Thank you for the…

Thank you for the opportunity to comment on proposed changes to the Provincial Policy Statement. Clean Air Hamilton is an innovative, multi-stakeholder agent of change dedicated to improving air quality in our community. This will be accomplished through sound science based decision making, using the most up-to-date information and tools available, such as the Hamilton Airshed Model. These comments should be read in conjunction with City of Hamilton Planning and Economic Development Department Report PED191881 dated October 1 2019 on the subject of the Provincial Policy Statement Review. We have organized Clean Air Hamilton's comments around the following questions.

Which changes are important from on air quality concerns and adverse effects on sensitive uses?
1. The proposed changes addressing land use compatibility in policy 1.2.6.1 will significantly strengthen the separation of sensitive uses from industrial and manufacturing uses and reduce adverse effects from air emissions on sensitive uses. This will support the regulatory responsibilities of the Ministry of Environment, Conservation and Parks as well as strengthen manufacturing and industrial viability of existing and planned employment areas and investment. By changing the wording from “should” to “shall” and by directing specific consideration be given to long-term manufacturing and industrial “operational” and “economic” viability in planning decisions, better planning and decision making for sensitive and industrial manufacturing uses will be provided for.
2. The addition of new policy 1.2.6.2 adds additional policy where sensitive uses are proposed adjacent to existing or proposed industrial uses. Taken together, policies 1.2.6.1 and 1.2.6.2 will help better buffer and separate industrial and manufacturing uses and sensitive uses where air emissions may cause adverse effects. This will better implement new policy 1.3.1 (c) by improving “the conditions for economic investment” for both sensitive and industrial manufacturing uses.
3. Taken together with new policies 1.3.2.2 and 1.3.2.3, municipalities will have the opportunity to plan industrial manufacturing centres using an industrial ecosystem approach. Firms which produce components for and use by-products from local firms will be able to strengthen investment and employment synergies thereby supporting and increasing industrial viability and competitiveness.
4. Policy 1.3.2.4 will provide for more structured and systematic reviews where proposals are made to re-designate employment lands for other uses. However, policy 1.3.2.5 may limit the effectiveness of policy 1.3.2.4 by providing an “escape hatch” for speculative properties purchased in employment designations to be converted to sensitive uses. Implementation of this policy should be carefully monitored and the three conditions together with policy 1.3.2.5 be strictly applied in order to ensure that it is not used inappropriately.
5. The addition of “manufacturing uses” to the list of Major Facilities in the Definitions section clarifies that the above policies apply to both industrial and manufacturing uses.
Do the proposed changes support the Ontario’s effort to improve air quality?
1. We believe these policies will have a positive effect on mitigating air quality adverse effects where the planning of industrial, manufacturing and sensitive uses are concerned.
Are there other policy changes needed to provide for better air quality?
1. New policy is needed to address the planning of sensitive uses in close proximity to 400 series highways where vehicle emissions result in poor air quality. In the coming decade, the electrification of vehicular fleets, implementation of AI to transportation, and the increase of “shared” vehicles together with the decrease in private automobile ownership may dramatically change transportation and land use patterns throughout the Province. Policy is needed provide strategic direction in order that this transition and implementation be orderly and a constructive inter-relationship between land use and transportation is achieved. Some municipalities are beginning to strategize what this emerging transition will look like and how their transportation and land use policies need to change. Acknowledgement and encouragement in a revised PPS is needed. In addition, this transition may greatly assist Hamilton improving neighbourhood air quality.
2. New policy is required to prohibit the use of legal non-conforming status when applied to sensitive residential uses as a means of avoiding the proper separation of sensitive residences from major facilities where adverse effects are concerned.
3. In addition to the use of Provincial guidelines, standards and procedures where policy application is concerned, the use of municipal air quality monitoring and modelling should also be required where this information is available and can be usefully applied to the interpretation and application of Provincial policies within the revised Provincial policy Statement.
4. Climate change should be considered in guidelines related to settlement area and boundary adjustments and employee land conversions. Clean Air Hamilton supports comments provided by the City of Hamilton’s Planning and Economic Department on these matters as submitted and referenced in report PED191881.

References
1. https://pub-hamilton.escribemeetings.com/filestream.ashx?DocumentId=204…