Monday October 21st, 2019…

Monday October 21st, 2019
Honorable Steve Clark
Minister of Municipal Affairs & Housing
777 Bay Street - 14th Floor
Toronto Ontario M5G 2E5

Re: Provincial Policy Statement (2014) Review 2019
ERO Number 019-0279

Thank you for your letter dated July 22nd in which you announced your Ministry’s decision to undertake a review of the Provincial Policy Statement (2014). Your announcement for changes to the Provincial Policy Statement (PPS) as we understand it, is to provide further measures to enhance land use related processes and particularly, to increase housing supply in Ontario.

As Director of Planning for the Town of Mono, I attended the Municipal Webinar, hosted by MMAH, on September 19th. Subsequently, I prepared a Planning Report regarding the PPS Review for discussion at Council’s October 08th Session. It included a brief analysis of key aspects for change in the PPS, with an emphasis on consequential outcomes for rural municipalities, like Mono.

The following summary comments regarding the PPS Review are the Town of Mono’s submission to ERO Number 019-0279, as follows:

1. Proposed Section 2.5.2.2 respecting aggregate extraction permission in NHS features causes much consternation in view of the likely ability for such sensitive lands to be rejuvenated after any extractive life cycle period. This proposed policy is probably not achievable in view of the typical thirty (30) + year life span of aggregate sites.

2. Town of Mono Council is strongly opposed to proposed changes to the PPS that permit aggregate extraction activities below the water table, including proposed PPS changes as noted under Section 2.5.24. Council’s position on this matter is cited in the Minutes from the October 08th 2019 Council Session.

3. The supply and servicing implications for increasing the time horizon from twenty (20) years to twenty-five (25) years may need further assessment, particularly as it relates to rural municipalities.

4. Clarity respecting Part 2 wording in the proposed changes to PPS (2014) in order for municipal councils to better understand how their decision-making initiatives will be impacted.

5. Clarification as to what constitutes “minor rounding out” is needed.

6. Clarification is needed as to what constitutes “market demand” “market-based” and the manner in which it is to be interpreted and applied.

7. How and where will “tiny houses” be required and whether this is solely an urban option or also intended for rural municipalities.

8. Clarity is required respecting employment land conversions for rural municipalities that like Mono, do not have any PSEZ.

9. The timing and significance of any findings and/or recommendations from the Provincial Special Advisor, relative to the ERO deadline for comments, adds to the uncertainty of any ERO commentary.

The Town of Mono wishes to thank you Minister Clark and your Ministry staff for this opportunity to comment on the proposed changes to the PPS. Note: separate comments will be submitted to ERO Number 019-0556 - Aggregate Resources Act Review 2019 prior to the November 04th deadline.

We look forward to working with your Ministry on this initiative and others and appreciate the ongoing support and assistance of your staff at MMAH and partner Ministries.

Best regards,
David Trotman
Director of Planning
Town of Mono