This submission will outline…

This submission will outline comments based on a review of the draft changes to the PPS based on a review by staff and County Council. The comments are focused on the proposed changes that are anticipated to most affect land use planning in Middlesex County.

Increasing the Supply and Mix of Housing

Provincial Preamble “A stable housing market with sufficient supply will help make housing more attainable and affordable for the people of Ontario. It will also attract new investment and create investment-ready communities that are attractive to employers and provide workers with places to live.”

Planning Horizon

The draft policies would increase the ‘planning horizon’ from 20 to 25 years, and make corresponding changes to the ‘housing supply’ and ‘serviced land’ requirements thereby increasing the amount of land that municipalities could designate for growth. The policies would also reference an updated provincial guidance document to support ‘land budgeting’ however that document has not been released.

The increase in the ‘planning horizon’ from 20 to 25 years would give municipalities additional flexibility to ensure that lands are designated and available for growth. This may be of assistance as municipalities, especially smaller municipalities, can at times face near monopoly ownership situations where large components of the land designated for development are owned by only a few people.

Settlement Area Boundary Adjustments

The draft changes would permit settlement area boundary adjustments outside of the Municipal Comprehensive Review subject to evaluation criteria and where there is no net increase in overall land within the settlement area. This change would provide municipalities with additional flexibility to address limited settlement area boundary adjustments without undertaking as extensive of a planning exercise but likely will also lead to additional pressure on municipalities from the development industry to consider such proposals.

Housing Affordability

The proposed housing policies would recognize a greater mix of housing types through the addition of the term ‘housing options’. The definition provides an extensive list of housing types including single and semi-detached, rowhouses, townhouses, multiplexes, tiny homes, as well as housing for people with special needs and housing related to employment, institutional and educational uses.

The proposed policies would also require that municipalities align official plan housing policies with applicable Housing and Homelessness Plans. While this makes sense, it would be challenging to align the documents as Housing and Homelessness Plans are very separate in structure, content and process from municipal planning documents.

Housing to Meet Market Based Needs

The draft changes reference the undefined term ‘market based needs’ in relation to the provision of housing and development for long-term economic prosperity. Although the meaning of this is not entirely clear, there is some concern that this policy could be interpreted to put emphasis on housing types that are easy to build and market, and therefore preferred by the development industry.
This could be in opposition to municipal planning policies which may seek to encourage housing of different forms. It is also important to note that while the provision of housing is an important policy goal, there are infrastructure and other pressures that come with growth that must be addressed by municipalities. The provision of housing to meet the current market is one of many inter-related municipal priorities.

Reduced Cost and Barriers

Provincial Preamble “A streamlined land use planning and development process which protects what is important – while reducing barriers and costs – supports economic growth and investment and the continued prosperity of Ontarians.”

Fast-Track Priority Development

In order to support development and reduce costs, the province has proposed to add a policy that requires municipalities to facilitate a timely and streamlined process for development. The proposed policy states that municipalities shall identify and fast-track ‘priority development applications’, which support housing and job-related growth and development. The proposed changes call on municipalities to reduce the time needed to process priority development applications.
There is no guidance on what it means to fast-track priority development applications or how to identify ‘priority’ vs. ‘non-priority’ applications. Overall, the timely processing of development applications is less of a concern in southwestern Ontario compared to larger urban areas.
It is noted that provincial approval processes (Environmental Compliance Approvals, Environmental Assessments, etc) are often significantly longer than municipal planning approval processes. For example, the lengthy Environmental Assessment process that municipalities must undertake related to servicing infrastructure improvements are at times considered to be a constraint on the timely provision of additional housing.

Supporting Rural, Northern and Indigenous Communities

Provincial Preamble “Rural, northern and Indigenous communities are vital to Ontario’s continued prosperity and overall well-being”

Indigenous Community Engagement

The draft changes would recognize and encourage the important role Indigenous communities have in land use planning and development, as well as the contribution of Indigenous communities’ perspectives and traditional knowledge on land use planning decisions. The proposed changes encourage municipalities to consult with Indigenous communities on land use matters that may affect their Section 35 treaty rights and to build constructive, cooperative relationships with Indigenous communities through meaningful engagement that will facilitate knowledge sharing to inform decision making.

To implement this policy change, it would be important for the Province to assist municipalities and Indigenous communities to make the necessary connections and to ensure a practical and effective consultation process is put in place that considers municipal and Indigenous community capacity and resources.

Supporting Certainty and Economic Growth

Provincial Preamble ”Economic opportunities and continued investment are vital to supporting jobs and the continued economic well-being of all Ontarians. Supporting jobs is a key priority of Ontario’s Open for Business agenda”

Employment Land Conversions

The draft changes propose to permit employment area conversions outside of the Municipal Comprehensive Review, subject to criteria. This may give municipalities additional flexibility to consider such proposals but will also likely result in greater pressure from the development industry to consider such proposals outside of a larger planning exercise.
Regional Employment Lands

Reference is made to the identification of regionally-significant employment lands by a ‘regional economic development corporation’ working together with an affected upper-tier municipality. The reference to a ‘regional economic development corporation’ would benefit from clarification.
There are several areas within the proposed wording where reference is made to the upper-tier level of government. Wording could be included in the PPS to clarify that all levels of government are to work towards the provincial planning goals.

Conclusion

Thank you for the opportunity to provide feedback in respect to the proposed changes to the PPS. The comments focused on the proposed changes that are anticipated to most affect land use planning in Middlesex County.

It is additionally noted that the proposed changes make several references to levels of government such as ‘the upper-tier shall’. It is important for the PPS to reflect that all levels of government have an important inter-related role in good land use planning.