Hon. Steve Clark Minister of…

Hon. Steve Clark
Minister of Municipal Affairs and Housing
Ministry of Municipal Affairs and Housing
777 Bay St.
Toronto, ON
By email minister.mah@ontario.ca
Rescue Lake Simcoe Coalition
120 Primeau Dr.
Aurora ON
L4G 6Z4
rescuelakesimcoecoalition@gmail.com
August 18, 2022
Dear Minister Clark,
Do Not Approve York Region Official Plan
We are writing to you today to recommend you do not approve the York Region Official Plan,
submitted in early July 2022. Our reasons are explained below, but first we wanted to introduce
the two groups that penned this letter.
About Us - The Rescue Lake Simcoe Coalition (RLSC) was formed in 2003 to provide a citizens’
voice for Lake Simcoe and to get better policy protections for its water and natural heritage. As
a result of our efforts with Environmental Defence and Ontario Nature, and then MPP Garfield
Dunlop’s private members bill, we got the province to pass the Lake Simcoe Protection Act in
2008 to the enormous relief of citizens and cottagers who were watching the lake’s health
deteriorate in front of their eyes. It feels like we are back where we started now, with growth
plans that will result in doubling the watershed’s population by 2041. This growth will
undoubtedly harm the lake’s health and make it either impossible or astronomically expensive
to maintain the water quality for 12,000 cottagers and about 400,000 watershed residents
(virtually all in PC ridings by the way.)
In March of this year the RLSC branded an exercise and campaign we had been working on for
two years already – the Municipal Comprehensive Reviews in York, Simcoe and Durham – by
creating Stop Sprawl York Region. Since March, we have built up grassroots support for
responsible planning around the Stop Sprawl York Region brand from dozens of York Region
ratepayer groups etc. We are organizing with new and worried people because people are
increasingly concerned about their quality of life, the costs of sprawl development, legal
liability, protection of our source water, natural and cultural heritage, and damage to our
ecosystems and communities from the development that the provincial government has
directed to York Region. We are speaking to you about genuine community concerns. As
Minister, we hope you will address them.
2
Comments on York Region’s Draft Official Plan
York Region’s Official Plan (OP) was supported by only 2/3 of Council. Mayors who have always
voted FOR the Regional OP did not, for the first time, because there were so many problems
with the OP. Four of York Region’s nine mayors voted against the OP.
1 Are you really going to
approve an OP that will consume in the neighbourhood of 8000 acres of farmland that was not
unanimously supported by the Regional Council? Those who voted against the OP gave reasons
of housing affordability, climate impacts, downgrading of Greenbelt and Oak Ridges Moraine
protection, source water, environment, and general principles of good planning (complete
communities, car dependency, lack of adequate infrastructure planning and costs that will be
born by the Region and ultimately property taxpayers.) Those who supported the OP said
nothing to defend it other than the need to compromise and meet the provincial conformity
deadline.
The June 30th, 2022 Regional Council meeting itself was a gong show. It is unclear whether
Council even followed its own procedural and closed meeting bylaws. At one point a vote was
recast and the outcome changed after a closed meeting. RC Jackson (Vaughan) introduced
numerous amendments which had not gone through the normal staff review and lower tier
endorsement and / or had not been supported by staff. Mayor Quirk (Georgina) described the
meeting as “pulling apart cotton candy… I’ve never seen anything like this.” It took days for
anyone to understand what had happened. We called it an example of terrible governance that
should be used in a civics class.
Many watching the June 30th meeting did not believe that governance could get worse after
the October 2021 meeting on forecasted land needs. Numerous deputations and informed,
passionate, communications were submitted, pleading with Councillors to support responsible
land use planning, affordable housing and to act on Climate Change. Not only were these pleas
ignored, Council brought forward motions seeking more whitebelt land to be brought into the
urban boundary and to develop on the protected countryside of the ORM/GB in the absence of
staff support and any kind of financial analysis.
Are you rewarding this behaviour with an approval of the OP? We sincerely hope not.
Reasons that MMAH should not approve the York Region Official Plan:
1. Precedent-setting development on the protected Greenbelt (prime agriculture) and
Oak Ridges Moraine (protected country-side) . If you approve this OP you will be
flooded with requests to permit development on or to change the GB/ORM boundary.
When the province reviewed the legislation in 2016-17 there were at least 600 requests
for boundary changes.2 Just don’t do it. We fear there won’t be much left to protect on
1 June 30 minutes of York Region Council at which the ROP was endorsed by Council.
https://yorkpublishing.escribemeetings.com/Meeting.aspx?Id=0f70fdc2-b4d…-
5616080f3837&Agenda=PostMinutes&lang=English
2 Ballingall, Alex. Sept 16, 2016. Province considering 600 requests to remove Greenbelt land. Toronto
Star.
3
Greenbelt/ORM at a time when global circumstances and climate change make the
importance of food security and source water protection more important than ever
before. We also fear for protection of our source and stormwater, not only for York
Region, but also for all those who live downstream.
2. It’s illegal. We are shocked that the majority of Council went against professional
planners and senior staff advice, and approved an OP that is not in provincial
conformity because it asserts that development will occur in at least four places that are
currently protected by the GB or ORM legislation.3 This move also ignores the
professional standards of the professionals who are paid by the taxpayer to uphold good
planning principles and the law. 4
3. The OP does not address the biggest crisis in Ontario at the moment: affordable
housing. We already know that York Region’s ability to reach its past, less ambitious
population target is hampered by its lack of rental and affordable housing. If you are
serious about sustainable local business development and “complete communities” this
is simply not a plan that will serve those ends. This is because there is too much
expensive sprawl at a 50% intensification rate, climbing to just 55% after 2031. York
Region was achieving a 54% intensification rate from 2016 to 20195. Please see the table
on pg. 7 that shows the intensification rates proposed.6
4. In new communities, York Region has set an abysmally low designated greenfield target
(DGA) of 50 residents and jobs per hectare (RJ/H). The Region plans to achieve 52 RJ/H
https://www.thestar.com/news/gta/2016/09/26/province-considering-600-re…land.html
3 As confirmed by York Region’s Chief Planner Paul Bottomley by email to letter co-writer Irene Zeppieri
and is to be submitted accompanying York Region’s endorsed 2051 ROP, the following are considered to
not be in provincial conformity:
“Consistent with advice provided to York Region Council throughout the MCR
process, my statement as submitted to the Province indicates the adopted 2022
York Region Official Plan conforms to and does not conflict with the applicable
Provincial Plans, save and except for the following:

● City of Vaughan Rizmi Holdings Limited Urban Expansion
● Town of Whitchurch-Stouffville Urban Expansion (Bethesda
Community Area Lands, South Gormley Employment Lands)
● Town of Whitchurch-Stouffville Future Strategic Employment Lands
Overlay
● City of Richmond Hill Gormley GO MTSA
● Regional Official Plan Amendment 7”
4 Attachment 7: Proposed Regional Official Plan Conformity With Provincial Plans (Note Several Motions
were passed at the June 30 Meeting that may not be included or referenced):
https://yorkpublishing.escribemeetings.com/filestream.ashx?DocumentId=3… 5 Watson and Associates. March 2021.Foundational Housing Analysis: York Region, Final Report. pg ix.
6 Intensification Rates: Table 6, from June 30, 2022 COW meeting agenda: (Table appears on final page
of this letter) https://yorkpublishing.escribemeetings.com/filestream.ashx?DocumentId=3…
4
which is lower than its 2010 Official Plan’s DGA of 70 RJ/H. This rate is calculated
differently in the current Growth Plan than it was in the last iteration; taking that into
account, the current target is lower than what has been achieved in recent years.7
5. Employment Land / Provincially Significant Employment Zones. In October 2020
Council reviewed numerous employment conversion requests. In Vaughan and
Richmond Hill several requests were supported that are near PSEZ. These were against
the recommendations of staff because they have the potential to undermine the
viability of employment areas and create sensitive receptors and land use conflicts8.
6. The impact to Lake Simcoe of all the growth-related sewage and stormwater has not
been publicly evaluated. This concerns us greatly and must be addressed. It is not
enough to create the problem and say you will fix it. For context, 31% of the phosphorus
loads to Lake Simcoe come from stormwater runoff. Ontario is trying to cut phosphorus
loads in half at least by 2041 according to the Lake Simcoe Protection Plan. The
province’s promised $26 million contribution to a phosphorus reclamation facility on the
Holland River is likely to remove 2.5 tonnes of phosphorus per year of the 50 tonnes per
year in excess of the provincial phosphorus target. We are well beyond sustainable
phosphorus loads already. To be consistent with the LSPP’s precautionary principle you
must not approve the Upper York Sewage System which will add phosphorus to Lake
Simcoe and is proposed to be offset by unproven remediation activities.
7. This OP is far too heavy on infrastructure costs. This presents significant financial risks
to York Region if investment in infrastructure is made and projected growth is not
realized, forcing York Region to carry a higher debt burden than planned. In addition,
due to the reactive manner that resulted in significant urban boundary expansions that
differ from staff recommendations, it is quite plausible that infrastructure costs will be
higher than anticipated. This has the potential to jeopardize York Region’s AAA Credit
Rating as happened in the past. Planned infrastructure services/upgrades for existing
communities could experience funding shortfalls and impede York Region’s ability to
service existing communities and services. In order to fund the capital, operating and
asset management with the projected level of growth-related infrastructure York Region
residents can expect a 0.6% annual tax increase.9 In addition, York Region is heavily
7 Designated Greenfield Area: Staff Report entitled: Planning for Density in New Communities
https://yorkpublishing.escribemeetings.com/Meeting.aspx?Id=c9ca8d5d-2c6…0b937477e050&Agenda=Merged&lang=English&Item=47&Tab=attachments
And Table 9B: https://yorkpublishing.escribemeetings.com/filestream.ashx?DocumentId=3… 8 All endorsed employment conversions in Recommendation 2 were supported against Staff
recommendations. https://yorkpublishing.escribemeetings.com/Meeting.aspx?Id=a73f3102-3d5…-
8d9a-ed1b20fdf955&Agenda=PostMinutes&lang=English&Item=17&Tab=attachments 9 Regional Official Plan Fiscal Impact Analysis, June, 2022. See:
https://yorkpublishing.escribemeetings.com/filestream.ashx?DocumentId=3…
Key Points:
-$20B of growth related infrastructure over the next 30 years, 63% will come from development
fees, 12% by tax levy and 25% from other levels of government.
-40% of expenditures will have to occur in the first 10 years (by early 2030s), yet less than 30% of
the growth is projected to happen during this time period
5
dependent on Great Lakes Servicing provided by the Regions of Peel and Durham. There
is uncertainty if the combined development proposed for all Regions combined can be
adequately serviced and there appears to have been little to no discussion on servicing
limitations. The lack of servicing is forcing atypical servicing solutions in York Region for
already approved growth. Getting approval seems based on the landowner’s ability to
finance and pay for development rather than criteria that demonstrate why the
infrastructure should be advanced and prioritized above all other development
applications10.
8. Particularly risky and premature is the growth and urban boundary expansions endorsed
in East Gwillimbury which require approval of the existing Environmental Assessment
for the UYSS currently on hold and submitted to the province 7 years ago. At a cost of
$1 billion in new sewage infrastructure in East Gwillimbury for the Upper York Sewage
Solution, it is worth your while to seriously consider the downsides of this plan
environmentally and financially.
9. East Gwillimbury has publicly consulted and endorsed their OP 11 and WhitchuchStouffville12 has released the first version of their OP for consultation ahead of the
Region, calling into question ‘who is wagging the dog’? How can the lower tier publicly
consult on land use decisions that are still subject to approval by the Minister of
MMAH for York Region? This backwards process creates red tape and confusion in the
public. In both cases, developer-led planning won the day, ultimately persuading the
majority of Regional Council to support plans hatched with no regard for the region or
sustainability. East Gwillimbury is planning for a 2% intensification rate. This process is
completely inappropriate for 2022, and certainly undermines the provincial process of
Official Plan conformity since they created their OPs before the Region did.
10. There are many complicating factors that are not well planned at all, like the Transit
Oriented Communities (TOCs) at Yonge / 407. Local residents are concerned about the
lack of coordination and provincial disinterest in resolving the traffic and congestion
problems created by MZOs and EMZOs. Note that the Region is planning for these but
10 Prepaid Development Charge Credit Agreement with the Block 27 Developer Group in the City of
Vaughan https://yorkpublishing.escribemeetings.com/Meeting.aspx?Id=c9ca8d5d-2c6…0b937477e050&Agenda=PostMinutes&lang=English&Item=65&Tab=attachments
The Mount Forest Upgrades was not approved through the Development Charges By-Law or under the
Planning Act, it is a funding agreement that York Region entered directly with the Mount Forest Albert
Group Landowners to pay to upgrade the plant. There was no procurement and staff indicated it is
permitted as per broad powers contained in the Municipal Act. See Staff Report entitled: Mount Albert
Water and Waster Water Systems Upgrade and Development Agreement
https://yorkpublishing.escribemeetings.com/Meeting.aspx?Id=efcfe61b-620…-
3b3b02489b4a&Agenda=PostMinutes&lang=English&Item=36&Tab=attachments 11 Town of East Gwillimbury Official Plan, June, 2022 Endorsed and submitted for approval to York
Region June 21, 2022 https://eastgwillimbury.civicweb.net/document/162577/Appendix%201%20-
%20Updated%20Official%20Plan%20and%20Schedules.pdf?handle=1894E5B95D4348BFA15BEB1E25
409593 and https://eastgwillimbury.civicweb.net/Portal/MeetingInformation.aspx?Org… 12 Town of Whitchurch-Stouffville released the first version of it’s Official Plan for Public Consultation at
the end of June prior to York Region Council endorsing the upper-tier Official Plan see:
https://www.cometogetherws.ca/opr
6
did not include the total anticipated population in the planning period because it
doesn’t expect the TOCs to be achieved during the planning period to 2051, despite
provincial statements to the contrary13.
We recognize the significant challenges the province faces, that 1.5M households must be built
during the planning period and that there is a housing crisis. However, we contend that the
Official Plan fails to address this in any meaningful way for the reasons stated above and York
Region will continue to fall short of meeting housing goals and will fail to provide enough
housing, let alone affordable housing and the “missing middle”, where it is most needed in our
existing urbanized areas.
In conclusion, the submitted OP has significant financial, legal, planning and environmental risks
that were well articulated by staff and ignored by politicians. This approach does not put people
first; it’s up to you to uphold good planning and financial management principles for the people
of York Region and Ontario and not approve the submitted OP14.
Please contact us with any questions or comments you have.
Sincerely,
Claire Malcolmson
Executive Director
rescuelakesimcoecoalition@gmail.com
647-267-7572
And Irene Zeppieri
Vaughan Resident and Stop Sprawl York Region member
Supported by:
Peter Miasek, Transport Action Ontario
Graham Churchill, Director, Federation of Urban Neighbourhoods