Comments on EBR 019-6177…

Comments on EBR 019-6177
Review of A Place to Grow and Provincial Policy Statement

General Comment

The proposal seeks to integrate A Place to Grow and the Provincial Policy Statement by:
• Prioritizing A Place to Grow over the Provincial Policy Statement
• Removing policies that result in
o duplication
o delays or
o burden in the development of housing
Elimination of duplication is good. However, the timeline and thoroughness of studies, assessments, reviews and approvals of development plans should not be sacrificed in the name of expediency. A bad plan or decision that is rushed to construction is very difficult and expensive to correct. In other words, proceed with caution and seek expert advice on what policies can be simplified or eliminated without significant consequences to the resiliency of housing and infrastructure in the face of climate and other global changes.

As will be show below, there are not enough details to render a comprehensive review of this proposal. It is therefore recommended that the Province proceed with caution and not make any decisions until further details of the new policy direction is available for additional comment and constructive input.

Specific Comments on Core Elements

Residential Land Supply
• Settlement area boundary expansion should be resisted until all other options to develop additional housing within current boundaries are exhausted. Doing so would encourage urban sprawl and require costly new highways, urban infrastructure, etc. Funding that would go into these items should be diverted to expand and electrify the commuter rail system and to develop the infrastructure needed to transition from the individually-owned personal internal combustion vehicle to a mix of rental and individually-owned electric vehicles.
• Provision of more rural housing should not be done at the expense of valuable natural ecosystems or prime agricultural land. Likewise, building new housing in naturally hazardous areas should be avoided. Farming and agribusiness are major component of the Ontario economy and should be protected at all costs. Natural hazards are only increasing under global warming and mitigation should be a major priority.
• Conversion of employment lands to new residential and mixed-use development must ensure that new residences (sensitive receptors) and the employment activities are compatible and don’t lead to ongoing disharmony between residents and businesses.

Attainable Housing Supply and Mix
• No comments.

Growth Management
• No comments related to Large and Fast-growing Municipalities beyond those provided above under Residential Land Supply.

Environmental and Natural Resources
• The dual objectives under Agriculture: protecting prime agricultural land and increasing residential development in rural areas seem contradictory; how will this be achieved?
• Under Natural Heritage, the plans to empower local decision makers and providing more options to reduce development impacts are problematic. Aren’t planning decisions already done by municipal decision makers, within the constraints of the Planning Act? The one example provided of offsetting/compensation for development impacts is poor alternative to preserving the natural heritage our well-being depends on – wetlands, pollinator and sensitive species habitats, groundwater recharge areas, etc.
• Under Natural and Human-made Hazards why is the Province considering allowing residential development in areas prone to natural hazards? This doesn’t seem to be in anyone’s interest and is a recipe for costly remedial measures, litigation, ruined dreams of owning a home, etc. The term “streamlining policy … direction” seems to be hinting at weakening current safety/precautionary requirements, a direction that I oppose, just as I oppose the weakening of the mandate of local Conservation Authorities.
• Under Aggregates, there is enough land licensed to produce aggregates in Ontario to meet Ontario’s requirements for many decades. The Province has already streamlined and simplified policy in this area. What is required is some additional planning at the Municipal and possibly Provincial levels to ensure that settlement areas and aggregate operations can coexist in harmony. New policy could be developed to deal with where aggregate extraction is allowed and not allowed, so that there is a suitable buffer zone between the two land uses. The current practice of giving aggregate companies access to lands as close as 30 m to a settlement area and the proposed plan to eliminate the right of third parties to object to such developments are unfair and bad planning. This needs to be changed, not made even worse through the changes planned under the scope of EBR 019-6177.
• Under Cultural Heritage, the Province needs to protect the historical centres of its Municipalities so that they continue to be social activity centres, tourist areas, etc., not weaken them as is hinted at through the use of terms like “creating flexibility to increase housing.” Preservation of natural heritage and increased housing can coexist but only If done properly

Community Infrastructure
• Under Infrastructure Supply and Capacity, the Province wishes to increase flexibility for servicing new development. This should not be by saddling current residents with costs of new infrastructure as has been hinted at by downloading such costs from developers to municipal taxpayers.

Streamlined Planning Framework
• This entire section talks about being less prescriptive, streamlining requirements, requiring fewer studies, etc. Good planning requires a combination of competent planners, with adequate site-specific information, guardrails to protect other parties possibly impacted by new development, and a system of checks and balances. These all need to be in place for good planning and none should be sacrificed.