Comments on ERO 019-6813…

Comments on ERO 019-6813

These comments follow the wording of the proposal and refer to paragraphs as I proceed through the document:

"The Provincial Policy Statement, 2020 (PPS) and A Place to Grow: Growth Plan for the Greater Golden Horseshoe (A Place to Grow) 2019 both provide comprehensive, integrated, whole-of-government policy direction on land use planning matters including:
• Growth management, housing and economic development;
• Infrastructure planning, including sewage, water and stormwater management services, transportation, transit, energy supply and corridor protection;
• Protection and management of resources, including prime agricultural areas, aggregates, natural heritage, water, and cultural heritage; and
• Protection of public health and safety, such as mitigating potential risks due to natural and human-made hazards.
Both policy documents aim to support the achievement of liveable communities, a thriving economy, a clean and healthy environment and social equity, improving the quality of life for all Ontarians."

• Comment: The goals of these documents (PPS and A Place to Grow) are exactly what we need to achieve, so instead of replacing them with something that is intended to weaken their ability to protect farmland and natural heritage, they need to be strengthened, so that there are no loopholes allowing further destruction of farmland and natural heritage. 'A clean and healthy environment' and mitigation and adaptation to climate change depends heavily on natural heritage and farmland, and we already have destroyed a great deal of it. We need to protect what is left so that current and future Ontarians will have a 'clean and healthy environment'.
• Comment: Several studies have shown that there is already more than enough land available to accommodate housing for population growth expected to 2050 and beyond. New housing needs to be concentrated in already built up areas to create walkable, liveable communities, so people can live near where they work and shop and don't have to commute. The empty office space in downtown Toronto should be included in the potential housing supply and people encouraged to work from home so they don't have to commute. No need to 2. 'Make land available for development'. It already is.
• Comment: The current PPS and 'A Place to Grow' plans need to be tweaked to help '1. Generate an appropriate housing supply.' The focus needs to be on 'establishing (increased) minimum density targets' for built up areas, especially near public transit'. There needs to be a focus on higher 'intensification targets', and higher minima set for 'affordable housing units'.
• Comment: Ontarians, including farmers have clearly said they don't want '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 ' or 'more housing on farms, including residential lot creation subject to criteria, additional residential units and housing for farm workers'. Our farmland is precious, especially if we are expected to feed a growing population.
• Comment: Funding: a great number of the proposed policies would 'require municipalities to....'. If the provincial government plans to require all these things of municipalities, it should provide them with funding as needed to do all these things, including the need to hire on staff who are knowledgeable about natural heritage, 'watershed planning' and 'hazard lands' so that they can knowledgeably direct development away from valuable wetlands, woodlands, valley lands, grasslands and other forms of crucial natural infrastructure that human and other life depends upon. Since this critical function has been removed from Conservation Authorities, Ontarians are at the mercy of developers who are happy to destroy all our remaining natural heritage in order to profit from the sale of a few over-sized houses.
• Comment: policy needs to require all new housing to be built on already existing infrastructure to save resources and labour. This is the most efficient way to add to our housing supply. And these houses need to be smaller and more affordable, and multiple unit, affordable housing needs to be a priority. These are the most efficient ways to add to the housing supply that Ontario needs.
• Comment: the most efficient and cost-effective way 'to prepare for the impacts of a changing climate and develop approaches to reduce greenhouse gas emissions' is to protect natural heritage/infrastructure such as wetlands, woodlands, valleylands, grasslands. These are the features that contain huge amounts of carbon and the potential to soak up so much more as the years pass. Destroying a wetland releases tonnes of GHG into the atmosphere and removes the future potential for absorption. These features are crucial to our future climate change mitigation strategies.
• Comment: one of the best ways to preserve 'a healthy environment' for Ontarians is to preserve farmland. So requiring municipalities to 'to designate specialty crop areas and prime agricultural areas, and to protect specialty crop areas and maintain minimum separation distances between livestock operations and houses, and promote an agricultural systems approach to support the agri-food network' is excellent. But the provincial government should also retain these same policies at the provincial level and protect good farmland like the Duffins Rouge Agricultural Preserve so that our farmland is protected and future Ontarians will have local sources of food as climate change brings about reductions in food supply from geographies threatened by climate change such as California, Florida, and other big sources of our current supply.
• Comment: Conclusion: Policy that truly protects farmland and natural heritage lands is what is really needed in Ontario, along with restoration of Conservation Authorities with strengthened powers to accomplish this work. Natural heritage lands and farmland are what support our healthy lifestyles, along with the biodiversity of life that they support. Without these crucial resources, human life in Ontario will not be healthy, prosperous or enjoyable.