Section 2.8.2 could be…

1. Section 2.8.2 could be further strengthened by the addition of language allowing the Minister of Municipal Affairs or the Minister of Economic Development, Jobs and Trade to step in if a municipality is considering employment land conversions that negatively impact businesses.
2. Re-instate a process to consolidate employment land conversion at one point in time, similar to the previously removed Municipal Comprehensive Review (MCR). In absence of such a process, we remain concerned that a patchwork of land planning processes will emerge, generally increasing complexity and red tape for Ontario businesses. This is especially true for manufacturers with several facilities across the province.
3. The province has not yet articulated a process to replace the Provincially Significant Employment Zones (PSEZ), to ensure it maintains strategic oversight on the management of lands connected to manufacturing facilities and critical infrastructure, in support of the province’s long-term economic needs. We believe the upcoming release of an Advanced Manufacturing Strategy provides a perfect opportunity to develop such a process, and the PPS should include some reference to that effect.
4. Guiding language in the PPS would bring greater clarity to new authorities in Bill 185 which create new exceptions under anti-bonusing rules contained in the Municipal Act and the City of Toronto Act. Based on our analysis, those could be used by the province or municipalities to attract new manufacturing investment with measures such as property tax abatements (a tool routinely used by U.S. agencies to poach manufacturing firms from Canada).