General Halton Hills…

General

Halton Hills Planning staff welcome the opportunity to provide comments as part of the Provincial consultation on proposed Updates to the Projection Methodology Guideline to Support the Implementation of the Provincial Planning Statement, 2024 (PPS, 2024)

In 2024, through Bill 162, Get It Done Act, Halton Regional Official Plan Amendment 49 (ROPA 49), was approved by the Province. In accordance with the Greater Golden Horseshoe: Growth Forecasts to 2051 prepared by Hemson Consulting for the Province and the Schedule 3 Growth Plan Forecasts, ROPA 49 identified a 2051 population forecast of 1.1 million for Halton Region. This population was distributed to the four local municipalities with the Town of Halton Hills forecast to reach a population of 132,050. This represents a significant increase in the Town’s current population of 66,000 and is in keeping with planned growth and the extension of lake-based services to Georgetown.

As a general observation, staff are concerned with utilizing the Ministry of Finance Projections as a starting point since these projections, as noted on the Ministry website, “do not represent Ontario government policy targets or desired population outcomes, nor do they incorporate explicit economic or planning assumptions. They are developed using a standard demographic methodology in which assumptions for population growth reflect recent trends in all streams of migration and the continuing evolution of long-term fertility and mortality patterns in each census division. Census division projections are summed to obtain the Ontario total.”

Aside from the foregoing, the Ministry of Finance projections are significantly lower than the Schedule 3 Growth Plan forecasts. This has the potential to create uncertainty with respect to planned growth over the next twenty-five years. We do note that as per PPS policy 2.1.2 municipalities may continue to forecast growth using population and employment forecasts previously issued by the Province for the purposes of land use planning. We are pleased that the draft Projection Methodology Guideline also references the continued use of the Schedule 3 forecasts of 132,050.

Ongoing Local Official Plan Review

The Town of Halton Hills is currently undertaking an Official Plan Review, which is currently utilizing the forecasts that were approved by the Province through ROPA 49. In keeping with PPS policy 2.1.2 and the draft Guidelines, we intend to continue to rely on the population and employment forecasts contained in ROPA 49 as approved by the Province. Given that a comprehensive land budget was prepared in support of ROPA 49, it is our view that further analysis based on the Projection Methodology Guideline will be counterproductive and costly. Instead, we would suggest that the guidelines - be utilized as part of the next Official Plan Review.

The Province should clearly outline how it plans to support local municipalities to implement the methodology upon approval.

Establishing Municipal Population Projections

In an earlier part of this submission, we expressed reservations about utilizing the Ministry of Finance projections. The Town encourages the Province to continue to provide specific comprehensive forecasts for high growth areas such as the
GTHA at the Census Division level. In addition, given that the two methods referenced in the Projection Methodology Guideline are relatively rudimentary, more direction on the distribution of growth amongst lower tier municipalities that form part of a Census Division would be helpful. This could include better clarifying how the local context should be considered.

The proposed methodology notes that “a coordinated, integrated and comprehensive approach should be used when dealing with planning matters within municipalities, across lower, single and/or upper-tier municipal boundaries, and with other orders of government, agencies, boards, and Service Managers.” The Province should advise how it intends for these projections to apply on the ground and provide direction for how the Upper-Tier Municipalities can deliver on the servicing capacity required to meet locally created projections.

Developing a Housing Needs Forecast

Direction should be provided on how to account for temporary residents (e.g. students and farm workers) as part of the methodology in this chapter.

Further direction should be provided on how municipalities are to calculate/determine “suppressed household formation” and “propensities for households to occupy certain types of housing”. The Guideline should provide a standard method of calculating both. Based on the steps outlined for determining the Total Forecasted Household Need, discrepancies between municipalities for determining these inputs could result in significant differences, impacting results of each local housing needs forecast, which ultimately could cause issues in how the Region justifies the provision of infrastructure needed for growth.

Further direction on what kind of information the Province is looking for in Step 3 (Forecasted Housing Need after Intensification), should be provided, including the level of analysis and information supporting the calculated outcome.

Developing Employment Projections

The new definition of employment area in the PPS 2024 has removed commercial, retail and office uses from the list of permitted uses, which may result in more jobs to be accommodated by intensification in built up areas or designated growth areas. In some situations, warehousing and logistics uses located within employment areas may not have a significant number of jobs or may be heavily automated. Municipalities do not have the tools to limit warehousing and logistic uses within employment areas as defined by the PPS. In addition, due to their function, such uses cannot be readily intensified.

It is assumed that a larger proportion of jobs will need to be accommodated in general employment areas. This will be challenging given the recently updated PPS 2024 definition of employment areas. Halton Hills contains urban centres with larger employment areas separated a fair distance from community areas. The Guideline should consider and provide direction to municipalities on how to better intensify these employment areas so that an adequate number of jobs can be accommodated.

Staff also have concerns with relying on National Occupation Classification as this could lead to an underestimation of Employment Area land demand, as the rise in high-skilled jobs in industrial operations might be mistakenly classified as office uses. Municipalities should at minimum have the flexibility to complete step 3 using the North American Industry Classification System (NAICS) which classifies jobs by the type of business in which they are performed.

Land Needs Assessment

Further direction on what constitutes “undevelopable lands” would be helpful in this section, including what level of analysis is required to demonstrate what is “undevelopable”. Where Natural Heritage Systems are generally considered to be undevelopable, a more precise calculation of these areas is only available after relevant technical studies (such as subwatershed studies) have been completed.
Method 1 talks about dividing the residents and jobs by the planned density targets. The density targets in most cases will be different in greenfield areas than in infill or stable residential neighbourhoods. It should be clarified whether municipalities can set one general density target for the purpose of using this method, or whether multiple calculations based on differing targets (e.g. existing built up areas vs strategic growth areas) are more appropriate.
Implementation

This section primarily speaks to the Provincial expectations regarding collaboration between municipalities and documentation of the land needs assessments. Page 52 identifies that “...other appropriate stakeholders are encouraged to undertake a coordinated approach...”. This suggests that landowners should be involved when municipalities are completing their land needs assessments, implying a public process. If this is the case, expectations for such a process should be made clear, including any statutory public meeting requirements. Direction on whether upper-tier municipalities with responsibility to deliver water and wastewater infrastructure need to be consulted should be made clear.

It would be helpful if the Province provided a checklist or rubric outlining what municipalities are required to submit. Additionally, this chapter should better clarify who the appropriate approval authority is for LNAs (e.g. Province, or upper-tier municipality with planning responsibilities).