The Council of Tay Valley…

The Council of Tay Valley Township thanks the Province for the opportunity to comment on proposed changes to the Provincial Policy Statement (PPS).

The proposed PPS changes in section 1.1.1 b) and elsewhere refer to “accommodating an appropriate market-based range and mix of residential types”. There is a stark dichotomy between the provision of affordable housing (e.g., to meet County Homelessness Plans, stated as a goal of the review, or housing for seniors on fixed incomes) and policies which mandate that new development will be based on a market-based approach. In addition, section 1.2.4 a) requires housing allocations shall be informed by provincial guidelines (e.g., Bill 108 concentrating affordable housing near "protected major transit station areas) which could lead to ghettoization.

Section 1.1.1 i) calls for “preparing for the regional and local impacts of a changing climate”. The Township believes mitigation of those impacts is as important as planning for adaptation to the impacts. In addition, the definition of “impacts of a changing climate” - “potential for present and future consequences and opportunities from changes in weather patterns at local and regional levels including extreme weather events and increased climate variability” is too narrow. Focus on weather events ignores the impacts on health, social equity, financial dislocation and other impacts.

Section 1.1.3.1 states: Settlement areas are the focus of growth and development. The Township has 8 Settlement areas, very few of which have room for infill. This implies a shift in growth patterns and trends for the Township if it is strictly enforced by the province.

The Township appreciates the additions to Section 1.8.1 “Planners shall support energy conservation and efficiency, reduced greenhouse gas emissions” including “district energy” but is concerned that this policy is contradicted by the province’s encouragement of natural gas (a climate change accelerant).

Agricultural policies are proposed to permit the erection of ground-mount solar on specialty crop areas and agricultural lands up to a maximum of 2% of the land holding. This policy can aid farmers similar to the policy allowing diversified on-farm uses.

While the Township appreciates the direction in Section 2.6.5 that “Planning Authorities shall engage with indigenous communities and consider their interests when identifying and protecting cultural heritage and archeological resources” – as the Township has already begun the process of relationship building with the Sharbot Obaadjawin and Ardoch Algonquin - meaningful engagement requires funding which the province has not identified. Furthermore, there may be as many as 31 indigenous groups at play in Tay Valley Township according to Cambium Consultants. The Township would appreciate clarification and support from the Province on engagement.

Municipalities may adopt a voluntary management approach to locally and regionally significant wetlands. However, this new PPS policy may result in proposals for offsets for filling wetlands and the province has not proposed a minimum standard for compensation. Also, policies are included to permit mineral aggregate operations in areas of natural heritage systems "where no negative impacts will occur" (however, there is no explanation of how this extraction would be possible as negative impacts are unavoidable).

While the proposed changes in Section 4.7a) call for fast tracking “priority applications” there is no definition of what constitutes a priority application. Also the implication is that local planners, not Ministry departments, are slowing down development. With a 90 day turn around on Zoning applications this seems to be a misplaced emphasis on the local planning process.

There are several noted changes in language of the PPS to change shall to should (or vice versa) which result in major interpretation changes.

Finally, a significant number of policies are proposed to have “companion policies” by the Province, but there is no information about when these would be available or what they would specify. The Township would like those policies to be available so that the proposed PPS changes can be clearly understood in context.