I am a retired municipal…

I am a retired municipal planner having had worked in various municipalities of the Toronto-centred region for over 35 years. I am familiar with planning in the Greater Golden Horseshoe (GGH) and the mechanics of the Places to Grow Plan being implemented starting in 2006.

The following 3 points are made for your consideration respecting the proposed amendment number 1 to the 2019 version of the Places to Grow Plan (ERO 019-1680).

1) General comment - The ‘build bigger for progress’ mantra is a dated notion and illustrates a poor understanding by the current government of what is required to build healthy, resilient and sustainable communities. If the largest communities would be considered the ‘best places in the world’ to live then the largest cities in the planet would be considered the best due to their shear size, e.g., Tokyo, Delhi, Shanghai, San Paoli, Mexico City. From available global rating services, these cities rarely rank as the ‘best’ places to live. Simple phrases such as ‘build more to create jobs’ doesn’t cut it as there is ample evidence of significant infrastructure costs and deficits associated with both hard and soft service provision in GTA municipalities.

2) Policy 4.2.8 policy change - It is unclear what is the basis for relaxing rules respecting the protection of endangered species habitat to allow additional aggregate extraction. A simple explanation that ‘additional supply opportunities near to market’ doesn’t cut it. This is a dangerous precedent. Where will this all end? Will the government also consider removing groundwater protection areas and other natural heritage features (e.g., provincially significant wetlands) in the next amendment to the Plan? Instead of working to enhance the existing ‘poor’ natural heritage system of the GGH, the current government is looking to make it worse.

As outlined in the attachments, the proposal directly contradicts the need identified to protect and enhance the existing natural heritage system in the GGH. Several documents provided by Ontario Nature and the Suzuki Foundation identify the importance and value of a GGH Greenway network (2006 Ontario Nature Greenway Vision; 2014 Ontario Nature NHS Planning; 2013 Suzuki Nature Edge). The proposal to permit the loss of endangered species habitat also is contrary to existing government direction as noted in existing Ontario planning documents (2005 Ontario MNR Natural Heritage System Reference Manual; 2018 Ontario Natural Heritage Systems guideline for the GGH).

3) Policy 5.2.4 policy change – The proposed policy change would permit municipalities to adopt higher forecasts than the ones outlined by the Province. How does this make sense? What about lower forecasts? What is the rationale for pushing development that has significant costs associated with it? In effect, the proposed amendment is incorporating a ‘notwithstanding clause’ statement that states that population/employment targets outlined from the Places to Grow document 'may' be implemented in local municipal planning efforts where appropriate. This proposed change undermines a regional co-ordinated planning effort for the GGH, and invariably will cause needless potential confusion and debate (thereby slowly down so-called ‘progress in a bigger is better’ planning effort).

Thanks for reading and considering my comments.