Comments on planning…

Comments on planning statement

I submitted most of the following comments to the office of my MLA, urging him to have three specific clauses from the Proposed Provincial Planning Statement 2023 drastically modified or preferably removed from the proposal because of the negative impact they will have on land use in rural Ontario. I also suggested that MLAs be required to read the OECD report Rethinking Urban Sprawl: Moving Toward Sustainable Cities which outlines a better way in broad strokes. It was the MLA's office that suggested that I could also submit my comments to you, so here they are.

I do agree with many points in the proposed Provincial Planning Statement.  There is urgent need for more housing in our rapidly growing province. As well, some of the proposals in the Planning Statement are valid.  However, the problems of housing a growing population will not be solved by allowing any piece of property that becomes available in rural Ontario to be developed willy nilly.  Turning over land currently or in recent food production to housing under the guide and guise of these vague proposals will set Ontario on the path to even more urban sprawl than at present.

The three proposals in the Proposed Provincial Planning Statement 2023 to which I most strongly object are:

In Section 1, Generate an Appropriate Housing Supply
* “Require municipalities to permit more housing on farms, including residential lot creation subject to criteria, additional residential units and housing for farm workers”
And in 
Section 2, Make Land Available for Development 
* Provide flexibility for municipalities to allow for more residential development in rural settlements and multi-lot residential development on rural lands, including more servicing flexibility (e.g., leveraging capacity in the private sector servicing
AND
* Provide a simplified and flexible approach for municipalities to undertake settlement area boundary expansions. Municipalities would be allowed to create new Settlement Areas and would not be required to demonstrate the need for expansion.

Urban sprawl has been an interest of mine since I was a teenager in high school geography classes and I wrote papers on the topic when I was in university.  The continuing urbanization and  gentrification of Ontario’s rural land saddens me. I often travel on Christie Lake Road to Perth, a rural road that used to be lined with dairy farms.  Now there are a couple of dairy farms and a few cornfields, but for how long?   Twenty years ago, an American visitor was gob-smacked at the black and white cows so visible along our route to Perth.  She remembered when her area of rural upstate New York had farms too.  

Along Christie Lake Road, many of those dairy farms have now been sold to people who only have horses.  We don’t eat horse meat in this country. Nor do we drink horse milk or spread our toast with horse butter.  I recently came back from Florida where butter was $2.98 per pound.  Do you know what the price of butter is in Ontario now? Supply and demand must be a factor. There is still demand but where is the supply? Wisconsin?

I learned of the Proposed Provincial Planning Statement 2023 that would replace the existing Provincial Policy Statement and A Place to Grow: Growth Plan for the Greater Golden Horseshoe from the reeve of Tay Valley who recently brought the request for comments on the proposal to the attention of subscribers to his newsletter in his recent council update. I read the review of the proposal, as well as the reeve's brief comments and the comments of some law firms to which the reeve referred.  I also read the OECD report on urban sprawl referenced above.

The OECD document repeats conclusions about the negative effects of urban sprawl that are well known, and have been well known and obvious for decades to those with even a little knowledge of the topic of land use. Surely, whoever wrote this proposal must have more than a little knowledge of the negative effects of urbanization and gentrification on rural land, and yet there they are. The proposals to which I strongly object in the statement will not solve the problem of getting housing where it is needed and wanted. Instead, housing will end up where it is undesirable, of little use to those who really need housing, and will be harmful to generations to come.

The proposal in Section 1 will lead to more piecemeal strip development across the province  with farmland valuable for its food production suffering the death of a thousand cuts.  A thousand land severances is a modest estimate.  This is the way it was before some control was put on strip development decades ago.  Before even modest restriction, every farmer who wanted a quick infusion of cash knew he could flog off some of his property to meet a shortfall or to fund a vacation or to buy the latest in machinery.  This regressive proposal is an enemy to good planning.

Without going into supportive detail that is available in any college level geography or economic textbook on this topic and in the OECD paper,  this type of development is not good for Ontario as a whole.   The parcelling off of farmer's land requires a large lot size to support a septic system.  Is that what we want?  Septic systems lining our rural roads?  In addition, strip development will encourage the gentrification of rural Ontario into “horse lots.”   In most of these cases, farmland has been taken out of production.  There is a shortage of housing in Ontario.  Horse lots in rural Ontario are not the way to increase housing stock in downtown Toronto or anywhere it is actually needed. The price is too high for too little return.

Section 2 should read Make Land Available for DevelopERS.
The proposals in Section 2 will encourage larger municipalities to poach the land adjacent to them rather than to search within their own boundaries for open land or to require different types of zoning promoting higher density.  This section seems designed to feed the symbiotic and suspiciously mutually beneficial relationship evident between politicians at municipal and provincial levels, property developers and real estate agencies in too many Ontario municipalities. 

The proposals as stated will encourage urban sprawl and gentrification. The difference this time is that it will be unrestrained and unrestricted with all the attendant evils described in the OECD document.  Even if rural land is not currently in food production, land that does not face the pressure of real estate demand is a hidden asset that current generations do not have the right to give away to property developers.  Not only will this generation, but future generations, will condemn the irresponsiblity of the proposals repeated above.

It is already too late for the area north, east and west of Toronto.  Has any analysis been done of the farms that have been taken out of agricultural production to provide a checkerboard landscape of luxury homes on large lots and middle class homes in a ribbon of septic systems and immaculate fertilized lawns. What has been the cost to Ontario’s economy and to Ontarioans.  This landscape seems harmless, but it is not.

Before farmers can sell off their land piecemeal or more urban sprawl be allowed to overtake rural Ontario, the following options must be exhausted within urban areas to increase urban density and to provide housing where it is needed and wanted.

1. The rezoning of urban residential land to much higher density levels than at present
2. Establishment of ratios of rental properties to condos when granting building permits for high rise buildings
3. The building of lower rent housing suitable for families in urban areas
4. The regulation of residential housing left vacant or for use as Airbnbs etc  
5. Complete infilling in already established urban or semiurban communities, such as villages and hamlets. 
6. Starter homes in  planned communities within the boundaries of existing urban areas
7. A requirement that property immediately adjacent to an already municipally serviced lot be added to that service even if it is in another municipality.  Details of billing to be worked out. 
8. Rezoning of areas, presently zoned for industrial or commercial uses, be rezoned to residential if a review shows extensive industrial and commercial zones are in the wishful thinking of politicians and planners

I urge you to have the clauses sited above from the Proposed Provincial Planning Statement 2023 drastically modified or removed from the proposal.  You can do better. Canada’s low urban density is embarrassing.  Give the  proposals in the OECD report a hard look.  What is it really going to take to provide housing where it is needed and wanted.  Ignore the wants of the selfish and the short-sighted,  Provide the possibility of housing, not necessarily a house, for all Ontario people.  Provide incentives for building higher density affordable rental spaces.  Penalize speculators and flippers.  Require higher density rezoning.  

The final statement will be a toolbox for providing housing for all Ontarioans. What will be in that toolbox? Will it be the hammer and nails that put housing where it is needed and wanted? Or will it be a wrecking ball to the beauty and utility of rural Ontario? Do you have the courage to choose wisely or will our beautiful province be scarred irrevocably by your actions. If these three proposals remain, there may soon be a horse lot for every middle class horse lover, but there won’t be a chicken in every pot nor a roof over everyone's head.