The Grand River Conservation…

ERO number

019-8462

Comment ID

98774

Commenting on behalf of

Grand River Conservation Authority

Comment status

Comment approved More about comment statuses

Comment

The Grand River Conservation Authority (GRCA) recommends the following feedback be provided on the ERO posting:
1. That the province includes a requirement for watershed/subwatershed planning to support all settlement area boundary expansions, secondary planning and other large-scale planning projects (i.e., planning for potable water, stormwater, and wastewater systems).
Report:
On April 12, 2024, MMAH released an updated proposed PPS on the ERO (ERO Posting 019-8462) titled “Review of proposed policies for a new provincial planning policy instrument”. This posting incorporates feedback received through a previous consultation completed in spring 2023. The proposal outlines the province’s plan to integrate the Provincial Policy Statement and A Place to Grow: Growth Plan for the Greater Golden Horseshoe into a single housing-focused province-wide land use planning policy document. If passed, the Growth Plan would be revoked in its entirety. The draft PPS provides a revised vision focused on “the building of more homes for all Ontarians.”
The GRCA provided comments during the initial consultation as outlined in Report GM-05-23-43. GRCA’s previous recommendations are highlighted below accompanied by a discussion of how the comments were addressed in the updated version of the PPS.
Natural Heritage
• That the province, through their review of the natural heritage sections of the Provincial Policy Statement and Growth Plan continue to recognize the importance of natural heritage and water resource features (i.e., wetlands and watercourses) and systems.
Updated PPS
The updated PPS maintains the 2020 PPS requirements for the identification of natural heritage systems in central and southern Ontario municipalities and requires that provincially significant natural heritage features and areas be protected. This is also in keeping with the requirements of the Growth Plan.
The retention of these policies is particularly important given the changes in the role of conservation authorities in the protection of wetlands in the province. Through amendments to the Conservation Authorities (CA) Act over the last couple years, conservation authorities are prohibited from commenting on any natural heritage matters under various Acts (O. Reg 596/22), including the Planning Act. The regulated area around wetlands has recently changed (O. Reg 41/24) to 30 metres for all wetlands (formerly 120 metres for provincially significant wetlands or wetlands equal to or greater than 2 hectares) and the conservation of land test/decision criteria for permitting has been removed. As such, increased responsibility now lies with municipalities to lead the management and protection of natural heritage features.
Role of CAs in Natural Hazard Management
• That the province clarifies the roles of municipalities and conservation authorities in the identification and management of hazardous lands and hazardous sites.
Updated PPS
Updated wording has been added to the PPS which require municipalities to direct development outside of hazardous lands and sites in collaboration with conservation authorities.
Although roles have not been further clarified, the new requirement to collaborate with CAs is a positive step in acknowledging the need for municipalities and CAs to work together in natural hazard planning and management.
Watershed/Subwatershed Planning
• That the document includes a requirement for watershed/subwatershed planning to support settlement area boundary expansions, secondary planning, and other large-scale planning projects (i.e., planning for potable water, stormwater, and wastewater systems).
Updated PPS
The new version requires municipalities to identify and protect water resources and features. It requires large and fast-growing municipalities and encourages others, to undertake watershed planning in collaboration with conservation authorities. The previous version only encouraged watershed planning for all municipalities.
It also requires municipalities to plan for water and wastewater infrastructure, and waste management systems. Large and fast-growing municipalities are required to, and others encouraged to undertake watershed planning to inform planning for sewage and water services and stormwater management, including low impact development, and the protection, improvement or restoration of the quality and quantity of water.
GRCA’s previous concern outlined in Report GM-05-23-43 remains. Staff recommend that an additional policy be added under Section 2.3.2 of the PPS to require subwatershed planning for new settlement areas and settlement area boundary expansions. Subwatershed planning is an important tool used to identify the most appropriate areas for new growth, including assessing alternative areas that avoid water resource and natural heritage systems as well as natural hazard areas that may be unsafe for development. This proactive approach to planning ultimately streamlines the development review process when Planning Act applications are submitted to municipalities. The result is a more seamless and less costly development application review process for applicants, municipalities and commenting agencies.

Supporting documents