1. What are your overall…

1. What are your overall thoughts on the updated proposed Provincial Planning Statement?

According to the Stockholm University Resilience Centre and others, biodiversity reduction and climate change are the biggest threats facing humanity1.

1“Earth Beyond 6 of 9 Planetary Boundaries”, Richardson et al., Science Advances, 2023.
Therefore, the Township is pleased to see that PPS 2024 Section 2.9.1 Climate Change has been strengthened from the 2020 Provincial Policy Statement and that watershed planning is mandatory for the first time (Section 4.2.3)

The Township is also pleased that the province has removed permission for lot severances on prime agriculture lands as farmland will be better protected for food security and sprawl will be more likely curtailed on these agricultural lands.

The Township is pleased that PPS 2024 section 3.2.1 has added transportation systems “should be provided that support the use of zero and low emission vehicles”.

However, the Township does not support the proposal by the province to repeal regional planning. Shifting of planning authority away from regional governments to lower tier municipalities that are smaller and more vulnerable to development pressures with not promote good community outcomes. This seems to make little sense given the province is simultaneously requiring planning at the (regional) watershed scale.

The Township does not support new settlement area creation without the Comprehensive Review process. This could result in leap-frog sprawl development that destroys farmland, destroys natural heritage features, and does not support transit.

The National Task Force for Housing and Climate has stated that, “If we build the next 5.8 million homes the same way we built the last 15 million – using inefficient design, carbon-intensive materials and predominantly low-density, car-dependent land use patterns – Canada will exceed its carbon budget by 2050 on housing alone". (Unfortunately, over the past five years, 75% of housing built in Canada was in greenfields).

The Task Force report, Blueprint for More and Better Housing, presents a reminder that aiming for a total housing target can lead to a “build anything anywhere” approach. “An overlooked strategy to provide single-detached houses for younger and newcomer families is in “recycling” and “repurposing” the existing stock, rather than developing new car-dependent subdivisions further afield to build this typology. The key to this strategy is to focus on developing desirable housing alternatives for older Canadians, be it co-housing, co-living, smaller-scale retirement living or simply adding suites to their houses.”

The Township supports the report’s finding that, “Adding one Accessory Dwelling Unit to just 10% of the suitable single-family properties located in many Ontario municipalities would meet between 8% and 30% of provincially mandated housing supply targets. With the right suite of policies these could be added quickly and gently and with much less carbon, as has been shown elsewhere in North America.”

2. What are your thoughts on the ability of updated proposed policies to generate appropriate housing supply, such as: intensification policies, including the redevelopment of underutilized, low density shopping malls and plazas; major transit station area policies; housing options, rural housing and affordable housing policies; and student housing policies?

The Township is pleased the 2024 PPS returns the definitions used in the 2020 PPS for affordable housing and low and moderate income, and in section 2.2.1 (a) returns the requirement for affordable housing targets to be established.

The Township supports coordinating with housing Service Managers and post-secondary schools on planning housing including student housing.

The Township supports the 2024 PPS revocation of policies in the proposed 2023 PPS to allow lot creation on an agricultural lot. The Township supports PPS 2024 section 4.3.2.5 allowing two additional residential units on a lot.

The Township supports the intensification of development along transit corridors (section 2.4.2), re-use of shopping malls and plazas for housing, and the identification of strategic growth areas (section 2.4.1) but would prefer the growth area targets were mandatory as in the 2020 PPS.

The Township would prefer to see the conservation and redevelopment of existing rural housing stock on Rural Lands returned to the 2024 PPS (section 2.5.1).

The Township supports the direction that Rural Settlement Areas shall be the focus of growth and development (section 2.5.2).

The Township supports section 2.6.1 (c) that permits “residential development, including lot creation, where site conditions are suitable for the provision of appropriate sewage and water services” which replaces the more nebulous wording of the 2020 PPS “that is locally appropriate”.

However, the Township needs much more information from the Conservation Authorities on where those site conditions are located, given that almost all of Tay Valley Township is a highly vulnerable aquifer.

3. What are your thoughts on the ability of the updated proposed policies to make land available for development, such as: forecasting, land supply, and planning horizon policies; settlement area boundary expansions policies; and employment area planning policies?

The Township has no concerns with the proposed forecasting time frame or source of data from the Ministry of Finance.

The Township supports the standardization of the use of modular homes as they can be manufactured rapidly and provide housing quickly.

The Township supports the location of growth within settlement areas.

However, the Township does not support the removal of the PPS 2020 requirement that planning authorities establish and implement minimum targets for intensification and redevelopment within built-up areas from section 2.3.2.1.

The Township does not support the weakening of the criteria for settlement area identification or expansion and the opening up of the timing for settlement area expansion. Currently, a planning authority may identify a settlement area or allow the expansion of a settlement area boundary only at the time of a comprehensive review and only when certain conditions have been demonstrated.

The 2024 PPS would permit the planning authority to identify a new settlement area or allow a settlement area boundary expansion at any time instead of during a Comprehensive Review with criteria that should be considered rather than shall be considered. This weakens planning from the perspective of the public good and strengthens the ability of developers to influence Councils.

4. What are your thoughts on updated proposed policies to provide infrastructure to support development?

The Township supports the addition of “including the quality and quantity of water” to section 3.6.1 Sewage and Water Services as a requirement for protection of rural drinking water.

The Township supports the hierarchy of preferred servicing (municipal, communal, private) and strongly supports the addition, in section 3.6.4, of a requirement to consider the financial viability of servicing that is sustainable for a municipality over the long run.

Section 3.6.7 is supported by the Township and has recently become particularly relevant to Tay Valley Township since the Town of Perth has indicated it is no longer accepting septic waste. “Planning authorities may allow lot creation where there is confirmation of sufficient reserve sewage system capacity and reserve water system capacity. Reserve sewage system capacity includes approved capacity to treat and land-apply, treat and dispose of, or dispose of, hauled sewage in accordance with applicable legislation but not by land-applying untreated, hauled sewage.”

The Township supports the addition of a new section 3.6.8 (g) that includes “cumulative impacts on a watershed scale” in stormwater management. The watershed is the appropriate scale for planning and cumulative impacts are the meaningful measure of impact.

The Township supports the inclusion of green infrastructure in the 2024 PPS. And the Township supports the addition of section 4.3.6 that supports local food production.

The Township supports the addition of “energy storage systems” to the list in section 3.8 of the energy supply opportunities municipalities should provide.

As a Township with 44% of its residents over the age of 55, the Township supports the addition to section 3.9.1 Public Spaces, of wording stating municipalities “should meet the needs of persons of all ages and abilities” and the addition of the word “inclusive” to describe the type of communities municipalities should promote.

5. What are your thoughts on updated proposed policies regarding the conservation and management of resources, such as requirements to use an agricultural systems approach?

The Township supports an agricultural system approach as adding value to land use planning, but it will be difficult for smaller rural municipalities to implement the system without support from consultants or from their upper tier County.

The Township strongly supports the protection of natural heritage features as its tax assessment is dependent on these features (especially lakes and rivers) and because it recognizes the role forests, and in particular, wetlands, play in mitigating climate change.

The Township supports the addition of the “protection of drinking water supplies” not just “municipal drinking water supplies” as was in the 2020 PPS. Protection of well water is of high importance to the Township.

6. What are your thoughts on any implementation challenges with the updated proposed Provincial Planning Statement?

Increased emphasis on Indigenous consultation is supported by the Township. However, Indigenous groups need more financial support to hire staff to respond to municipal requests in a timely manner.

The Township supports the inclusion of “equity deserving groups” in section 6.2.3 with respect to public consultation.