June 19, 2018 Mr. Aidan…

June 19, 2018

Mr. Aidan Grove-White, Manager
Partnerships and Consultation Branch
Ontario Growth Secretariat
Ministry of Municipal Affairs
777 Bay Street, 17th Floor
Toronto, ON M5G 1Z3

Dear Mr. Grove-White
Re: Comments on Draft Guidance to Support Implementation of the Growth Plan for the Greater Golden Horseshoe, 2017: Application of the Intensification and Density Targets & the Municipal Comprehensive Review Process (Notice #013-2359)

LORAPON is pleased to provide the following comments on the above noted draft guidance documents to support implementation of the Growth Plan. These comments have been produced in consultation with the Development Directors of Ontario (DDO), the Regional Information Systems Working Group (RISWG), and the Long Range Planners of Ontario (LORAPON) GGH caucus.

The provincial land-use planning system is a policy-led system that is implemented through municipal planning efforts . To achieve municipal official plans that implement policy objectives of the Growth Plan, Ministry staff and municipal planning staff – as partners – need to problem-solve and collaboratively work towards conformity. This letter reflects a joint effort amongst LORAPON to articulate the challenges municipalities face in the coming years in achieving Growth Plan conformity. In response to the meeting with Ministry staff at the LORAPON meeting held in Peel Region on May 31, 2018, this letter provides specific suggestions on how the two draft guidance documents could be modified to provide more flexibility and clarity needed to achieve the Growth Plan policy objectives.

The principle of providing municipalities the flexibility to implement the intent and purpose of the Growth Plan is a broadly shared concern that allows the varying context and needs to shape good planning across the Greater Golden Horseshoe. As draft documents that apply to all municipalities within the GGH, the final guidance documents ought to produce a level of clarity, where it is required. Discussed below are comments and suggestions on the draft guidance documents. LORAPON extend its gratitude to the Ministry for providing the continued opportunity to share these concerns in an open, ongoing and constructive dialogue.

1. The Province should recognize existing regional and local municipal planning and land use contexts and provide municipalities with flexibility throughout the MCR process.
• Municipalities want to work in partnership with the Province but are asking for trust and flexibility when completing MCR work, including checking in as needed rather than at specific times which could result in delaying the MCR process to get approvals.
• The Province should explicitly provide municipalities the flexibility to phase their MCR across multiple OPAs in order to accomplish all the requirements towards conformity.

2. Guidance documents should indicate where flexibility is being given and where a more rigid process needs to be followed.
• Municipalities are asking the Province to identify in the Guidance documents cases where flexibility is being given and where a more rigid process should be followed.
• For example, if there is flexibility in the components of the Housing Strategy, this should be indicated in the document.

3. Delineation of MTSAs should be at the discretion of local municipalities and should only include areas where intensification is appropriate.
• Municipalities are requesting flexibility when determining what areas are appropriate for intensification in the delineation of MTSAs based on local contexts.
• Rather than be based on a 500m catchment area, the delineation of MTSAs should follow logical planning boundaries where possible and appropriate, to exclude lands that are not intended to meet the intensification objectives of the Growth Plan, including low density residential, parks and other natural heritage areas.
• The Province should consider providing clarity that although overlapping areas may be uniquely delineated, the municipality may specify overlapping areas, and the population and number of jobs within the overlapping areas can be counted towards the targets for each area and thus shared.

4. Municipalities are asking the Province to let municipalities set alternative targets for MTSAs and not require approval by the Minister.
• The process of receiving preliminary approval by the Minister for alternative targets for MTSAs prior to commencing the LNA is not feasible in many municipalities
• The Province should trust municipalities when setting alternative targets for individual MTSAs and work with municipalities through this process to identify any major issues early on in the process.
• The Province should consider removing the two-step process, which may prolong the MCR process in a way that was not intended. The documentation to support the alternative target request should form part of the final OPA for each municipality’s respective MCR.
• The Province should consider allowing for alternative targets as long as the average of the network meets the specified targets.

5. The duty to consult with Indigenous Communities rests with the Province.
• There are references in the document to consult with First Nations as part of the MCR process. Municipalities want to re-iterate that while First Nations are important stakeholders in the MCR consultation process, the statutory duty to consult with First Nations rests with the Province, not municipalities. Instead, this process should be done in partnership with the Province.

6. Municipalities are looking for clarification and a consistent approach on how students should be treated when setting targets for MTSAs.
• Municipalities have questions on if and how to account for students when setting density targets for MTSAs. Students are major trip generators but do not contribute to density if they live elsewhere. Additionally, the Guidance documents are unclear on how students living on campuses are to be counted when determining density targets for MTSAs.

7. Employment land conversions should be assessed based on a full set of criteria, not simply if there is a surplus of employment land.
• Both the Lands Needs Assessment methodology and the MCR Process guidance document imply that employment land conversions should only be considered if a surplus of employment land has been identified.
• The direction on assessing employment land conversions in the MCR Process guidance document should be revised such that employment land conversions are assessed comprehensively, based on a fulsome list of criteria, and not exclusively based on whether or not there is a surplus of employment land and/or a shortage of community land.

8. More discussion would be beneficial on the following topics:
• Employment trends
• Employment forecast

9. Municipalities are asking for a response and explanation from the Province when comments are not included in final documents

Municipalities would be happy to discuss these comments further with Provincial staff. For questions regarding the above comments, please contact Paul Freeman, Chief Planner, York Region at 1-877-464-9675, ext. 71534 or at Paul.Freeman@york.ca.

Sincerely,
Paul Freeman, MCIP, RPP
Chair, Long Range Planners of Ontario

Copy:
Marcia Wallace, Assistant Deputy Minister, Ministry of Municipal Affairs and Housing
Cordelia Clarke Julien, Assistant Deputy Minister, Ontario Growth Secretariat
Rino Mostacci, Chair, Regional Planning Commissioner of Ontario