I’ve read through the…

I’ve read through the proposed amendment and offer the following comment directed at a few topic areas of interest to me. I’m coming at this review with an implementation experience perspective as a municipal planner working with the GGH P2G Plan since its inception.

My comments will relate only to high level overview statements respecting the amendment due to the very short timeframe for review and comment (Jan 15 – Feb 28, 2019) on the over 70 pages of text.

As stated as the purpose for the amendment, there is a belief from the new Ontario government that the P2G (2017) plan needs revision “to address policies seen as potential barriers to the development of housing, job creation and business attraction.” From a high level perspective, there are significant difficulties with the amendment for the following reasons:

1) The amendment provides for a reduced prescriptive planning intent and gives additional subjective consideration for planning policy direction for municipalities within the GGH. This is seen, for example, in proposed wording clauses to remove the requirement for municipal employment strategies, allow for the creation of varied municipal employment density targets, and permit the over-designation (wasted land) for potential employment purposes. The proposed policy wording changes appear to be reflective of a short term ‘open for business’ perspective without necessarily giving much thought to the implications this has to necessary strategic investments for infrastructure in the region.

2) Long term aspirational objectives to protecting highly valued natural and agricultural assets seem to have given way to local development interests in the region. As an illustration, the extent of high quality agricultural lands will be determined at a municipal level using local knowledge as to what is valuable and what is not. The province will then compile the results of this information at some future date. The ground-truthing on the importance and extent of prime ag lands will vary across the region. As a result, instead of considering the ag lands as a long term strategic resource to be protected for the overall provincial interest, much of the land will be viewed more as a consumable item as has been the past practice since at least the Second World War.

3) The amendment makes several provisions to permit additional land supply to become available in urban/rural locations. These permissions are by way of relaxed settlement expansion restrictions and also recognition of new settlement opportunities in rural locales. The underlying assumption that will result from this revision is that more raw development lands will equate to lower costs and then ‘affordable’ development will happen. This is a faulty assumption as there are already ample development lands available within the GGH, and affordability issues are present (see work by Victor Doyle (Nov/Dec 2018), "Greater Golden Horseshoe Ground Related Housing Supply" and also Pembina Institute's Rian Allen and Philippa Campsie (October 2013) "Implementing the Growth Plan for the Greater Golden Horseshoe-Has the strategic regional vision been compromised?" – see attachments. The consideration of ‘affordability’ is a common issue that is directed at all urban areas of the world facing strong growth demands. It is a multi-faceted problem and providing more land does not equate to more potential affordable housing. A major challenge to the provision of ‘affordable’ new development in place for all GGH municipalities is the present deficiencies of existing public infrastructure as well as redevelopment effort in already built-up areas.

4) Proposed revision definition semantics of well-understood words such as ‘urban sprawl’ to the proposed ‘unmanaged growth’ phrase does not add any useful purpose, i.e., this is quite meaningless as all growth in the GGH has been managed by way of provisions of the Planning Act since 1945. Land use planning that has embraced sprawl – the uncontrolled expansion of urban areas onto agricultural areas within the GGH is well understood, and its impacts well researched, e.g., Pamala Blais (2011), "Perverse Cities - Hidden Subsidies, Wonky Policy, and Urban Sprawl"; Ontario Environmental Commissioner (2008), "Economic Implications And Consequences Of Population Growth, Land Use Trends and Urban Sprawl in Southern Ontario"; Pembina Institute’s Caroline Kim (2019) "The Way to Go" - see attachments. These documents clearly demonstrate the need for high density, concentrated development activity forms that provide the critical mass for the provision of efficient/cost effective mass transport in the Toronto-centred region. The proposed P2G GGH amendment diminishes the push to higher densities within the region and overall, it is a regressive move.

Thank you for the opportunity to comment.