We work in developing a…

We work in developing a community plan with the Six Nations of the Grand River. We are commenting from our knowledge in our positions, not on behalf of the people of Six Nations.

The Growth Plan for the Greater Golden Horseshoe is fundamentally a useful plan in that it encourages intensification and densification, as opposed to expansion of settlement boundaries. But when looking at the map, it is clear that all First Nations communities are considered as external to any kind of planning (they are just greyed out areas). Many First Nations across Canada are undertaking their own planning processes right now. We need to move beyond the old paradigm of reserves being considered limits to development - First Nations communities are growing and changing along with the rest of the country. It should also be clarified whether and how Indigenous communities were engaged through the development of the Growth Plan. We understand that the specific policies being developed now (MCR and Density Targets) are subsidiary to the Growth Plan, but wanted to make these comments on the broader Growth Plan for future consideration.

With that being said, we do not have any specific comments on the Application of the Intensification and Density Targets - intensification and lowered expansion is typically in the interest of First Nations as it will reduce land degradation and leave more opportunities for growth and development of First Nations. With respect to the Municipal Comprehensive Review Process, we have a few comments. The language in the document under 4.2 "Duty to Consult with First Nations and Metis Communities" is for the most part positive. The language of encouraging engagement "early on, and throughout" and "constructive, cooperative relationships" is positive, as it shifts away from very unfortunate and inadequate norm - letters of notification being sent and hoping for a response. Also, stating that "municipalities are best positioned to explain their approach" is positive as it takes into account how nuanced relationships will be across the area - no single approach can be prescribed. Finally, the sentence beginning with "Municipalities have broad..." uses strong language that reflects the conversation around reconciliation and using the principles of the original treaties such as "mutual respect".

However, beyond this positive language, the section doesn't go far enough to shift the status quo, which is that engaging Indigenous communities seems to be an afterthought or an inconvenience. We feel that there are real opportunities for mutually beneficial outcomes through genuine relationship building, and the policy should reflect that. We feel that the MCR process, as regularly occurring process for municipalities, should be an important trigger for municipalities to take the leap into more substantial and constructive relationship building. Both the Canadian Institute of Planners and the Ontario Professional Planners Institute are taking positive steps toward shifting the attitude of planning through their own engagement and policy development, and there is an opportunity for the Growth Plan to mirror it. Some suggestions:
- Can this section appear earlier in the document? To have this section appear as a sub-bullet later in the document seems to contradict the substance of the section that Indigenous communities should be engaged "Early on, and throughout". If this is in fact a key context, it should be presented that way.
- The title of the section should be called "Engaging Indigenous Communities". The "Duty to Consult" is of course a crucial context that should appear in the substance, but framing this as a "duty" perpetuates the assumption of too many planners which is that this is an obligation, not an opportunity.
- Similarly, the sentence "Early on, and throughout, the MCR process, municipalities should engage Indigenous communities to determine whether any Aboriginal or treaty rights (or interests) may be impacted by municipal land use planning decisions" perpetuates the idea that, as long as municipalities aren't infringing on anything then they are in the clear. Again, it pits municipalities against First Nations, instead of promoting mutually beneficial, solutions based dialogue. Something like: "Early on, and throughout, the MCR process, municipalities should engage Indigenous communities to strive for mutually beneficial planning outcomes. The latter part of the sentence (whether any Aboriginal...) should appear later on as an important consideration.
- There should be a sentence along the lines of "Sufficient time and resources should be budgeted to support these ongoing relationships." Many First Nations are administratively over-burdened and under-resourced so users of this policy should understand the need to do better than sending letters and hoping for responses in short time frames.