February 28, 2018…

February 28, 2018

Aidan Grove-White

Manager Ministry of Municipal Affairs and Housing

needs to be clearly articulated.

Recommendation J – Assumptions need to be enhanced and reviewed as suggested in other recommendations. The current approach to assumptions presents problematic situations such as the inclusion of population forecasts that include census net under coverage held at a constant rate, the growth of population needs to be verified, as it is possible that the current forecasts are not being met. http://www.neptis.org/publications/update-total-land-supply-even-more-l… -greater-golden and https://www.ryerson.ca/content/dam/cur/pdfs/Backgrounders/Growth_Plan_P… rounder.pdf

Recommendation K – Excess lands. The proposed method would also identify excess lands. Two potential considerations for excess lands need to be considered. 1. It he excess land is in an area that should not be considered for urban expansion as the location is better suited for ecological function, allowances should be made to un designate the lands of ecological function and designate more appropriate lands. This could easily be part of a natural capital/ecosystem service assessment. 2. Perhaps there could be a discussion between municipalities with excess lands, especially where the natural infrastructure/ecological function is significant, that unmet growth is shared from the municipality with excess lands to a municipality where there is additional room for development in delineated built up areas in which as share of the land tax is given back to the excess land municipality. Additionally, exploring the idea of payment for ecosystems, where tax base is shared back to municipalities that are delivering greater ecosystem services, could be considered. These two directions would lead to a more balanced, sustainable, healthy and equitable sharing of costs and benefits in the GGH.

Recommendation L: We did not see anywhere within the methodology how civil society can participate nor any detailing of what the expected public consultation process will be for using the methodology. We recommend that this be included.

Closing: We have submitted these comments without prejudice, in good faith and for the public good. We applaud this direction for helping make land use planning more sustainable upon the landscape. We hope that this consultation process will be extended. We will strive to add supplementary materials, regardless of if the period is extended. We believe that the current approach does not reflect all the elements it needs to, nor considers how systems change over time. We look forward to the incorporation of, and responses to, these comments and recommendations. We are here to help develop and/or clarify comments if need be.

Sincerely,

Leslie Adams and Wendy Thompson

Co-Chairs OEN

[Original Comment ID: 213086]