I know many people internal…

I know many people internal to the Provincial government worked hard on these changes...as they did on the previous PPS.

I felt compelled to comment as I understand the important role of the Planning Act and PPS.

Economic Health
I am a parent, business owner, and Registered Professional Planner whose income depends on development; and as such I am pro-development!
However, I am concerned that the these proposed changes will negatively impact the financial well-being of most municipalities and communities across Ontario permanently; particularly small, rural and northern
Ultimately this would reduce our collective prosperity including protection of human health and safety.
The very act of opening the PPS for review before 2024, changing the Planning Act, Conservation Authorities Act, etc. has a destabilizing effect.
I am assuming a few large-scale developers of single family detached housing may benefit in the short-run in the areas expected to receive development pressure: Ottawa area, and Toronto - Niagara corridor. However, in the long-run, we will all be less prosperous due to the combined net increase of sprawl and unmitigated climate change contributions, putting economic pressure on the Provincial government.

Public Process
Expecting practitioners and the public to put effort into reviewing an incomplete document is not appropriate. Section 3 should have been completed before seeking input.
The Provincial government made a deliberate decision not to provide draft red-lined changes which assist citizens in identifying and considering proposed changes. A red-lined version was provided for the 2014 review and should have been this time.
The formal consultation process summarized changes into politicized categories, directing reviewers away from potentially impactful changes and making them appear positive when they may not actually be. These "Placemats" were provided along with what could be interpreted as "leading questions". Perhaps it was intended to be helpful; but to me it raised concerns.
Some policies defer to guidelines. Unless the guidelines are available to review at the same time as the policy, the Ontario Policy-led system becomes an unpredictable "Guideline-led" system with guidelines that may or may not exist yet or could be changed without a public process. I agree that we have always relied upon guidelines rooted in evidence (science and research) to implement policies, e.g., MECP d-series, MMAH growth projection methodology, etc.; but to be explicit in several areas of the PPS raises the question of if/how these guidelines may change.

Sprawl
Several proposed changes deliberately support sprawl which we have long-known to be the most destructive and costly form of development, threatening our long-term prosperity in countless ways by consuming and contaminating food-growing land, ballooning long-term infrastructure costs particularly with exacerbating and increasingly unpredictable climate change impacts, and so on. The purpose of the original PPS was to hinder sprawl and protect areas that provide essential services: wetlands (stormwater management, clean drinking water), natural areas (protects biodiversity and creates oxygen/carbon sink = human life) and so on. As such several of the proposed changes are in conflict with the original Section 1.1.1. Specific sections are referenced below.

Climate Change
The emphasis on avoiding or preventing climate change impacts has deliberately been changed to a focus on managing the impacts. Such impacts which are unpredictable if we do nothing to reduce them in the first place, thus making it nearly impossible to plan for! I agree that it's good planning to include preparation for the impact of climate change per the proposed changes; but not at the exclusion of prevention — which is distinctly "lack of planning".
The PPS continues to imagine growth. This term should be used more sparingly as we know that it relates to only a limited section of the province (according to the Province's data). The terms like "improvement" or "prosperity" should be used for most areas outside of the Greater Toronto - Niagara corridor and Ottawa area.

Summary
While there are some positive changes in the PPS some which I will note below in the "Specifics", I am concerned that Ontario planners will be left with the lack of ability to practice good planning for our collective future if the proposed policies are implemented. Many of the proposed changes are in conflict with ORIGINAL Section 1.1.1 of the PPS; and as such threaten long-term prosperity, health and safety.
In Ontario the PPS in our policy-led system provides the balance between public and private interests. Unfortunately, it appears the 2019 PPS fails to achieve this, tipping the balance of power to a small group of development interests.

Some specifics
1.1.1 b) what is market-based? I am concerned this will mean single-detached housing; not affordable, higher-density housing.
1.1.1 e) is a positive change but unfortunately is undermined by the others when the PPS is read in its entirety.
1.1.2 unless the guidelines are available to review at the same time as the policy, the Ontario Policy-led system becomes and unpredictable guideline-led system with guidelines that may or may not exist yet or could be changed overnight without a public process. Is there a link to this? A name so a person can search on-line? A public process for developing the guideline at a later date?
"preparing" for the impacts of climate change should be changed to "preventing" further impacts and preparing for the impact already occurring. Here and throughout document.
1.1.3.3 transit supportive housing is positive, but how "significant supply" is defined will determine whether or not it is meaningful
1.1.3.7 keep original "shall". "Should" undermines municipal efforts to increase density and reduce sprawl along with removal of s. 37 of Planning Act and other changes.
1.1.3.8 a) remove market demand unless it is further defined to emphasize high-density housing.
1.1.3.8 e) keep original…level of detail of comprehensive reviews and other technical studies are already correspond to scale of development/potential impacts.
1.1.6.1 how is recreational dwelling defined? Since PPS is open for review, this should be addressed.
1.2.1 h) positive change as far as I understand it
1.2.2. ditto
1.2.4.a) which guidelines?
1.2.6 Clearly the attempt to define how "evaluation of alternative locations" and "reasonable alternative" will put municipalities/citizens in conflict with developers. This will increase LPAT case-load, and place the advantage with wealthy developers, costing municipalities and potentially negatively impacting citizens. Ditto for 1.2.6.2.
1.3.1 c) What does "seeking to address potential barriers to investment" get defined? Are these land use planning barriers? Or is the Province asking Municipalities to engage with the finances of private businesses that goes beyond the Planning Act? (And are normally illegal under the Municipal and other Acts).
1.4 how are air rights defined?
1.6.2 Since PPS is open "should" ought to be changed to "shall" since green infrastructure is free and provides millions of dollars of services.
1.6.6.1 throughout: who determines if a system is failed and what are the criteria?
1.7.1 e) change "promoting" well-designed built form to "requiring" (via locally-developed design guidelines)
1.7.1 k) change…"considering" the ecological benefits….to "calculating the dollar-value ecological benefits/services" provided by nature
2.1.10 Are these existing guidelines?
2.2.1 require the north to plan on a watershed basis as well; and support the Conservation Authorities in expanding in order to facilitate this.
2.3.6.2 new wording undermines ability to protect
2.4 "except where groundwater may be impacted", particularly in the case of Fracking. This should be updated with the PPS open as evidence has shown Fracking destroys ground water; and any future housing or agriculture.
2.5.3.2. how is "concentration" defined? This should be addressed with the PPS open.
2.5.2.2 I live outside of the Greenbelt. The protected natural areas are protected for important reasons that are supported by evidence. To explicitly permit extraction using an outdated and weak process found in the Natural Heritage Reference manual/Aggregate Resources Act is not acceptable. Again, "long term rehabilitation" and "no negative impacts" put the municipality or citizens in conflict with the developer, using up resources at LPAT at best; and destroying what keeps us alive and prospering at worst.
2.6.5 is a positive change if the Province recognizes its Constitutional obligations. Certainly planning authority have a critical role, but it needs to be financially supported by the Province. Indigenous capacity-building with their direction needs to continue.
In the same, all small, rural and northern communities that are grappling with continuous downloads, shrinking economies, out-migration and also need Provincial financial support in land use planning. With LPAT legislation changing to the disadvantage of citizens, the closure of the LPASC, citizens and municipalities are at the mercy of often unscrupulous developers as they do not have the resources to hire planning expertise, thus falling even further behind financially. A northern and rural Local Land Use Planning Support Centre needs to be established and financed by the Province.

Some positive observations:

Indigenous communities
Changing Aboriginal to Indigenous is positive if that is what the Indigenous communities requested
Using the term "engagement" is positive is that is what the Indigenous communities requested.
Were Indigenous communities engaged in the preparation of the PPS 2019 amendments?
Agricultural Systems and Network appear positive and I look forward to learning details and results of implementation.

Conclusion
The Province has already removed Section 37 "density bouncing" from the Planning Act which undermines an important, well-thought-out tool for reducing costly and destructive sprawl while encouraging higher density forms of housing/affordable housing.
This, along with some of the other legislative changes already in force, plus the proposed PPS policy changes I have flagged, the result points to a severely impaired Provincial economy in the medium and long term; with concurrent with (costly) reduction of human health and safety.

We are in the throes of a mass extinction and municipalities are declaring a climate crisis in desperation for policy support and strong leadership to implement meaningful preventative measures. Now is not the time to be undermining the very policies in the PPS that facilitate such measures.

Thank you for considering my comments.