Dear Provincial Officals, My…

Dear Provincial Officals,

My comments reflect my expertise as a PhD land, environmental, and resource economists, including my 25 years research experience and findings. I am a full professor in the School of Planning at the University of Waterloo.

The proposed PPS abandons important principles that were contained in the previous growth plan and PPS. Those principles encouraged sustainable urban intensification and protection of natural assets. They are critical to building sustainable and livable environments. With climate threats increasing, they are also crucial for protecting the people of Southern Ontario against climate flood and heat island risks. Encouraging compact development and intensification, while maintaining blue green infrastructure, is also fiscally sound, as it encourages municipalities to provide housing at least infrastructure cost.

The new PPS appears to be based on incorrect assumptions about housing needs and how to address them. It’s well known that land for housing is not scarce. Instead, the major barriers to housing provision including investor led financing models and too low “as of right” unit numbers on all residential lands. As of right zoning for 4 units, plus floating zoning for 10 unit apartment buildings, on all existing residential lots, would go a long way towards addressing housing supply and affordability. This policy was the consensus view of the housing task force. Policies need to encourage parking lot conversion, instead of ag land conversion.

15 years of housing research indicates that households want housing, green space, and urban amenities. They can only afford intensified housing with reasonable transportation costs.

The provinces policies are not evidence based. They don’t appropriately consider household sizes and housing needs. Such a major policy deserves credible analysis.

Finally, allowing additional rural housing disproportionately harms ag land. My thesis research showed how quickly ag land uses can be destroyed via land market pressures as other uses harm the viability of agriculture. It’s a bad idea.

Finally uncertain policy environments harm the real estate development industry. No one can keel up with the chaotic and unpredictable changes.

thanks,

Dawn Parker
Professor, school of planning
University of Waterloo