1. What are your thoughts on…

1. What are your thoughts on the policies that have been included from the PPS and A Place to Grow in the proposed policy document, including the proposed approach to implementation?

In general, incorporating policies from the Growth Plan opens up more opportunities for smaller urban and rural municipalities that are not located within the Greater Toronto Area. This includes the ability, should a municipality choose to define areas that are strategic growth areas or major transit station areas. The policies for these areas recognize the benefit of concentrating growth and compact form in specific areas of a municipality.

Overall, when reading through the policies and thinking carefully about the problems / restrictions of the past as well as what the Province is trying to achieve, many of the proposed changes make sense. While some may lament and dwell on the removal of local authority to be "more restrictive" than the overall PPS, others will welcome relief from what were previously seen as agents of rural stagnation.

The lessening of a number of restrictions is welcomed, most notably, providing greater flexibility to expand existing settlement areas and/or define new ones. It is clear that, within our Township, the free market has not responded in any significant way to the imposition of density policies. Forcing us to direct development towards settlement areas while at the same time restricting the boundaries of those areas has not generated tangible results in a decade or more. Clearly, a new approach is required and the proposed PPS does that.

With respect to implementation, the Township continues to work in a coordinated approach with the United Counties on Planning matters.

2. What are your thoughts on the proposed policy direction for large and fast-growing municipalities and other municipalities?

The Township of Elizabethtown-Kitley is not identified as a large or fast-growing municipality. The opportunity to be able to adapt the requirements for large and fast-growing municipalities is appreciated. There are areas of the Township that would benefit from the policy directions provided for strategic growth areas. Although the Township does not have a transit system that would fit the definition of a major transit station areas, the planning statement leaves it open for municipalities not identified as large and fast growing to adopt the policy principles within the statement.

3. What are your thoughts regarding the proposed policies to generate housing supply, including an appropriate range and mix of housing options?

The proposed changes to the policy statement requires that municipalities provide a range of housing options. As defined in the Planning Statement, the housing options relates the different typologies of dwelling units (single detached, semi-detach, multi-generational housing, low-rise apartments etc.).

The new Planning Statement removes the language from the 2020 Provincial Policy Statement as it relates to affordable housing and housing for low- and moderate-income families. Removing policy language around requirements for affordable housing is concerning. How will this impact the ability of municipalities to require affordable housing as part of a residential development project?

Policy language is softened in the Planning Statement regarding the requirement to plan for residential infill and intensification, including removing the requirement for municipalities to establish minimum density targets. The policy changes being brought in through the Planning Statement lend themselves to the creation of more urban sprawl. The lack of density requirements and removal of policies related to residential infill and intensification may lead to the creation of one typology of housing options, being largely single-detached dwellings. It is unclear how these policy changes will support achieving complete communities, which requires density to be successful.

It needs to be better understood on the expectations for collaboration with Housing Service Managers on ensuring a range of housing options. Will the Housing Service Managers establish specific targets through County Official Plans that local municipalities need to achieve?

4. What are your thoughts on the proposed policies regarding the conservation of agriculture, aggregates, natural and cultural heritage resources?

In the new PPS, the requirement has been removed for a proponent of sensitive land use to demonstrate need, etc., when it is not possible to avoid contaminants. This raises the question of what happens the other way around – i.e., when the after-the-fact proponent is the "polluter", not the sensitive use? What tests / policies – if any – apply in those cases?

The proposed changes to the agricultural and rural land policies opens up more opportunities for lot creation and development, which often conflict with the conservation of agriculture, aggregates, natural and cultural heritage resources.

The agricultural policy change will allow up to three residential lots to be created from a property that is actively farmed. This opens up a large potential of new residential severances. This further introduces more non-compatible land uses into the agricultural area, and further reduces the capacity for the establishment and expansion of livestock facilities. This policy change is concerning, and although the Township understands the desire for families of multi-generational farms to be able to create additional lots for the next generation, when this policy is combined with the PPS's overall direction that local policies cannot be more restrictive, this overall direction seems problematic – and counterproductive to the overall goal of preserving prime agricultural lands for future use. This is an area where local governments should be able to be more restrictive than the PPS (e.g, prescribing maximum lot sizes, etc.), responding to prevailing local needs and attitudes.

The remove of compatibility with the rural landscape may have a negative impact with allowing for incompatible development to be located in rural areas. The policy changes will no longer require development to be concentrated within rural settlement areas, opening up more opportunities for commercial and industrial uses to be located throughout the rural area.

Although the elimination of the requirement to use the provincially mapped Agricultural System may be seen, at first, as downloading a new responsibility to municipalities, the Township ultimately see this as a positive change. Our current OP contains language which makes use of "broad stroke" mapping (think: protected woodlands, etc.) and a corresponding disclaimer that it may not be accurate – and that field verification will be required. This can create very restrictive presumptive circumstances, based on inaccurate data, which can then only be overcome by a proponent consuming considerable resources (time and $) to correcting the errors.

The Township is concerned about, what appears to be a contradiction in the policies to protect speciality crop areas. The weakening of the threshold to "should consider" seems to be inconsistent with a policy to protect prime agricultural areas for long term use and mandatory compliance with MDS. Some clarity is needed.

Further clarification is required on the intent of multi-lot development. Is it the expectation that municipalities will now be required to permit rural estate subdivisions again?

Additional considerations for the Agricultural policy changes includes:

• Residential lot creation in the agricultural area should be scaled based on the size of the property. For example, a 10-acre parcel under agricultural production could not reasonably support three new residential lots and have enough land leftover to cultivate.
• Ensure Minimum Distance Separation is still adhered to.
• Require that new lots being created do not take good farmland out of production. For example, there are parts of properties that cannot be cultivated (e.g. bedrock at the surface). These areas should be considered first for a new residential lot.
• The residential lot creation could create opportunities for farm families to create housing for their family members.
• Clarity on appropriate development in the rural area and agricultural area should be expanded on to limit sprawl.
5. What are your thoughts on the proposed policies regarding planning for employment?

Employment uses are being more well defined to ensure that adequate lands are being set aside for uses that require greater separation from sensitive land uses. This may restrict municipalities who have used these lands for larger format commercial areas.

Further guidance should be provided to protect employment areas from being converted to non-employment uses. Additional direction should also be given to how employment areas can expand.

It is appreciated that the Province is detailing the ability to locate smaller scale industrial, or warehousing uses where they do not have an adverse impact into strategic growth areas and in proximity to residential uses. This helps achieve the policy goal of having complete communities.

Restricting the uses within Employment Areas will create non-conforming uses. Municipalities will need to review their current employment lands and decide as to whether the lands should be converted to another designation where the predominant use is commercial or maintain the uses as a non-conforming use.

6. Are there any other barriers to, or opportunities for, accelerating development and construction (e.g., federal regulations, infrastructure planning and approvals, private/public partnerships for servicing, provincial permitting, urban design guidelines, technical standards, zoning, etc.)?

Provincial permitting for Environmental Compliance Approvals for Stormwater and the review of documentation to receive a Record of Site Condition should be expedited to reduce the delay in the development process.

Allow municipalities ample time to catch up with the policy and legislative changes that are being made.

Ensure that municipalities are properly funded to support the creation of more housing units. This includes efforts to train and recruit more building officials.

It is important that settlement expansions be either initiated or approved by a municipality, and that a municipal decision to not support a privately initiated application to expand a settlement not be subject to appeal (to the OLT), as has been the approach under the current Planning Act. The alternative would lead to more speculation and uncoordinated/inefficient settlement expansions, due to possible pressure from development proponents to expand settlements and infrastructure in multiple directions. This continuous pressure would distract municipalities from completing the necessary growth and infrastructure planning that is important to sustainably accommodate growth and build great communities.

The Province needs to provide through the Bulletin identified in Bill 23 what the Affordable Housing Rates are for rental and homeownership. This is creating a barrier to ensuring that affordable housing units are being created in new developments.