Thank you for providing the…

Thank you for providing the opportunity for the County of Bruce to comment on ERO Posting 019-8462 on the proposed 2024 Provincial Planning Statement through the Environmental Registry.

Bruce County and our eight local municipalities are committed to supporting the province’s goals to increase housing supply, bring more affordable housing to market and streamline the development process to get more homes built faster.

Bruce County delivers planning services to our eight partner municipalities and delivers a range of housing services, including the construction of County owned/operated housing.

Throughout the recent changes to the Planning System, Bruce County and its partner municipalities have been advancing initiatives to increase the supply of affordable housing by updating planning documents and preparing a new County Official Plan.

An Official Plan Amendment implementing Growth Management policies and new population projections into the Bruce County Official Plan was adopted in October 2022 and is before the Minister of Municipal Affairs for approval. A further Official Plan Amendment to the Bruce County Official Plan to enable implementation tools under the Planning Act for the County and Local Municipalities and to simplify and streamline Implementation policies was adopted and approved by Bruce County Council in February of this year.

Bruce County delivers planning services to our eight partner municipalities and delivers a range of housing services, including the construction of County owned/operated housing.

This letter summarizes proposed policy changes to the 2024 Provincial Planning Statement (PPS), which is proposed to replace the currently in-effect 2020 Provincial Policy Statement. This letter outlines PPS policy changes that Bruce County and its partner municipalities see as beneficial and supporting the supply of affordable housing in the County. It also highlights areas of concern that will limit our ability to effectively plan for complete communities and protect natural and agricultural resources.

Overview of Comments on the Proposed 2024 PPS:

4.3 Agriculture:
• Agriculture is a pillar of the economy in Bruce County. The protection and support of the viability of the agricultural industry in Bruce County and across the province is central to the economic success of Ontario and the well-being of its residents.

• The proposed PPS requires that up to two Additional Residential Units (ARUs) shall be permitted where a residential dwelling is permitted on a lot in a Prime Agricultural Area. Requirements that the new ARUs be “limited in scale” and “minimize land taken out of agricultural production” have been added. (4.3.2 Agriculture Permitted Uses)

We understand the premise of these changes to be to provide housing for farm workers and for the next generation of farmers. 2021 OFA statistics for Bruce County report 1,946 farms, and 5,180 farm jobs. Dozens of dwellings surplus to agriculture are severed each year in Bruce County. Farms in Bruce County can already construct an ARU, and construct temporary farm worker accommodation, within the existing farm building cluster. This provides opportunities to address specific housing needs.
Mandating two additional dwelling units on agricultural land may further drive up the price of each parcel of agricultural land, not in relation to its agricultural potential, but in relation to residential development potential.

We recommend that the wording of the proposed new policy be changed to say “up to two additional dwelling units may be permitted”, instead of the current language of “shall be permitted”.

The prosed policies that require clustering of ARUs and minimization of impact to farmland are appreciated.

• The proposed PPS provides new policies for surplus farm residence severances. This type of severance is limited to one residence to be severed per consolidation.
The intent in permitting only one residence to be severed per consolidation appears to be conservative. If the intent is to be more restrictive and protective, we believe it would be helpful for the PPS to provide a definition of what constitutes consolidation. We are concerned that a loose interpretation could lead to farmland fragmentation, especially on farms with Additional Residential Units (ARUs).
The surplus severance policies of the proposed PPS address ARUs, indicating that these can be severed if the requirements for surplus severance are met. Bruce County is concerned that this approach would facilitate multiple lot creation from one farm, if the farmer purchases multiple properties and/or has future consolidations.

It would be preferable if PPS policy required any ARUs to be severed with the surplus residence, rather than permitting a maximum of one residence to be severed. When the clustering policies are considered, along with considerations for shared driveways and septic systems, severing the ARU with the main residence will be more practical in many cases.

We are concerned that the approach proposed in the 2024 PPS would facilitate fragmentation of the agricultural lot, introducing additional land use compatibility issues with multiple clustered individual lots.

Further, farm residences with an ARU inside the dwelling would be ineligible for surplus severance. Or, existing additional dwelling units may be eliminated inside farm houses to become eligible for surplus severance.

We appreciate the intent of the surplus farm residence policies which allow farmers to convey residences that are surplus to their needs. However, the policies, as written, would require the farmers with ARUs to retain residences that aren’t needed.

• Proposed PPS policy changes to require an “agricultural systems approach, provide direction for the use of Agricultural Impact Assessments and support the agri-food network are all positive and welcomed.

2.8 Employment:
• Narrowing of the definition of Employment Areas will remove of protection for municipal business parks which include lighter industrial uses, institutional uses and offices. This may pose economic development challenges for municipalities. Existing planned land uses and infrastructure may have to be reconsidered in municipal Official Plans and further expense may be incurred if new Employment Areas need to be identified.

• Considering planning authorities may designate lands for employment beyond a 30-year horizon, additional clarity is needed to help municipalities determine the appropriate supply of Employment Lands that would be required over the longer term. A significant surplus of employment lands would be necessary to justify removal of employment areas.

Although the proposed policies give municipalities more flexibility, infrastructure and servicing costs for industrial lands come with a high cost to municipalities. Slower growing rural municipalities may find the infrastructure costs of a larger supply of Employment Lands that distinguishes between protected employment lands and the broader supply of areas where people work difficult to financially manage.

Bruce County has several business park areas where mixed uses are permitted and there is considerable pressure to permit a high proportion of residential development relative to employment; at the same time, Bruce County often sees multiple extension requests for draft approved residential subdivisions. Flexibility in conversion of employment lands, where appropriate, can be achieved without also narrowing the definition of employment.

2.3 Settlement Area Boundary Expansions:

• Municipal comprehensive reviews are proposed to be removed as a requirement for settlement area boundary expansions. The removal of the concept of a municipal comprehensive review is a significant change, as this type of review has been in place since the 2005 Provincial Policy Statement. Overall, the additional flexibility for municipalities to be able to consider settlement boundary changes at times outside of Official Plan Reviews is considered by Bruce County Council as a positive change. The ability to consider boundary expansions outside of the framework of population projections based on regional market areas will assist member municipalities and the County of Bruce in responding to the unique needs and demand for growth of each of our settlement areas that cannot be reflected through a regional market study.

• Tools such as intensification targets and density targets, which Bruce County municipalities have utilized in settlement areas to effectively manage growth, affordable housing and servicing, have been de-emphasized in the 2024 PPS. The removal of requirements to use these tools to manage growth within settlement boundaries make the policy framework less clear for how municipalities can “right size” their settlement areas, plan for infrastructure investments, and encourage appropriate density.

• The County of Bruce continues to encourage the province to recognize the importance of infrastructure to facilitate growth in settlement areas. The need for funding support for infrastructure to keep up with the demand for settlement area boundary expansions is critical for municipalities. The proposed policies in the PPS have the potential to put significant demands on municipal infrastructure such as sewage and water systems, roads, bridges and stormwater. Supportive provincial funding and streamlined approvals for replacement and new infrastructure is key to municipalities being able to accommodate forecasted growth.

Indigenous Consultation

• Bruce County appreciates the recognition in the proposed 2024 PPS of the contribution of Indigenous communities’ perspectives and traditional knowledge, including the direction to have meaningful early engagement and constructive co- operative relationships.

2.1 Planning for People and Homes and 3.1 General Policies for Infrastructure and Public Service Facilities

• Bruce County supports the provincial interest in creating complete communities. Recognizing the importance of growth management and its impacts on schools and childcare facilities is key to building complete communities. The addition of policies to encourage collaboration between schoolboards and planning authorities is welcomed.

There is a need to extend the collaboration between provincial ministries, such as Municipal Affairs and Housing and the Ministry of Education to ensure there is alignment between the growth Ontario is planning for and the schools and childcare facilities needed to support growth and complete communities.

Bruce County appreciates the recognition that the long-term prosperity and social well-being of Ontario depends on planning for complete communities for people of all ages, abilities and incomes.
The above comments outline our most significant areas of comment and concern from a Council perspective. Further comments on finer detailed aspects of the proposed Provincial Planning Statement are provided below.

Detailed Policy Comments and Recommendations

Section 2.1 Planning for People and Homes:

The reduced emphasis on intensification coupled with more flexibility for boundary growth may lead to increased infrastructure costs and long-term liabilities for municipalities if not carefully implemented.

Section 2.4 Strategic Growth Areas:

The 2024 PPS policies do not restrict the identification of Strategic Growth Areas to large and fast-growing municipalities. Bruce County welcomes the opportunity to support intensification, mixed use development, a range of housing options and efficient use of public infrastructure in parts of the County, where appropriate.

Section 3.2 Transportation Systems

The policy that refers to requiring a land use pattern, density and a mix of uses that minimize the length and number of vehicle trips and support current and future use of transit and active transportation is proposed to be deleted. This indicates a shift in priority away from reducing vehicle trips, which is contrary to the notion of creating complete community and addressing transportation as one of the major sources of climate-changing emissions.

Section 3.6 Sewage, Water and Stormwater Servicing

Changes to servicing policies appear to remove limitation on individual onsite services in settlements to infilling and rounding out, however partial services remain limited to infilling and rounding out. This would appear to suggest that growth in communities where only one service is available should not make full use of that service but should instead proceed on the basis of full services (at significantly higher cost) or private services (at significantly lower achievable density).

Clarification from the province is needed to understand if the intent is to prevent infilling and minor rounding out on private services or if the intent is to allow full scale development on private services in Settlement Areas.

Additional wording has been added to the latest version of the PPS to clarify that partial services are allowed within rural settlement areas where new development will be serviced by individual on-site water services in combination with municipal sewage services or private communal sewage services, which is helpful. However, the apparent unrestricted use of individual on-site sewer and water where municipal services are not planned or feasible (not restricted to infilling and rounding out) remains to be proposed in the 2024 PPS.

The recognition that centralized and decentralized servicing systems can both be considered as municipal sewage and water services is a good addition to help facilitate municipal communal servicing solutions.

Policy wording for stormwater management planning is proposed to change from ‘the long term’ to ‘their full life cycle’. This change may not adequately consider ultimate replacement costs.
There are several references in the proposed new PPS to “ensuring appropriate sewage and water services”. With an increasing recognition of the potential for individual onsite sewage and water services to play a role in meeting housing needs, provincial direction on how to ensure appropriate sewage and water services are to be provided, in the context of individual lot creation proposals, would be beneficial. The existing MECP D5-4 guideline does not appropriately address individual lot creation, multiple uses on a lot, or the role of advanced technologies, resulting in variable approaches across the province.

Section 4.2 Water

In removing the word “municipal” it appears that the responsibility of planning authorities to restrict development and site alteration has been expanded to protect all drinking water supplies, not just municipal drinking water supplies. Please clarify if this is the intent, and if so please provide appropriate resources and training to address this new responsibility.

Section 4.6 Cultural Heritage and Archaeology:

Cultural Heritage
On balance there appears to be less protection overall for cultural heritage resources in the proposed 2023 PPS. The language around protection of heritage property has changed from using the term “significant” to using “protected” to reflect Bill 23 changes that focus only on protection of designated heritage resources. The direction to consider the development of cultural plans for the protection of “cultural heritage” has been removed. The protection of heritage resources continues to be important to our communities in Bruce County, as it helps define the uniqueness of our towns and villages, as well as supports tourism experiences within the County.

Archaeology
With respect to the conservation of archaeological resources “significant” has been removed; thus it would appear the direction expands the requirement to conserve all archaeological resources, not just those deemed to be significant. Clarification would be appreciated to understand how this changes current practices for protecting archaeological resources. Updated guidance and training from Provincial Ministries around the implementation of archaeology policies of the Provincial Policy Statement is requested, as are clear opportunities to address the costs of conserving archaeological resources that are uncovered through assessments related to growth and development.
Planning Authorities are now encouraged to develop Archaeological Master Plans for conserving archaeological resources. Generally, Bruce County is supportive of the proposed policy changes for archaeology. The direction to develop Archaeological Master Plans affirms the efforts that have already been undertaken in Bruce County.

Early engagement with Indigenous Communities is now a requirement of the PPS, to ensure their interests are considered when identifying, protecting and managing cultural heritage and archaeological resources, built heritage resources and cultural heritage landscapes.
Bruce County has and will continue to build a positive relationship with our indigenous communities focused on early engagement on land use planning matters.

Section 6.1 Implementation and Interpretation:
When implementing the Policy Statement, the Minister of Municipal Affairs and Housing may make decisions that take into account other considerations to balance government priorities.
This gives the Minister a broader range of considerations when implementing the PPS. It implies the Minister may not be held to the same standard as other planning authorities when making decisions on Official Plans.

The PPS requires planning authorities to keep their zoning by-law up to date with Official Plans and the PPS by establishing permitted uses, minimum densities, heights and other development standards to accommodate growth and development. A decision of a local planning authority must be consistent with the PPS even if the Official Plan has not been updated.

Consideration should be given to the successive legislative changes that have been introduced within a short period of time. Planning Authorities need time to update Zoning By-Laws and Official Plans. It is recommended that workshops and training be offered by Ministry staff to help planning authorities understand the new changes prior to implementation.

Section 6.2 Coordination

Planning authorities shall undertake early engagement with Indigenous communities and coordinate on land use planning matters to facilitate knowledge sharing, support consideration of Indigenous interests in land use decision making and support the identification of potential impacts of decisions on the exercise of Aboriginal or treaty rights.
These changes appear to be positive, but Bruce County would recognize the comments of Indigenous communities as being most relevant to whether these changes are to be supported or not.

Summary

Bruce County Council and staff appreciate the opportunity to provide input on the government’s efforts to address the need for housing in Ontario through the proposed 2024 Provincial Planning Statement. We encourage the province to work with groups such as AMO and the Warden’s Caucuses, as well as rural and small urban communities to engage in meaningful dialogue on the proposed changes and their implications for municipalities across Ontario.