I am voicing my objection to…

I am voicing my objection to some of the significant changes outlined in the Proposed Amendment 1 to the Growth Plan for the Greater Golden Horseshoe, 2017.

Overall, the Amendment seeks to undo much of the work that the Growth Plan required cities to do to address issues that are critical to Ontario’s citizens: urban sprawl, traffic congestion, food security, air pollution, carbon emissions, loss of biodiversity, and health. Many cities have made urban renewal a priority and have spent years developing plans to intensify, improve public transit, add opportunities for active transit, diversity housing options, and promote green space and food production. Brampton’s 2040 Vision seeks to transform the City of Brampton and reduce car dependency by achieving enough density to sustain efficient local and regional transit. Municipalities need provincial leadership that moves policies into the future instead of revisiting a flawed past.

My initial concerns are related to the reduced density targets for greenfield development. It is critical to be as efficient as possible with development to minimize further disturbance to natural and agricultural areas. The FAO has just released a report detailing the threats to our food supply due to loss of biodiversity, which is directly connected to loss of habitat as well as pollution. This Amendment would seek to more quickly contribute to greater biodiversity loss through both these avenues as urban sprawl occurs.

After thoroughly reading the Amendment, I am highly disturbed by the nature of wording changes that might seem subtle or unimportant to some people, but deliberately reduce clarity and impede movement toward innovative, efficient design and technology.

I have specifically annotated my concerns with the following sections by writing comments after each excerpt:

1.1 is amended by deleting “low-density urban sprawl” and replacing it with “unmanaged growth”.

Managed growth at too-low densities is identical to low-density urban sprawl. Changing the words does not change the result.

1.2 is further amended by deleting “, a clean and healthy environment” and “social equity” and replacing it with “an approach that puts people first”.

A clean and healthy environment is essential now and for future generations; how many more scientific reports will government ignore? Some of the largest conflicts in the world are provoked by social inequity. Which people do you want to put first?

It is further amended by deleting “offer a wide variety of choices for living” and replacing it with “have sufficient housing supply that reflects market demand and what is needed in local communities”.

Only people with money drive the market for real estate. A government should consider ways to promote more environmentally-friendly demand and ensure there is social equity by mandating a variety of housing options that do not require vehicle ownership.

It is further amended by deleting “long-term” and deleting “net-zero” and replacing it with “environmentally sustainable”.

Net-zero is one of the most common sense, achievable requirements for all new buildings and should be legislated into building codes.

It is further amended by deleting “low-carbon” and replacing it with “environmentally sustainable” and deleting “, with the long-term goal of net-zero communities,”.

The future must be low-carbon. Net-zero communities are one way to work toward that future. The longer governments stall, the bleaker that future will be. Low-carbon economies can transform our society through innovation, improved health, and a safer environment.

2.1
It is amended by deleting “Ontario’s Climate Change Strategy, 2015 reaffirms the government’s commitment to meet its long-term targets to reduce greenhouse gas emissions below 1990 levels by 37 per cent by 2030 and by 80 per cent by 2050. Ontario’s Climate Change Action Plan 2016, outlines a range of actions related to fighting climate change that can assist with achieving the goals and objectives of this Plan. This Plan contributes towards the Climate Change Action Plan’s goal of moving towards low-carbon communities, with the long-term goal of net-zero (communities”.
It is replaced with “Ontario has recently affirmed its commitment to reduce greenhouse gas emissions by 30 per cent below 2005 levels by 2030 in the proposed. Preserving and Protecting our Environment for Future Generations: A Made-in-Ontario Environment Plan. This target aligns Ontario with Canada’s 2030 target under the Paris Agreement.”
The targets are wholly insufficient. Too little is being done too slowly.
2.2.1.4 f) is amended … by deleting “towards the achievement of low-carbon communities” and replacing it with “to environmental sustainability”.

2.2.7 Designated Greenfield Areas
2.2.7.2 is deleted.
It is replaced with "The minimum density target applicable to the designated greenfield area of each upper- and single-tier municipality is as follows:
a. The City of Hamilton and the Regions of Peel, Waterloo and York will plan to achieve within the horizon of this Plan a minimum density target that is not less than 60 residents and jobs combined per hectare;
b. The Cities of Barrie, Brantford, Guelph, Orillia and Peterborough and the Regions of Durham, Halton and Niagara will plan to achieve within the horizon of this Plan a minimum density target that is not less than 50 residents and jobs combined per hectare; and
c. The City of Kawartha Lakes and the Counties of Brant, Dufferin, Haldimand, Northumberland, Peterborough, Simcoe and Wellington will plan to achieve within the horizon of this Plan a minimum density target that is not less than 40 residents and jobs combined per hectare."
Decades of experience and research around the world has proven that low-density sprawl leads to automobile dependence, obesity, shorter life spans, poorer mental health, and lost productivity. Even without considering loss of agricultural land, habitat, and biodiversity, moving back toward a low-density, sprawl model is in no way “an approach that puts people first”.

2.2.8.3 a) is amended by … deleting “to support the achievement of complete communities”.

Why is this government unwilling to support complete communities?

2.2.8.3 e) (of 2017 document - below) will be changed from
watershed planning or equivalent has demonstrated that the proposed expansion, including the associated servicing, would not negatively impact the water resource system, including the quality and quantity of water;
to:
The sub-policy would read “the proposed expansion, including the associated water, wastewater and stormwater servicing, would be planned and demonstrated to avoid, or if avoidance is not possible, minimize and mitigate any potential negative impacts on watershed conditions and the water resource system, including the quality and quantity of water;”

Water is not negotiable. “No negative impact” is a clear, defined, measurable boundary. Who will determine which developments are worth potential negative impacts on watershed conditions? How large will the potential negative impacts be allowed to be? Will communities or individuals lower on the “social equity” scale be the people who suffer most from impacted quality and quantity of water?

2.2.8.3 g) (of 2017 document) IS DELETED. It says:
for settlement areas that receive their water from or discharge their sewage to inland lakes, rivers, or groundwater, a completed environmental assessment for new or expanded services has identified how expanded water and wastewater treatment capacity would be addressed in a manner that is fiscally and environmentally sustainable;

Does this mean environmental assessments would actually no longer be necessary? This is completely unacceptable.

2.2.8.5 is a new policy added to the Plan
a settlement area boundary expansion may occur in advance of a municipal comprehensive review, provided:…
“For a settlement area boundary expansion undertaken in accordance with policy 2.2.8.5, the amount of land to be added to the settlement area will be no larger than 40 hectares.”

This is much in the spirit of the now-withdrawn Section 10 of Bill 66 that will allow a piecemeal, one-farm-at-a-time, expansion of urban sprawl.

3.1 is amended by deleting “lower density development” and replacing it with “unmanaged growth”.

3.2.1.2 is amended by adding ",environmental planning”, by deleting “infrastructure master plans, asset management plans, community energy plans, watershed planning, environmental assessments, and other” …
Environmental planning is far too vague a term to have any legal meaning. The terms that are being deleted are important, meaningful, clearly defined, and have been created by staff, consultants, and experts based on science and research. These plans must be respected and incorporated into future development.

4.1 is further amended by deleting “the long-term goal of net-zero” and replacing it with “environmentally sustainable”.

Again, the wording change reduces clarity.

In conclusion, this Amendment is not something that average Ontarians asked for. The public outcry to Section 10 of Bill 66 should have made it abundantly clear that the public is no longer blindly allowing nature to be paved over, for the benefit of developers and land speculators. Just because land is not protected by the Greenbelt does not mean it is not valuable in its own right. Endless fields of too-large houses filled with too many consumer goods surrounded by too many roads with too many cars is not the Southern Ontario that I voted for.