Thank you for the…

Thank you for the opportunity to comment on the government’s proposed planning ideas guiding future development. The following comments can be used to answer the 5 questions that you have posed. I’m taking the general perspective here (based on recent past public engagement sessions such as the Bill 23 review) that this is more of a performative exercise in soliciting opinion rather than one of legitimate substance, i.e., the lowest rung on the Arnstein’s Ladder of Citizen Participation, 1969.

Let me begin by stating my credentials in reviewing and implementing planning policy of the provincial government. I have been involved with municipal planning in ON for the past 5 decades – in roles as a planning student, as a municipal planning bureaucrat, as a researcher and planning educator. In essence, the current iteration of provincial planning direction is to give an ‘appearance’ of providing land use guidance against a backdrop of MZO or MMAH ministerial exemption exception clauses when good public policy gets in the way of potential development. The fixation of the current government’s obsession to the province as a ‘place to grow’ above all else is heard loud and clear in the proposed document.

My comments here will be illustrative in extent as I do not want to waste my time and energy in explaining things when a final ‘political planning’ predetermined outcome may have already been set. With the governments’ current ‘housing crisis’ mantra, it has fixated on the trickle-down economics notion that if you provide more housing (supply) that demand will be met, and prices of housing will become more attainable/affordable. This is a fiction, especially within a fast-growing urban conurbation such as Toronto; evidence to this is found in the academic literature. The Province is faced with many challenges besides building more houses – many health care, social and environmental issues are evident that have associations to land use planning.

With the above being stated, I will now outline comments concerning proposals of the draft PPS that I find most outrageous:

A – obvious to see that a scientific co-ordinated basis for planning has now been replaced with one where the 444 municipalities in the Province can make decisions giving ‘should’ or ‘encouragement’ considerations of the Provincial prescriptions of the new PPS. Regional co-ordination planning bodies (regional planning, conservation authority planning) to guide collaborative servicing, natural heritage and watershed protection have now been largely done away with. In addition, land use planning municipal decision-making monitoring by the Province is largely absent as it now may be deemed to be unnecessary bureaucratic ‘red tape’ and a needless monitoring expense (as advanced already by the ON Auditor General).

B – a development ‘anywhere any-type’ approach to planning has been adopted to assist speculative development interests. In reading through the policy only a few targeted prescriptions for minimum levels of density have been retained in large and fast-growing GTA municipalities. Settlement boundaries may be expanded without comprehensive review, non-standardized projection methodologies for land need for residential/non-residential development can be used, and development can occur in many more places in rural locales (where development expectations are set simply by local market-demand developers’ marketing dreams).

C – a general prescription to municipally-plan into the future without a maximum end date does not make sense, i.e., proposed PPS permits municipalities to plan beyond a minimum of 25 years. Differing planning horizons for adjacent municipalities will make co-ordination of servicing, land protection for natural/ag land areas difficult to accomplish.

D – a part-positive comment to make now. It is fortunate to see that the Province has already identified the error (in the press at least) in suggesting the permission of more residential severances across agricultural areas of the Province is a mistake. The ag lands should be protected for food and agri-business production now and into the long term. Nebulous policy such as ‘promotion of an ag systems approach’ to planning will not assist in protecting ag lands. In addition, the cumulative impacts of ag land removal through additional rural sprawl are not adequately considered.

E – additional policy is required in the PPS to give direction to municipalities to the protection of endangered species habitat, and also to plan for the negative impacts of climate change (not simply change, but measures to adapt to and mitigate impacts). Addition policy is required to protect natural areas as well as to provide for new urban development.

F – the indigenous peoples 'duty to consult' responsibility down-delegation to municipalities for planning is not appropriate. There is unclear guidance in the draft PPS as to what this entails, especially in light of the new streamlined development application review requirements set out in other legislation by the current government.

In conclusion, while there is merit in creating planning guidance that avoids repetition and potential confusion between differing planning guidance documents (the current PPS and the GGH Growth Plan), the new PPS proposal does not do the job and is not appropriate to guide development in the remote/rural/urban parts of this diverse provincial landscape. The draft document overall appears to have been put there quickly with many ill-conceived notions. I would suggest the government either abandon this exercise or begin anew with all potentially impacted stakeholders involved in the review and discussion.

If interested in reading further background as to how I have formulated my observations, I would direct your attention to the following organizational links. Thanks for reading.

“By failing to plan, you are preparing to fail” - Benjamin Franklin

Ontario Nature - https://ontarionature.good.do/no-sprawl/email/

Ontario Federation of Agriculture - https://ofa.on.ca/resources/ofa-submission-to-the-standing-committee-re…

Ontario Farmland Trust - https://ontariofarmlandtrust.ca/get-involved/take-action/

The Alliance for a Liveable Ontario - https://www.liveableontario.ca/alliance-resources/new-report-province-p…