PROVINCIAL POLICY STATEMENT…

PROVINCIAL POLICY STATEMENT 2020 REVIEW

COMMENTS

• The 2020 PPS was short on enforcement provisions and as a result, while the 2020 PPS imposed several obligations on municipalities, they failed to meet those obligation and there was no enforcement mechanism of those provisions. As an example, Section 1.4.3 of the 2020 PPS stated that “Planning authorities shall provide for an appropriate range and mix of housing options and densities to meet projected market-based and affordable housing needs of current and future residents of the regional market area by: a) establishing and implementing minimum targets for the provision of housing which is affordable to low and moderate income households and which aligns with applicable housing and homelessness plans...” No municipalities did this, and there were no consequences for that failure. The 2023 Proposed PPS is also lacking any enforcement provisions and hence will likewise be toothless in regard to enforcement.

• Section 1.4.3 of the 2020 PPS has been removed. In fact, the obligations of municipalities to set and meet targets for affordable or attainable housing is totally missing from the 2023 Proposed PPS. This is a major gap in the new document and needs to be rectified by reintroducing the majority of the 2020 PPS section dealing with a range and mix of housing.

• The 2023 Proposed PPS contains no definition of affordable or attainable housing and in fact those terms have been removed from the document entirely. This must be fixed as the PPS is the perfect document to create a general definition that can be modified by local municipalities as they need. In fact, it should be an obligation of each planning jurisdiction to generate its own version of the PPS definition that fits its area, and to yearly review that definition for accuracy and effectiveness while it revies local municipal performance in meeting targets set annually.

• Schedule A being a list of large and fast-growing municipalities is missing several fast-growing municipalities in Ontario. For instance, the Town of The Blue Mountains was listed by CMHC in 2022 as the second fastest growing municipality on Canada, yet it is not on the Schedule A list! What other municipalities were missed? TBM has consistently lodged over 450 new home builds a year over the past number of years over a base of 7,500. However, none of those were in the affordable range. Council’s attempt to force developers to pay attention to the attainable or starter home portion of the housing market was frustrated by a lack of support from Provincial planning statements!

• In the Preamble, the proposed document states that “The policies of this Policy Statement may be complemented by provincial plans or by locally-generated policies regarding matters of municipal interest…” Locally-generated policies and plans must complement the PPS or there will be an inconsistent application of the PPS across the province. The word “may” should be replaced by “must”.

• In the Preamble, the proposed document states that “Official plans should coordinate cross-boundary matters to complement the actions of other planning authorities and promote mutually beneficial solutions…”. Again, in order to ensure that the PPS is consistently applied across the province and in particular, across regions, OP’s of palling authorities should be forced to coordinate across municipal boundaries, or at a minimum, municipalities be forced to publicly advise why this should or cannot be the case.

• In the Preamble, the proposed document states that “Zoning and development permit by-laws should be forward-looking and facilitate opportunities for an appropriate range and mix of housing options for all Ontarians..” Part of the reason why the province and many municipalities are facing an affordable housing crisis is that municipalities in Ontario failed to implement zoning and development permit by-laws that were not forward looking in regard to a range and mix of housing. This should be a firm obligation of municipalities and hence the wording of this section should make this forward-looking stance to be mandatory. Further, as in the 2020 PPS, municipalities should be obligated to annually set targets for affordability and measure their success in achieving those targets.

• In the Vision section of the Preamble, it is good to see that the province has identified the need for a full range of housing. However, this theme is not recognized anywhere else in the document. It would seem appropriate for a major theme to be reflected a number of times in the document body but it is not.