Submission to the Province…

Submission to the Province of Ontario, Environmental Registry of Ontario
The Leaside Residents Association (LRA)

Re: Proposed Provincial Planning Statement – ERO posting 019-6813

Leaside is a residential and industrial/business community in Toronto. Over the past 110 years, the Leaside Business Park has been a major employer in the medium to heavy industry sectors. From the production of munitions in WW1, to auto production in the 1920’s and 30‘s, to radar and optical instruments in WW2, and from adhesive and chemical production, cement and concrete making to hardwood flooring and electrical engineering, the Park has endured.
The juxtaposition of business park and residential communities has been of great public benefit. It is important to maintain highly skilled jobs that are also closer to home, reducing traffic, and the need for even more private vehicles pumping out more CO2. This plays to the environmental challenges we face.
Up to now the Business Park has been protected though Official Plan policies and zoning bylaws, and Ontario Municipal Board decisions that have respected the Employment Lands boundaries and policies therein. However the Provincial proposal to consolidate two major planning documents in Ontario: A Place to Grow: Growth Plan for the Greater Golden Horseshoe (Growth Plan) , 2020 and the Provincial Policy Statement, 2020 appears to endanger this.
The proposed merged documents will form the basis for the Province to achieve its housing objectives. Unfortunately, the document fails to set a foundation to achieve the Province’s vision of a complete community that provides employment, community services, and all housing types to meet the current and future needs of Ontarians.

We recognize the need to expedite the planning processes, address housing
shortages (especially affordable housing) and protect employment lands, however we have the following concerns about the proposed Provincial Planning Statement and its ability to achieve the vision of the plan. We have included some suggestions to aid in improving outcomes for the plan.

Key Areas of Concern

1. The Provincial Planning Statement does not define affordable housing, and does not bring forward targets for affordable or rental housing. Nor are there any new tools being considered for municipalities to require affordable or rental housing within development plans. The plan misses the mark on the core housing issue – which is affordability - not just supply.

LRA recommends:
• that targets be set for affordable and rental housing, and
• that the Province should provide municipalities with tools to require affordable and rental housing.

2. Municipal Comprehensive Reviews would no longer be required, creating open season on employment conversions, creating uncertainty for employers, and reducing future opportunities for Ontario businesses to grow within their markets.

LRA recommends:
• that the Municipal Comprehensive Review needs to remain and be improved with a focus on the protection of Ontario businesses located within employment and business districts using the same timeline as the 5-year Official Plan Review.

3. Employment Area definition changes may result in loss of businesses and impair the
future growth of those businesses. The Provincial Planning Statement is
recommending the removal of office, institutional and film production industries from
Employment Areas which is, in our opinion, short-sighted and will have negative
consequences for those businesses and for Ontario as a business location. We need to give businesses certainty of operations and opportunities to grow in Ontario.

LRA recommends:
• that the Employment Area definition should explicitly include clusters of office uses, film production, institutional uses, and stand-alone convenience retail and services to support businesses and their employees within Employment Areas.

4. Employment targets and business locations are being sacrificed for housing at any cost, anywhere.

LRA recommends:
• that the Province needs stronger land use policy protections for all Employment Areas across the Province. The policies need to be strengthened to ensure that these lands support the economy and are viable over the long-term.

• that when conversions of employment lands occur, municipalities
should be provided with the following:
- conditional zoning that would enable municipalities to secure employment
space prior to or concurrent with residential developments that would replace
lost jobs as result of the conversion
- permit zoning conditions that would secure replacement employment space
as part of redevelopments proposing to convert existing commercial and
institutional space.

• that the Province consider securing additional employment lands to meet employment targets of a growing population. You cannot afford housing without a job and not everyone will be working from home.

5. The proposal eliminates the provincial mapped Agricultural System and permits
additional residential uses in agricultural areas.

LRA recommends
• that the environmental, climate change and local food production impacts need to be considered holistically for the Greater Golden Horseshoe before decisions on eliminating prime agriculture lands are made