The following comments are…

The following comments are provided by myself, Devon McCloskey, RPP, MCIP, Manager of Planning Services, City of Thunder Bay.

As observed by many other planners (OPPI) and Municipalities in Northern Ontario such as Sudbury, several policies within the proposed 2023 PPS are contradictory.

I am supportive of policies that promote compact and complete communities, with mixed uses that are serviced with full urban municipal services, but I am not supportive of policies that would open up residential lot creation in prime agricultural areas, or lot creation in rural areas on private communal or partial services within rural areas,.

I am also concerned that creating and expanding settlement areas without substantial justification, will lead to further pressure on municipal government to approve development in unserviced areas which is not financially viable and risks greater hardship in infrastructure planning, as well as greater burden on tax payers and asset management, negating efforts to resolve existing infrastructure gaps, and ultimately furthering social disparity between lower and higher income earners.

Thunder Bay, like many northern municipalities is not short on land supply, and needs stronger policy support to encourage compact development. Policies that allow for single serviced or partially serviced developments could be said to have been phased out already and should now be eliminated. Justification for partial servicing based on no negative impacts is dependent on D-Series Guidelines which do not properly contemplate small lot development on partial services.

If rural lot development is to be allowed in prime agricultural areas, rural lands within northern municipalities, which produce vegetables, hay, and pasture land, although not as productive as Southern Ontario farmland, are also vulnerable to speculative exclusive single detached residential development that is inefficiently planned and proposed on private services. Meanwhile, these lands are agriculturally productive and providing food to local citizens a practice that supports low carbon activities, food security, health and well-being.