Canadian Manufacturers &…

Canadian Manufacturers & Exporters Submission
Proposed Provincial Planning Statement

Ontario manufacturers support bold measures to densify communities and improve the supply of housing, so our sector can get the workers it needs to be successful. There is an urgency in that regard. In the CME’s 2022 Labour and Skills Survey, Ontario manufacturers reported that labour and skills shortages in the sector cost Ontario’s economy almost $4 billion in the last year.

Such policies must be balanced by corresponding protections for employment areas. People need housing as well as quality employment in their communities to pay for this housing. As such, the proposed Provincial Planning Statement (PPS) should prioritize the utilization of existing residential areas for additional housing while minimizing the disruption to critical, scarce, and sensitive protected industrial lands.

To accomplish this, provincial land use policies must include clear provisions and safeguards to deter speculation and encroachments. These provisions are absent from the current draft PPS circulated for input. In fact, existing protections for employment and industrial lands are proposed to be removed, inviting more disruption for Ontario manufacturers in the future.

To provide appropriate certainty for companies to attract the investment needed to propel our sector forward, CME recommends the following:

1. Design areas of employment to fulfill the original policy intent of Provincially Significant Employment Zones (PZEZs) and push further where this framework fell short

According to preliminary analysis conducted by the Toronto Region Board of Trade, there were hundreds of requests to convert industrial lands to residential in the Greater Toronto Area during the current Municipal Comprehensive Review (MCR). While a small number of conversions are being approved, these requests and the land speculation associated with them drive up property values, which increases costs and uncertainty for manufacturers.

This is happening because key industrial areas south of highway 401 in the Toronto area were omitted from the original designation of Provincially Significant Employment Zones (PSEZ) in 2019. Further, the province never acted on the original policy intent which was to provide long-term certainty for these areas and protect them from re-zoning. Without enforcement mechanisms, the policy became less relevant.

The removal of the Municipal Comprehensive Review is expected to only exacerbate the situation, as it will mean conversion requests for employment lands can now occur at any time.

What will replace the current framework for employment lands protection is not yet clear. On p.2 of the document outlining the implementation approach for the new PPS, there is mention of possibly identifying “select PSEZs or portions of PSEZs for the sole purpose of protecting lands exclusively for employment uses through an alternative approach (e.g., section 47 of the Planning Act)”. This lack of clarity suggests a willingness to let more industrial areas be converted in absence of an explicit guidance issued by the province to protect them.

While CME is not opposed to the idea of using MZOs to protect employment lands, we are concerned that the current wording suggests a very limited scope for the policy. Such a laissez-faire approach is concerning, as the re-shoring of our industries is happening now, and once an industrial area is converted to residential use, it is usually gone forever. We will not get another opportunity to get it right.

To be effective, an employment area framework must be comprehensive and provide enhanced protections to deter speculation driving up costs for manufacturing operations. As such, the new process should:

• Provide ability for both municipalities AND the province to create new employment areas. The province should retain a say and provide specific direction for planning in those areas to be implemented in coherence with economic development strategies. Consultation with other departments such as MEDJCT should also remained explicitly mandated when a subtraction from an existing Area of Employment is proposed.

• Enshrine long-term protection against conversion of industrial areas deemed critical (10 years or more) to provide additional planning and investment certainty. The longer areas are explicitly protected, the stronger the signal to companies that those areas be relied upon to operate, therefore increasing certainty that costly equipment and real estate will deliver a return on investment.

• Retain the current five-year limitation on when conversions can occur. Previously, the Municipal Comprehensive Reviews (MCR) allowed municipalities to preserve a holistic view by consolidating requests every five years. With this process effectively removed, conversions can now occur at any time, leading to a ‘death by a thousand cuts’ effect where incremental encroachments erode industrial areas over time.

• Differentiate across various areas of employment types. Building on successful approaches in Sydney, Australia and the London area in the UK, the PPS should provide differentiated guidance for different types of industrial lands, moving away from the current ‘one-size-fits-all’ approach. Where it makes sense, light industrial can act as a buffer between heavy industry and residential, allowing intensification in a more coherent way.

2. Explicitly prioritize the intensification of existing residential areas to end creeping encroachments on areas of employment

The proposed, modified definition of ‘areas of employment’ enables conversion of employment zones to residential development. The implementation is left to municipalities, which in our experience often pursue short-term residential tax revenue maximization to the detriment of long-term economic planning. As a general principle, residential development should take place in designated residential areas before employment land conversions are permitted. Not doing so may result in an over-designation of residential land and undermine densification efforts, while also compromising the availability of employment lands.

3. Include broader provisions to include appropriate buffer space between residential and industrial areas

Section 2.8.1.3. of the policy currently provides that residential uses shall be permitted on lands for employment outside of employment areas. In some case however, development on adjacent land may be problematic and lead to encroachments, impacting industrial operations. We would welcome more flexible language leaving room for appropriate exclusion zones to be created for other motives than public health and safety. For example, a company may need to be further removed from residential developments if it requires nighttime operations, generates noise or emissions.

4. Consult on a fully developed framework to protect industrial areas of employment prior to implementing the consolidated Provincial Planning Statement

The proposed process using s. 47 of the Planning Act (Ministerial Zoning Orders) needs to be fully detailed and take effect simultaneously with the new policy. At this time, there is simply too little known about the proposed framework to determine if it will be adequate and effective. We believe the policy must be crafted with explicit involvement of manufacturers to preserve operations and ability to attract investment for the future. There also needs to be a mechanism for ongoing consultations with relevant stakeholders on appropriate land use planning policies and designations