I have several concerns on…

I have several concerns on the amendments to the Greater Golden Horseshoe (GGH) region’s growth plan (A Place To Grow) proposed by the Ministry of Municipal Affairs and Housing.

Proposed amendments include expanding the horizon for growth projections from 2041 to 2051 (which causes the projected population growth to increase from 13.5 million to 14.9 million), and allowing municipalities to "make available land for urban development to accommodate the needs of the growth forecast for a time horizon of up to 25 years" (currently, the time horizon is 20 years). Limits on development within certain areas within the GGH (such as Simcoe County) will be removed. In addition, a second ERO notice from the Ministry indicates that “assumptions [on population growth] that include density targets lower than those required in the Plan would require Minister’s approval.” The cumulative effect would be a required increase in urban development.

There are also changes to several definitions within the growth plan, including:

"Cultural Heritage" (removing the following: “Examples may include, but are not limited to, heritage conservation districts designated under the Ontario Heritage Act; villages, parks, gardens, battlefields, mainstreets and neighbourhoods, cemeteries, trailways, viewsheds, natural areas and industrial complexes of heritage significance; and areas recognized by federal or international designation authorities (e.g., a National Historic Site or District designation, or a UNESCO World Heritage Site).”)

"Ecological Function” (removing mentions of hydrologic and chemical functions)

"Habitat of Endangered Species and Threatened Species” (reducing the number of species to which the term may apply)

"Municipal Water and Wastewater Services” (adding that such services may be decentralized)

Furthermore, the proposal states the following:

"Mineral aggregate resources play an important role in the development of housing and municipal infrastructure. Ensuring adequate aggregate resources are available is critical to achieving the success of [A Place To Grow]. The proposed changes will make it easier to establish mineral aggregate operations closer to market and the product’s end users throughout the GGH.The proposed change to the Plan’s aggregates policies would be more permissive of new aggregate operations, wayside pits, and quarries within the Natural Heritage System for the Growth Plan.”

I have only highlighted amendments within the proposal; the full document is linked below.

Overall, it appears that the proposed amendments would skew the GGH’s growth plan to favour the interests of large land developers and mineral exploitation/aggregate operations. In the context of the definition changes listed above, I am very concerned as a resident of the GGH region that this new plan will endanger Ontario’s valuable agricultural lands, the landscapes and ecosystems that make up the Natural Heritage System, as well as sources of drinking water, by encouraging urban sprawl and deregulated aggregate extraction.

The Natural Heritage System is vital to the health of the province. It “includes natural features such as woodlands, wetlands, watercourses and valleylands that provide society with ecosystem services that are life sustaining or improve quality of life. These include a clean and reliable supply of groundwater and surface water; flood moderation; erosion control; moderation of air quality; pollination services; genetic resources for food, medicine, fibre or other products; and recreation opportunities.” (Quote from Credit Valley Conservation: https://cvc.ca/natural-heritage-system-strategy-frequently-asked-questi…) Furthermore, forests and wetlands are crucial for carbon sequestration, an essential piece of climate change mitigation.

The loss of agricultural land is already a serious threat in Ontario; the Ontario Farmland Trust estimates that 175 acres of farmland is lost each day, primarily to the twin threats of urban sprawl and aggregate mining. It is often claimed in the case of aggregates that post-operation rehabilitation can restore farmland to its original condition; however, this is untrue. The material that is mined for aggregates contributes to the drainage and mineral content of farmland soil. Once this material is removed, the same quality of soil can not be replicated; “…studies show that even if the land is rehabilitated back to what aggregate companies describe as an “agricultural condition”, it will never achieve the productivity it had before the extraction (Skelton Brumwell Associates Inc., 2009).” (Quote from the Ontario Farmland Trust: https://ontariofarmlandtrust.ca/impacts-aggregate-mining-farmland/)

Loss of agricultural lands to urban sprawl and/or pits and quarries would jeopardize Ontario’s food security, as the GGH contains a significant percentage of Ontario’s farmland. “Farmland makes up about half of the land area of the GGH and represents one of the most important economic sectors of the region, contributing $11 billion and 38,000 jobs to Ontario’s economy. This economic activity generates $1.7 billion in tax revenue for the three levels of government, about 38 per cent of all taxes received from agriculture in Ontario. Approximately one third of the province’s agri-food industry is based in the GGH and 42 per cent of Ontario’s best quality (Class 1) farmland is located in the region. A strong and stable agricultural industry is essential to Ontario’s long-term economic health.” (https://ofa.on.ca/resources/farmland-at-risk-report/) This is particularly relevant in light of the unreliability of global supply chains highlighted by the COVID-19 crisis.

With regard to urban sprawl, there are severe environmental implications of this type of growth. Sprawled development creates longer distances for commuting and accessing products and services, which encourages car use. As stated in a 2018 OECD report, this “translates into more vehicle kilometres travelled, higher air pollution and more greenhouse gas emissions.” The report also acknowledges that urban sprawl increases the risks of flooding and reduction in water quality. There is scientific agreement “that sprawling urban and suburban development patterns are creating negative impacts including habitat fragmentation, water and air pollution, increased infrastructure costs, inequality, and social homogeneity…negative impacts include, among others, air pollution resulting from automobile dependency, water pollution caused in part by increases in impervious surfaces, the loss or disruption of environmentally sensitive areas, such as critical natural habitats (e.g., wetlands, wildlife corridors), reductions in open space, increased flood risks, and overall reductions in quality of life.” (Quote from Nature: https://www.nature.com/scitable/knowledge/library/the-characteristics-c…)

Moreover, there are negative socioeconomic impacts of sprawling growth. According to the OECD report, “urban sprawl is long known to increase the per-user costs of providing public services of primary importance. Water supply, sanitation, electricity, public transport, waste management, policing and other services that are key for well-being are much more expensive to provide in fragmented areas of low-density. This entails that either the quality of these services will be low or that significant subsidies will be required to cover the costs of provision.” (Quote from the Organization for Economic Co-operation and Development: https://www.oecd.org/environment/tools-evaluation/Policy-Highlights-Ret…) Growth should instead be limited to intensification within fixed, permanent boundaries of urban areas, in order to avoid all of the issues mentioned above.

Finally, a personal note. I am a young resident of the GGH region who has lived in both rural and urban communities. Both types of communities have strengths, and I understand that each has different priorities and issues.

However, a loss of agricultural and natural lands to urban sprawl and aggregate extraction would have significant and negative impacts on quality of life for both. In these areas, water is purified, air pollution is filtered, and carbon is sequestered at minimal cost; food is produced, and recreation spaces are plenty. While rural communities exist within these areas and would evidently be directly impacted by their disturbance, residents of urban areas often seek out these areas — be it for hiking, camping, vacationing at a cottage, or simple day trips — for their enjoyment, and physical and mental well-being. This has become especially clear during the COVID-19 pandemic. Rural and urban residents alike treasure these lands. It is imperative that our government do so as well.