We support the submission of…

We support the submission of the Simcoe County Greenbelt Coalition:

"Our greatest concern is that many of these changes will reduce or eliminate altogether a planning regime that ensures consistency across municipalities, strong protection of farmland, climate action and protection of shared watersheds. These new proposals:

● Eliminate policies that were designed to rein in urban sprawl, thus protecting nature and farmland, such as greenfield density targets and mandatory intensification targets
● Allow municipalities to expand settlement areas without a comprehensive review of associated infrastructure needs or potential impacts on farmland, watersheds or natural areas
● Remove the policy for and direction of “affordable” housing making it harder to track, measure success and hold developers accountable to within-site plans
● Force municipalities to allow three lots to be severed from every farm including in Prime Agricultural areas. This is a policy that all farming organizations in Ontario have jointly opposed as they see it as weakening farmland protection and preservation of the agricultural systems.
● Exempt lands given a Minister’s Zoning Order (MZO) from complying with provincial policies and official plans—essentially overwriting local, community-developed plans.
● Force municipalities to enter into servicing agreements with developers even in lands that were not a part of their designated growth areas or infrastructure that wasn’t included in capital plans.
● Weaken the commitment to watershed planning and removes watershed planning requirements before urban boundaries can be expanded. In a region like ours where groundwater is still the main source of water for daily use for most municipalities, this is a dangerous change.
● By eliminating the Growth Plan, many climate actions that were related to planning, such as policies that encourage more compact, transit supportive designs, would also be eliminated in favour of weaker policies that put speed of construction before smart housing supply that increases affordability, healthy communities and climate action.

On top of that no policies have been released for review that specifically address Natural Heritage Systems (NHS). Strong, coordinated policies can help support a regional natural network that continues to function to provide clean air, water and green spaces. Weakened or eliminated policies could put many wetlands, forests, shorelines, watersheds and corridors in jeopardy.

Alone this is troubling, but combined with the proposal to remove Simcoe County as a planning authority and reducing the involvement of Conservation Authorities makes this proposal a direct threat to the health, connectivity, equity, affordability and climate resilience of many communities across Ontario.

As an example, lower tier or single tier governments do not have the ability to track and support the established Natural Heritage Systems and Agricultural Systems identified in provincial mapping beyond their boundaries. Who will do this critical work to ensure these systems are protected, enhanced and maintained?

Transferring planning power and authority to local municipalities with strong-armed provincial caveats (Ministerial powers to override local plans, MZOs, forcing capital agreements with developers, financial audits) while also removing expertise supports (Conservation Authorities, regional governments) appears to be a successful formula to further constrain municipal efforts to build housing that is affordable and climate resilient and instead opens up the mentality of “build anything, anywhere, at any time”.

From our perspective, this policy needs to be rescinded and more thought needs to go into how to increase the type and scale of housing needed at the local level. It also must be mentioned that forcing municipalities to increase supply is not the issue."

In sum our recommendations are as follows:
● Abandon this initiative in lieu of more consultation with municipalities, Indigenous governments, community organizations and other stakeholders to ensure that unintended consequences of these policy proposals are mitigated or avoided
● Abandon plans to dissolve Simcoe County Regional government and instead give it more authority to support the various municipalities within the region that lack staff, financial resources and taxation base to provide housing in the right places in the right way. Further, recognize the impacts and costs of removing this level of government outright. In 2022, Simcoe County provided the following services across the region to the benefit of municipalities that would not be able to afford these services on their own:
○ Paramedic services - $67M
○ Long Term Care and Senior Services - $92M
○ Children Services - $105M
○ Community Services including poverty reduction, immigration supports and homelessness prevention - $19M
○ Social Housing - $91M
○ Transportation and Engineering - $77M
○ Solid Waste Management - $85M

How will municipalities be able to take on these costs without pooling resources at a regional level?

Consider the needs of smaller municipalities that do not have the resources to implement the necessary changes to provide more housing quickly including staff resources, expertise, and taxation base. Combined with the removal of development charges for some housing projects and increased cost of infrastructure, there seems little hope that these proposals will do anything more than clog up an already strained system.

Policy proposals such as what is being discussed in ERO 019-6813 have broad and long standing impacts to our built communities, our public health and our shared financial future. We hope that the review team fully appreciates the gravity of these decisions and considers next actions carefully.

And we support the position of the Ontario Public Health Association:

"In any proposed changes to the PPS, the province must/should include policies that:

1. Reintegrate health and well-being concepts in the Vision and in Chapter 2, “Building Homes, Sustaining Strong and Competitive Communities”, with the goal of creating healthy communities that enable people to thrive

2. Strengthen policies that will help communities mitigate greenhouse gas emissions and adapt to climate change

3. Integrate affordability targets for low- and moderate-income households to support equity and promote housing affordability for all

4. Mitigate exposure to incompatible land uses and harmful levels of pollution

5. Prevent unsustainable urban expansion and fragmentation of agricultural lands

6. Strengthen policies to protect and enhance natural heritage features in recognition of the vital function of ecosystem services for health, well-being and climate-resiliency"