Minister Paul Calandra, The…

Minister Paul Calandra,

The Mississaugas of Scugog Island First Nation have read and reviewed the Provincial Planning Statement, 2024. As a Rights-holding First Nation, MSIFN plays a critical role in stewarding the lands, waters, and resources within our Traditional Territory and has a keen interest in the planning of lands within the Territory.

MSIFN is pleased with the additions of “early engagement with Indigenous communities” and “constructive, cooperative relationship-building between planning authorities and Indigenous communities” to the PPS. MSIFN requests that the PPS also provide explicit direction for municipalities and planning authorities to undertake meaningful consultation and accommodation with First Nations and Indigenous communities.

Given the significant role the PPS plays in directing planning across the province, MSIFN requests that the PPS ensure First Nations are understood as Treaty and Rights-holding Nations to be consulted, engaged, collaborated, and partnered with on planning decision-making and agreements.

In this vein, the PPS should promote collaborative restoration planning and restoration agreements between these municipal and regional planning authorities and First Nations. There is precedent for this type of agreement in the Tripartite Framework Agreement on Nature Conservation between Canada, British Columbia, and the First Nations Leadership Council. The PPS should also encourage planning authorities to establish relationship agreements with First Nations to facilitate knowledge-sharing, consultation, and collaborative decision-making.

MSIFN is concerned with removals made to the PPS, specifically on the need to “minimize the undesirable effects of development, including impacts on air, water, and other resources”, and requests that the Minister provide an explanation for these removals and changes.

Of note are changes to language on water and watershed planning. Planning authorities must continue to plan with the impacts to water resources at the watershed level in mind. With the escalating frequency and intensity of storms and stormwater, the PPS should require all municipalities and planning authorities to undertake watershed planning and pursue stormwater management practices. Further to this point, all municipalities should not merely be encouraged, but be directed, to collaborate with conservation authorities on watershed planning.

While Chapter 2.9 outlines some positive policy on climate, energy conservation, and air quality, planning for climate mitigation and adaptation should be more deeply woven into the PPS. While the PPS contains some direction on planning to reduce greenhouse gas emissions and preparing for a changing climate, the PPS should continue to include mention of, and direction on, the importance of planning policies that pursue a clean and healthy environment.

There is also a need for additional language that encourages sustainable development both within urban and rural areas, with a focus on advocating that planning authorities pursue a compact urban form. While language on general intensification and redevelopment to support complete communities is good, compact urban development avoids and drastically reduces the impact of development on cultural heritage, ecological, and environmentally significant features.

The emphasis on advancing a range and mix of land uses and housing options should rather be placed on compact urban form, with other development densities to be used when necessary. The PPS should also provide direction in favour of mixed-use development that co-locates residential uses with other uses, including schools, libraries, recreation centres, fire stations, healthcare clinics, transit stations, and other facilities. Additionally, redevelopment of these single-uses should be encouraged to add residential units above or alongside the existing use, in turn increasing housing supply in a compact form while providing for convenient access to these needs and services.

The new PPS notes that its policies represent a minimum standard. MSIFN supports this understanding and reiterates that planning decisions must respect First Nation approaches to natural environment conservation, with a need for further protections above and beyond those set out in this PPS. In line with the view of the PPS as a minimum standard, the PPS should take precedence over provincial plans where the PPS provides a higher minimum level of protection for features.

Planning considerations should continue to be made with consideration to the holistic nature of policy and its direct and indirect impacts to nature, people, culture, rights, and economy. The new PPS removes previous detailed guidance that notes the importance of reading the entire PPS, of considering specific policy language, and of the geographic scale of policies, resulting in a PPS whose direction and application is less clear.

MSIFN looks forward to hearing from you and engaging on the PPS and related planning documents and issues.