Proposed PPS April 2024-…

Proposed PPS April 2024- Town of Halton Hills Comments
Thank you for the opportunity to provide comments on the proposed Provincial Planning Statement (2024). Town staff previously commented on proposed Provincial Planning Statement, 2023, through ERO posting 019-6813. Attached is report PD-2024-35 which includes the Town’s comments on the Proposed Provincial Planning Statement (2024). Below are responses to the discussion questions provided in ERO posting 019-8462.

1. What are your overall thoughts on the updated proposed Provincial Planning Statement?

• Overall, the proposed Provincial Planning Statement, 2024 is an integrated document that combines elements of the Provincial Policy Statement, 2020 and the Growth Plan for the Greater Golden Horseshoe, 2019. Generally speaking, staff are encouraged by some of the changes proposed relative to the previous iteration released in 2023 and have identified areas of concern including Settlement Area Boundary Expansions, parking and density targets within MTSAs, and the definition of employment areas.

2. What are your thoughts on the ability of updated proposed policies to generate appropriate housing supply, such as: intensification policies, including the redevelopment of underutilized, low density shopping malls and plazas; major transit station area policies; housing options, rural housing and affordable housing policies; and student housing policies?

• Town staff welcomes policies to promote intensification in strategic growth areas especially those that focus on ensuring the required infrastructure is in place to support redevelopment and intensification opportunities, and to build vibrant, mixed-use communities.
• Staff does not support proposed PPS policy 2.4.2.2, which will require mandatory minimum density targets within MTSAs on higher order transit corridors (i.e. commuter rail lines), across all municipalities. This policy would require the Town to plan for a minimum density of 150 residents and jobs per hectare in both the Acton and Georgetown MTSAs. Considering the local context and/or infrastructure limitations, staff believe planning for this type of density would be inappropriate for these areas.
• Policies have been introduced in the proposed PPS that allow in limited circumstances, municipalities to request the Minister to approve alternative density targets for a MTSA. To date, extensive work has been undertaken by staff, consulting team and key stakeholders towards establishing a Preferred Land Use Plan and density target that reflect the local context for the Georgetown GO Station Area/Mill Street Corridor Secondary Plan Review. It is anticipated that a similar review for the Acton GO Station Secondary Plan Area will be initiated in 2025, subject to budget approval. The Town is committed to assigning appropriate densities for its MTSAs through these Secondary Plan exercises and staff believe that the determination of density targets should be a local exercise. This would ensure considerations such as the appropriate scale and type of development, the transition of built form to adjacent areas, and the supportive infrastructure and public service facilities required to achieve complete communities and compact built form are identified at the local level. Town staff suggests that the Ministry allow for lower density targets in areas where individual analysis has taken place and intend to engage with Ministry staff directly to discuss this matter.
• Staff note that the Town is not currently included in the list of large and fast-growing municipalities. Notwithstanding the foregoing, the density target of 50 persons and jobs per hectare calculated across the entire designated growth area is considered low. Given trends in recently approved growth areas, including the Vision Georgetown Secondary Plan where densities are likely to achieve a target of closer to 75 persons and jobs per hectare, the Ministry should consider increasing the recommended targets to better align with planned densities within major or large-scale designated growth areas.
• Overall, the proposed 2024 PPS has a similar policy approach to affordable housing as was seen in the PPS, 2020. One change however, that staff are supportive of, is the revised definition of affordable as it relates to housing. The definition in the proposed PPS, 2024 removes the reference to the regional market area, basing determination of affordability instead on the municipality. This is a significant improvement as in the context of Halton Hills, it means that the affordability thresholds are based on what is seen within the Town, rather than within the broader regional market area.

3. What are your thoughts on the ability of the updated proposed policies to make land available for development, such as: forecasting, land supply, and planning horizon policies; settlement area boundary expansions policies; and employment area planning policies?

• Proposed policy 2.1.1 requires that in the future, planning authorities must base their population and employment growth forecasts beyond 2051 on Ministry of Finance 25- year growth projections. Currently, upper and single-tier municipalities are required to utilize the growth forecasts provided in Schedule 3 to the Growth Plan to the 2051 planning horizon. These Schedule 3 forecasts were used by Halton Region through the Regional Official Plan Amendment No. 49 (ROPA 49) process and distributed to the local municipalities in keeping with the requirements of the Growth Plan. The Ministry of Finance growth projections have historically been prepared at the upper-tier level only, which means they have never been prepared for local municipalities. With the growth projections only being provided at the Regional level, staff recommend that the Province consider preparing guidance documents or direction on how the Ministry of Finance growth projections could be distributed amongst the lower-tier municipalities. This direction may also be helpful in providing advice regarding long term infrastructure planning and the distribution of water and wastewater capacity to support growth at the local level.
• The PPS, 2024 in conjunction with Bill 185, proposes significant changes regarding applications for Settlement Area Boundary Expansions (SABEs). Proposed policy 2.3.2.1 would allow private applications for SABEs at any time, so long as the proposed boundary expansion is outside of the Greenbelt Plan Area. Coupled with the proposed Bill 185 change (as discussed in Report PD-2024-034) that would allow a private applicant to appeal the Town’s refusal or non-decision of an Official Plan Amendment (OPA) to expand or alter the settlement area boundary, it is anticipated that these proposed changes will lead to numerous site-specific OPAs requesting expansion of the Town’s boundaries, with subsequent appeals to the OLT. This situation would create an unnecessary burden on both the Town and the OLT and would likely lead to ongoing litigation, with significant impacts on the Town’s staffing and financial resources.
• It is worth noting that in the context of Halton Hills, these proposed policies could potentially permit applications for SABEs for the remaining ‘whitebelt’ lands located outside of the Bill 162, Get It Done Act proposed urban area boundary identified in MEM-PD-2024-004, as well as lands within proximity to the Mansewood Employment Area. Given the existing urban areas of both the City of Burlington and Town of Oakville, and the Bill 162 proposed urban boundary expansion to the Town of Milton, Halton Hills is the only municipality within the Region that will be significantly impacted by these proposed SABE policies. Staff does not believe that permitting privately initiated urban boundary expansions outside of a broader comprehensive review process, such as an Official Plan Review, is prudent or in the public interest.
• Although the revised PPS includes criteria for the assessment of proposals for settlement area boundary expansion such as the determination of need, confirmation of servicing capacity, agricultural impact, and the phased progression of development, there are no limitations proposed for boundary expansion proposals. Town Council through report PD-2023-080 endorsed the growth concept now supported in Bill 162, which will allow the Town to accommodate the anticipated population of 132,050 and 65,460 jobs being reached by 2051. Secondary plan boundaries will be identified where appropriate through the upcoming Official Plan Review.
• As noted above, staff believe that the need for urban boundary expansions should be assessed through the local Official Plan Review or equivalent process, where the Province will be the approval authority. This process will typically include a growth forecast and accompanying land needs assessment to ensure that sufficient land has been designated to accommodate future population and employment growth. Any concerns with the growth forecast and accompanying land budget that underpins an updated Official Plan, should be resolved in a collaborative and transparent manner prior to the Minister’s approval. Staff strongly encourage the Province to reconsider these proposed PPS and Bill 185 revisions and would be happy to meet with Ministry staff to discuss this concern.
• Staff believes that prohibiting institutional and commercial uses from Employment Areas is not in keeping with the proposed PPS goal of supporting a modern economy and promoting economic prosperity. As mentioned in Report PD-2023-041 regarding Bill 97, restricting institutional and commercial uses in employment areas will require that Employment Areas in the Town, such as the Premier Gateway Employment Area, which are already designated and, in some cases, zoned to allow supportive commercial and institutional uses, be stripped of those existing land use permissions. As such, the Town does not support the revised definition or draft policies under section 2.8.2.3 restricting a range of supportive commercial uses. Supportive commercial uses often include business supportive retail and professional office space, which contribute to creating comprehensive and complete Employment Areas and influence the vitality and connectivity of the local economy.
• Further, staff is concerned about the proposed policies found in section 2.8.2.5, which would create the opportunity for employment land conversion applications to be submitted at any time, particularly for residential and major retail uses. This establishes the potential to create fragmented employment areas, where potentially sensitive residential uses are encroaching within historically established employment areas. In the absence of clearly identified policy requirements and continued protection of employment areas, staff is concerned about the potential long-term impacts on the Town’s overall employment land supply as a result of these proposed PPS policies

4. What are your thoughts on updated proposed policies to provide infrastructure to support development?

• Halton Region will continue to provide servicing infrastructure for development within the town. Staff do anticipate that the Province may be creating transition provisions regarding the shifting roles and responsibilities; should provisions be released, staff will assess any potential impacts at that time.

5. What are your thoughts on updated proposed policies regarding the conservation and management of resources, such as requirements to use an agricultural systems approach?

• Generally, staff are supportive of the proposed changes to the agricultural system policies in the proposed PPS, including the requirement to use an agricultural system approach, based on provincial guidance, to support and foster the long-term economic prosperity and productive capacity of the agri-food network.

6. What are your thoughts on any implementation challenges with the updated proposed Provincial Planning Statement? What are your thoughts on the proposed revocations in O.Reg. 311/06 (Transitional Matters - Growth Plans) and O.Reg. 416/05 (Growth Plan Areas)?

• See responses to question 2 which highlight the implementation challenges anticipated with the proposed changes to proposed major transit station area policies.
• See responses to question 3 which highlight the implementation challenges anticipated with the proposed changes to proposed settlement area boundary expansions policies and employment area planning policies.