Dear Premier Ford and…

Dear Premier Ford and Minister Clark

Thank you for the opportunity to comment on the proposed new Provincial Planning Statement. I have been a Registered Professional Planner in the Province of Ontario for over 19 years and I am employed in a Director-level role in the planning field. I am also the President of two Condominium Corporations in Ontario. I am sending my comments confidentially in order to ensure there is no conflict between my professional opinons and those of my employer.

As I see it, the proposed policy statement attempts to achieve two goals: 1) significant intensification of new development on serviced land near transit stations; and 2) significant growth of low density, ground related housing in un-serviced areas inaccessible by transit. I support the first goal and commend the government for being bold in implementing as-of-right development in urban centres. However, the second goal is entirely contradictory to the first and such a contradictory approach to urban planning policy can be detrimental to the development and well-being of municipalities. In my opinion, eliminating the award-winning Places to Grow Plan and replacing it with a much simplified and contradictory policy document will have life-long negative impacts on the health and welfare of Ontarians. This proposed policy document provides scant direction to municipalities and essentially downloads growth planning to landowners . In my opinion, the proposed policy statement has several flaws, as follows:

1. Lack of Coherence: The policies lack a unified vision and fail to provide a clear direction for urban development. This lack of coherence and conflicting objectives will result in inefficient and unsustainable new development. For example, if one policy promotes density and compact development while another encourages sprawl, car-dependent infrastructure, and expensive new servicing, it creates confusion and undermines the overall effectiveness of urban planning efforts.

2. Inefficient Resource Allocation: There appears to be no current research-backed justification for the policies. Many of them are antithetical to current professional practice (highways and low density land consumptive development). The policies will lead to inefficient allocation of resources. Urban planning requires careful allocation of resources maximizing redevelopment, existing infrastructure, and public services so that they can be budgeted for. Many of the proposed policies will make it challenging to prioritize and allocate these resources effectively, with municipalities competing for limited resources. This can result in wasted investments, underutilized infrastructure, and disparities in service provision across different areas of the province.

3. Uncertainty for Stakeholders: The contradictory policies especially the lack of comprehensive regional planning will create uncertainty for various stakeholders, including developers, investors, and residents. When policies are inconsistent, it becomes difficult for these groups to make informed decisions about investment, development, or even daily activities. Land pricing will become even more volatile and speculative. The constant changing of planning policy, legislation and regulation is extremely difficult and expensive to implement at the regional and local level. Uncertainty can hinder economic growth, discourage investment, and in my experience is leading to delays in urban development projects.

4. Inequitable Outcomes: Contradictory policies can exacerbate social and economic inequalities within the province. For example, if one policy emphasizes affordable housing and inclusivity, while another promotes luxury development and gentrification, it can result in displacement and segregation of marginalized communities. This has been happening for years and should have been addressed head on in any new planning policy – it has not. Inconsistent policies can widen the gap between different socioeconomic groups, leading to social tensions and unequal access to resources and opportunities.

5. Environmental Impact: Contradictory urban planning policies will have negative environmental consequences. It does not appear that this government has spent much time consulting with environmental experts, either here or internationally. One can see the impacts of a low density, land consumptive development pattern right now in Halifax, where subdivisions are burning. The proposed residential lot creation on prime farmland will result in more vulnerable populations and investment losses due to environmental disasters such as fires. It is critical that the Conservation Authorities be given back their ability to advise municipalities on natural heritage matters as they are directly linked to natural hazard planning. Taking this away has already resulted in delays and extra costs for the development community and the municipalities.

6. Long-term Planning Challenges: Contradictory policies make long-term planning and implementation difficult. Urban planning requires a long-term perspective to accommodate future population growth, technological advancements, and changing societal needs. In the proposed policy, municipalities would be able expand settlement area boundaries (SABE) at any time (because there is no MCR) and the criteria for expansion are less stringent, especially for critical environmental constraints. Devolving growth planning to individual municipalities means the need for more planners (they are scarce), more resources and an inconsistent approach to public service planning. How does this fix the housing problem?

Addressing these contradictions in the proposed policy statement is crucial to ensure effective and sustainable urban development. It requires a comprehensive and integrated approach to align various policy objectives, engage stakeholders, and establish a clear vision for the province’s future. I encourage the government to proceed with the necessary policy changes to encourage high density infill development near the existing and new transit stations the government has been (rightly so) funding and accelerating, provided these communities can be well designed; however, please take a pause on the contradictory suburban and ex-urban expansion policies you’ve included in the proposed policy statement.

As noted by many others, the housing issue in Ontario is not a planning or a land supply problem, it’s a financial problem. Growth of the entire housing sector in Ontario (except for a tiny percentage) is left to the free market. While this has produced much needed housing, especially in the GTA, it has resulted in increasingly expensive housing. Some lessons should be learned from places like Vienna, Austria which adopted a public housing development plan in the 1930’s that continues to this day. Citizens of Vienna do not spend upwards of 30 – 50% of their disposable income on housing, and the middle class have access to well built, transit friendly and predictably–priced homes. Ontario is nowhere near this because we have not for years addressed the financial side of housing development, and the proposed changes to the policy statements are not going to change the cost of housing.

I urge you to please put a pause on the proposed policy statement and engage with professionals both locally and internationally to adopt bold best practices. The proposed policy statement is not best practice but rather reverts to a 1980’s-style approach with all of the predictable negative impacts this will cause society.