Comments on the 2023/2024…

Comments on the 2023/2024 PPS revision, ERO number 019-8462
My comments are based on the following professional qualifications. I hold a PhD in agricultural and resource economics from the University of California at Davis, with sub-fields in environmental and resource economics and econometrics. I’m a full professor in the School of Planning at the University of Waterloo. I have a large body of funded research and academic publications on housing and land economics and the environmental impacts of residential land use. While my comments represent only my own professional viewpoint and not that of my university or collaborators, I have also collaborated with Canada Mortgage and Housing Corporation, UrbanSim, and the Ontario Municipal Property Assessment Corporation on housing market research.
My responses to your questions follow:
1. What are your overall thoughts on the updated proposed Provincial Planning Statement?

There are some good things proposed, but on the whole, the new PPS encourages urban boundary expansion and the conversion of agricultural land and natural areas for housing. That approach is unsustainable, as agricultural land conversion is irreversible, and our natural areas provided irreplaceable ecosystem services, including water purification, groundwater recharge, climate mitigation and adaptation.

In my view, density targets should be maintained at the municipal scale only. Right now, policies invite too-high intensification in urban cores and along transit routes, while maintaining too-low density in newer suburbs. Municipality-wide density targets could work in tandem with some good ideas in the new PPS, encouraging conversion of strip-malls and large power centres into higher density mixed use.

We also need to design policies that encourage consolidation and densification of employment lands. For example, many car-dependent industrial and business parks host services and recreational uses like martial arts studios, dance studios, chiropractors, dentists, etc. Subsidies should be provided for these uses to located in mixed-use developments close to transit, freeing up industrial lands within urban boundaries for industrial use.

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?
• As I said above, intensification targets should be only at the municipal scale.
• YES to redevelopment of shopping malls and plazas. To make this work economically, subsidize creation of multi-level parking structure to replace surface parking, which could be later converted to pickleball courts, indoor pools, and other active uses.
• MTSA policies have failed and will continue to fail, because they incentivize conversion of already-dense areas to higher-density, unaffordable condos. These markets are driven by international capital and small condo investors, not by housing market needs.
• “Housing options” means you are leaving provision of affordable and “missing middle” housing to the market. That approach will continue to fail, as it has been failing. If the Province wants housing options to be created, they need to 1) implement zoning that allows 4 units on all parcels, 10 units on most, and mid-rise on most higher-level roads. 2). Strict limits to low-or-mid-rise zoning in almost all areas, to contain land-value uplift and facilitate missing middle housing. 3) Provide non-profit housing finance for all builds that provide housing types that meet community needs (i.e. enough bedrooms and adequate public greenspace). 4). Provide public lands for affordable housing.5) Alter inclusionary zoning to require 10-20% of units to be affordable 6). Included unit mix (i.e. number of bedrooms with enough living space) in zoning. 7) Subsidize creation of convertible multi-level parking structures for small apartment and mixed-use builds, to create the needed density to support transit-oriented development.
• Rural housing development should be limited so as to support our natural heritage features.
• Universities should be required to provide more student housing, and this should be facilitated through zoning.
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?
• Housing and land needs assessment needs to be based on actual housing and land market simulation models, and not on projections based on historical trends. These models exist. They are not being used; unclear why not. The difficulty of accessing property transaction and assessment data is one reason. Putting those data in private hands, with the mandate for confidential, individually negotiated pricing, was a terrible mistake of the land administration, which harms housing market competitiveness. Housing assessments must match households to home types, not be based on average households and average dwelling sizes per the census. This means municipalities need to all gather bedroom/units on building permits.
• Planning horizons should be limited, as net migration is never well projected.
• Settlement area and boundary expansions should be limited and should be constrained to preserved agricultural land and natural heritage features. Does it make sense to consider more urban growth outside Southern Ontario, on the Canadian Shield?
• Re employment policies, see comment above. Lands inside municipalities are not well used.
4. What are your thoughts on updated proposed policies to provide infrastructure to support development?
This question pre-supposes that urban boundary expansions are a good idea. I disagree with that premise. But we know that right now with development charges taken away from municipalities, they can’t afford to build infrastructure.
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?
• Seems like an excuse to allow for more farmland conversion. Current cropping systems may not be future cropping systems. Consider, for instance, the transformation of Ontario strawberry production with the new late-season everbearing varieties and increased greenhouse production. When coupled with supply chain disruptions due to the pandemic, fuel costs, and climate-induced production challenges, local production will likely only increase. We need to preserve our precious, irreplaceable agricultural land to maintain its option value for the next agricultural innovation, and to be able to adapt to climate challenges.
6. What are your thoughts on any implementation challenges with the updated proposed Provincial Planning Statement? What are your thoughts on the proposed revocations in O.Reg. 311/06 (Transitional Matters - Growth Plans) and O.Reg. 416/05 (Growth Plan Areas)?
• See above. The problem with the growth plan is that it forced municipalities to plan for the wrong number of people, and it placed too much weight on housing and land needs assessments, which used poor and inaccurate methods. I would rather support municipal-wide density targets across the board, for almost all municipalities. At the end of the day the Province does not control where people move to or from, nor should it. Development regulations should provide a level playing field for all municipalities and use the tools I suggested above, under facilitating all housing types, to create gentle density and sustainable intensification everywhere within our urban boundaries. It works in Europe and could work here.