Plan as documents that each address a distinct lens on provincial planning matters, and therefore both need to be considered comprehensively. The new policy framework must consider the whole range of matters of provincial interest while still allowing flexibility for unique local context.

- The wide range of changes proposed in Bill 23, its associated ERO postings, and future proposed regulations will require consideration in the development of this streamlined document. Bill 23 begins to suggest the prioritization of the matters of Provincial interest which are not currently organized in a hierarchy in the Planning Act. The Province should assess this as it reviews these documents and considers other changes that may be required.

- The Province is encouraged to build on the success of a Place to Grow’s focus on considering decisions as part of a broader system (natural heritage, urban structure and growth management, infrastructure, employment, agriculture). This will be important in particular where the Upper-Tier role in planning may be changing, requiring all individual decision makers to consider local, regional and broader impacts of incremental decisions.

- The PPS highlights that:

The official plan is the most important vehicle for implementation of this Provincial Policy Statement. Comprehensive, integrated and long-term planning is best achieved through official plans.
Staff recommend that this direction be maintained in the streamlined document.

- A clear set of standardized rules will be necessary to support municipalities in achieving the objectives of approving homes faster and increasing housing supply including, among other things:

o Providing clarification regarding the use of the the Land Needs Assessment Methodology;
o Developing a standard source and define the role of growth forecasts for all municipalities;
o Considering the Regional Market Area and local municipal residential land supply and approaches to deal with variation and unique local context, such as a municipality, like Burlington, which has a fixed Urban Boundary defined by the Greenbelt Plan and the Niagara Escarpment Plan.

- The Province should carefully consider that significant and ongoing changes to the fundamental building blocks of planning could have the unintended consequence of slowing down the creation of new housing units. Each change requires comprehensive processes at the local level to update impacted policies, regulations and by-laws in a sequential manner (e.g. zoning by-laws cannot be updated until revised Official Plan policies are in effect), which may be further extended by lengthy appeal processes. Should the Province move forward with this new document it may be critical to consider opportunities to develop transition provisions and other means such as protection from appeal to support municipalities in timely implementation.