Thank you for the…

Thank you for the opportunity to provide comments on the proposed Provincial Planning Statement . The Town of Halton Hills’ comments are attached and summarized below.

Summary of Key Concerns:

• Key comments that staff wish to highlight regarding the sweeping changes proposed through Bill 97 and the proposed Provincial Planning Statement include the following:
• Overall, the changes proposed through the draft Provincial Planning Statement and Bill 97 appear to be heading back to the planning regime as it existed prior to introduction of the Growth Plan for the Greater Golden Horseshoe in 2006, wherein there were limited growth management targets and requirements for the municipalities within the GGH.
• With respect to Site Plan Control for 10 or fewer units, staff believe that the regulations should be extended more broadly to apply to all parcels proposed for multi-unit residential developments, to ensure that health, safety and accessibility considerations are addressed.
• Staff does not support the proposed change to allow for appeals to an Interim Control By-law at the time of initial passing rather than only at the time of extension as this creates an unnecessary burden on municipalities and the OLT and increases the possibility that land uses that are contrary to the public interest are established.
• Staff have significant concerns with the proposed changes regarding Employment Areas. Staff believe that prohibiting institutional and commercial uses is not in keeping with the proposed PPS goal of supporting a modern economy, and that it will require that employment areas in the Town, such as the Premier Gateway Employment Area, to be stripped of existing institutional and commercial land use permissions.
• Staff have concerns that overarching growth forecasts post 2051 will no longer be prepared by the Province, requiring individual municipalities to ultimately carry out population and employment forecasting on their own. This creates considerable uncertainty for local municipalities regarding the preparation of longer-term growth forecasts.
• With respect to settlement area boundary expansions, the proposed changes are of concern to staff. Allowing applications for urban boundary expansion at any time will create a lack of stability with respect to a municipality’s urban boundary and in the case of Halton Hills, given the extent of lands approved for future growth to 2051, this policy provision could lead to premature applications to expand the Town’s urban boundary.
• Staff are of the opinion that the proposed changes related to development within prime agricultural areas are significant and could have long term implications to the Town’s agricultural land base.
• Staff have significant concerns with the proposed change to allow new applications for rural lot subdivisions outside of settlement areas.
• Staff have significant concerns with the removal of the definition and references to “affordable housing” from the proposed PPS and strongly recommends that the Province re-introduce the existing definition, policy framework and requirements with respect to affordable housing in Ontario.
• As it relates to the climate change policies of the draft PPS, staff recommend that the existing Growth Plan and PPS 2020 policies regarding climate change remain.

Transportation

• Staff question the removal of the term “persons with disabilities” through the document. It is important to recognize that the term ‘persons with disabilities’ is used in the Accessibility for Ontarians with Disabilities Act and the Planning Act. Many of the Town’s transportation infrastructure is based on providing accessibility for “persons with disabilities”. Staff suggest that the term continue to be used in the new PPS to ensure alignment with the AODA.

• Staff disagree with the removal of section 2.1.4 (g). It is crucial for the Town that the necessary infrastructure and public service facilities are/ will be available to meet current and projected needs. This is an important component when planning any type of housing. Town staff request to keep this policy in the new PPS.

• It is vital to recognize the importance of transit to support complete communities and high-density areas. Staff disagree with the removal of “and transit in areas where it exists or is to be developed” and recommend including “and transit as appropriate” at the end of Section 2.2.(C).

• Town staff support the proposed amendment under Section 2.4.2 which allows municipalities that are not in the list of Fast and Growing Municipalities to continue to delineate MTSA boundaries and establish minimum density targets.

Water/wastewater infrastructure

• Staff understand that Section 3.6.1 b) is consistent with the new Complete Linear Infrastructure Environment Compliance Approval (CLI ECA) process. However, with the removal of site plan control requirements for most projects with fewer than 10 residential units, there are no tools to ensure that these requirements are met for those types of proposals. Staff recommends that consideration is given to incorporating appropriate tools for municipalities to ensure that these requirements are met for all development proposals.

• It is anticipated that the Town will not be able to implement Source Water Protection policies as per Section 3.6.1 f) when dealing with as-of-right developments i.e., up to two additional residential units or fewer than ten residential units which are exempted from Site Plan Control. A different mechanism to implement these policies, e.g., through the OBC, is potentially needed. In addition, the Region of Halton is currently responsible for implementing source water protection with the exemption of the implementation of salt management plan and water balance. Neither of these processes are considered under a building permit.

• Questions remain on the role of the Region in administering some of these processes i.e. Source Water Protection, Communal sewer systems, etc. if the role of the Region is to be transferred to the Town, additional resources such as technical expertise will be required in order to meet the Provincial requirements in the new PPS.

• Clarification is required regarding policy 3.6.8. Particularly Policy 3.6.8 g) indicates that planning for stormwater management shall align with any comprehensive municipal plans for stormwater management that consider cumulative impacts to stormwater from development on a watershed scale. Additional information is required to assess what is excepted from the local municipalities to satisfy this requirement.