Thank you for this…

Thank you for this opportunity to comment on ERO 019-6813 regarding the proposed Provincial Planning Statement. Bill 97 has already received royal assent. It seems wrong that it has while the comment period for some items is still open. This government has already made many drastic changes to land planning policy already and are now doing it again. Even prior to all these changes I heard about how challenging things were from municipal planners(workload with development applications) and after researching some comments from planners and Council members of various municipalities, it seems that this government is not listening carefully enough to what people and lower levels of government are saying. One Councillor I heard said developers are thrilled among other things but then had to restrain himself. Some municipalities had significant concerns about the definition of employment in employment areas but I see the Province still went ahead. Even the Auditor General Report 2021 it states that the growth plan was done to avoid negative outcomes of sprawl by creating compact, walking, transit supportive cities which protects valuable farmland, natural heritage and improves pollution, health, traffic etc. Yes housing and housing affordability is an issue but it can be done by increasing density in the cities and rural settlement areas which then protect farmland and natural heritage vital to many ecosystem services. Missing middle housing would be good in many areas which increase density and offers different housing options and perhaps could be built quicker than other higher density buildings. Compact mixed use cities where people can walk and use transit to everything they need reduces emissions and is less costly in terms of transportation costs. Citizens benefit from lower transportation costs if the city is compact.
Climate change is an existential threat to humans and biodiversity. There is not enough policy regarding this and by not enforcing density targets and allowing municipalities to enlarge whenever without conditions is wrong and does nothing to address climate change or farmland protection. I believe the current PPS and Growth plan are much better land use documents than what you have proposed. Once again, this government seems to be going backwards in terms of land use policies, the environment and farmland.
Natural heritage should apply in settlement areas too.
2.1.4 "Avoiding development and land use patterns which may cause environmental or public health and safety concerns" and "promoting development patterns that conserve biodiversity" as per the current provincial policy statement should remain. Public health and safety concerns are mentioned in 4.3.3.2. and 2.8.1.4 and 3.6.1b)3 but there are other areas and things than this can be an issue. For example, cemeteries have the same nutrients and pathogens of many of the drinking water threats listed for source water protection but are not included as a drinking water threat. They are also permanent so there should be more criteria for their establishment and should not be allowed in prime agricultural areas unless they are close to the urban centre in strategic growth areas and the proper hydrogeological studies are done.
There should be minimum targets for intensification and redevelopment within built up areas as otherwise there is no reason for municipalities to follow that. The preamble states this statement sets the policy foundation for regulating the development and use of land. “Should” and “encourage” or “promote” is not regulating. It would be far better to say municipalities shall have sufficient lands and mix of uses for a complete community (and compact) for walking and using transit.
2.4.1-all municipalities should be required to identify growth in strategic growth areas to achieve complete communities not just large and fast growing. Same with major transit station areas.

Settlement Areas and Expansions-I agree that settlement area boundaries can be expanded whenever necessary as comprehensive reviews take a very long time. But they should still have to meet conditions as per current policy and not “should consider” There should be density targets for all municipalities and not just large and fast growing for all items not just settlement expansion lands. There seems to be too many” should “and “encourage” language in this document with means nothing has to be done if municipalities don’t want to. Is that so no one can appeal decisions? If it is only a should than no one can say they are not following policy which means no one can say they do not conform to provincial policy. Leadership is required. The Province should direct municipalities to meet certain targets not let them decide. This proposal may increase housing but at the expense of other things. This does not benefit the Province as a whole or Ontarians. The current PPS and Growth Plan with density targets are much better. Farmland is a vital finite resource and this government needs to realize how important agriculture and farmland is for the long term needs of its residents and protect it. Supply chain issues during Covid, climate change , soil health, pricing for fertilizer and fossil fuels all impact farmers. For the 2016 Census of Agriculture the loss of farmland in Ontario was 175 acres per day and and in 2022 that number went up to 319 acres/day. See link to OFA. In an article in Farmtario titled Senate study connects Canadians to soil health, Senator Rob Black, chair of the Standing Committee on Agriculture and Forestry states “We need at the federal level, to be always thinking of the sustainability of agriculture, and we can’t do that if, as organizations in the province say, we’re losing 319 acres a day. “ That article ended with a quote from him ”We need to feed Canada and the world, and we’re not going to be able to do that if we don’t have the soil health and the capacity to do that.”
4.3.1.1. The proposed statement says planning authorities are encouraged to use an agricultural system. Some municipalities having both urban and rural areas do not have the expertise with agriculture. In my experience . many council members and even the planners are not very familiar with MDS or the importance of agriculture. The mapping of the agricultural land base has already been done by the Province(and they do have the expertise) and should remain as in the Growth plan 4.2.6.2. The municipality can then still refine it as per the Guidelines.
It will also be a huge mistake to allow the residential lots in prime agricultural areas as per 4.3.3.1a) . There is enough conflict between farmers and non farmers and this will introduce more. It will also limit farm operations for manure spreading and will destroy livestock farmers ability to expand due to MDS. It will cause more development pressure as well. I understand the Province has walked back from this.
I agree with 4.3.2.5 that two additional units may be permitted subordinate to the principal dwelling but it should not be allowed to be severed from the lot as this leads to the same issues as mentioned above and residential lots. If It is severed then it is not subordinate. If farmers build additional residences for hired help or family members and then they do not need them they should then have to rent them out which would help the housing crisis or leave them empty if they wish. They should not be allowed to be severed. As they are residences associated with the farm MDS would not apply for that specific farm*(but would be to other farms) and there would be no setbacks for manure storage/spreading etc and could not complain about farm issues-ie dust, noise etc.
4.3.5 b) should be removed entirely. This is a loophole for developers and municipalities to intrude into prime ag areas and is not needed especially if municipalities can expand their settlement areas at any time. The focus of growth shall be to settlement areas both urban and rural. If municipalities are to have enough lands for mixed uses in strategic growth areas there is no reason for this policy.
Municipalities should have to do watershed planning.
In the draft section 6.2.2. It says planning authorities” shall” undertake early engagement with indigenous communities and in 6.2.3 are” encouraged” to engage the public. It should be shall for both to be fair. Not having public participation in land planning decisions that will directly impact them makes them resentful especially if they are not included in early involvement as it appears decisions are made without consideration of the public and not transparent. But then again, it has been said before this government does not like the public involved in land use decisions. The public can comment of ERO's. but do you listen?
I do agree with 4.6.1 that only “protected” heritage properties shall be conserved.
I do agree with 4.2
Extraction in Prime Agricultural Areas- It should be a requirement to rehabilitate to an agricultural condition. If that is not possible, then these activities should not occur in prime agricultural areas.
Transition: There are development applications in the works that have not been completed. All planning documents have been prepared with current planning policy. Those should be allowed to continue to completion. To insist all decisions by a certain date follow this new policy is such a waste of people’s time and money.
The vision for the current PPS is much better. The draft vision says it all. Housing only. Wise use and management of resources will be encouraged? Not leadership language and not what people of Ontario want. All paragraphs in the current PPS starting with strong, liveable and healthy communities on page 5 and up to and including strong communities, a clean and healthy environment,…..on page 7 should remain. To me, through this draft policy statement that the environment, climate change, farmland, public safety, preventative approach are not priorities and this is just short term thinking for housing and developers. In the current PPS” Taking action to conserve land and resources avoids the need for costly remedial measures to correct problems and supports economic and environmental principles.” and “The Province must ensure its resources are managed in a sustainable way to conserve biodiversity, protect essential ecological processes and public health and safety, provide for the production of food and fibre, minimize environmental and social impacts,, provide for recreational opportunities (e.g. fishing, hunting and hiking) and meet its long-term needs,” These were statements Ontarians could live with and be proud of. I think this draft goes against this.
Thank you