While many of the policies…

While many of the policies proposed are reasonable there are also a number that are questionable in helping to create sustainable and affordable communities. below are a few points in particular that I take issue with.

1. Generate an appropriate housing supply

Provide flexibility for municipalities to allow for more residential development in rural settlements and multi-lot residential development on rural lands, including more servicing flexibility (e.g., leveraging capacity in the private sector servicing

- (non-agriculural) rural residential housing is rarely affordable for the average person. It is inaccessible to many and already requires a certain level of wealth (ie lots of time and money spent on car related expenses, ability to buy property). Excessive rural residences also contribute heavily to the fragmentation of farmland and natural areas, and takes away space for parks and outdoor recreation from those in urban areas, especially those who are also most in need of affordable housing. Providing that housing in urban areas would be much more efficient, affordable and practical. Rural settlement areas should be tightly controlled and allowing more of it is simply a bad idea.

Require municipalities to permit more housing on farms, including residential lot creation subject to criteria, additional residential units and housing for farm workers
- Rural settlement areas should be tightly controlled and allowing more of it is simply a bad idea. As per the previous point, this would be a great way to lose farmland. carefully planned housing for farm workers is one thing, but allowing many severances will inevitable fragment farmland.

2. Make land available for development

- Hard to choose exactly what to pick out here, but this whole point is kind of out there. As per the housing affordability task force: "Land is available, both inside the existing built-up areas and on undeveloped land outside greenbelts. … Most of the solution must come from densification. Greenbelts and other environmentally sensitive areas must be protected, and farms provide food and food security. Relying too heavily on undeveloped land would whittle away too much of the already small share of land devoted to agriculture.” (p.10)

There is plenty of existing land within urban boundaries available for development. Simply expanding them frivolously will create expensive unaffordable sprawl. A study by Neptis found similar results as far back as 2016.

4. Balance housing with resources

Require municipalities to designate specialty crop areas and prime agricultural areas, eliminating the requirement to use the provincially-mapped Agricultural System

Require municipalities to protect specialty crop areas and maintain minimum separation distances between livestock operations and houses, and promote an agricultural systems approach to support the agri-food network

Require municipalities to facilitate access to aggregate resources close to market and to protect minerals, petroleum and mineral aggregate resources

Require municipalities to protect water resources and features and encourage watershed planning

- all of these goals would be better achieved by the province taking responsibility and protecting exceptional farmland, especially class 1 farmland from development and sprawl. Farmland is incredibly important to the province as a whole and downloading decisions to municipalities on it is a poor idea. A provincial scale approach is needed to protect a provincial scale "good"

- with respect to watershed planning, this is literally the job of the conservation authorities, but other legislation has severely inhibited their ability to perform this function. This goal would be better achieved by giving authority back to the CAs, instead of downloading yet another responsibility down to municipalities.