May 10, 2024 The Honourable…

May 10, 2024

The Honourable Premier Doug Ford and Minister Paul Calandra.
Queen’s Park
Legislative Building
Toronto, Ontario
M7Z 1A1

Premier Doug Ford, Minister Paul Calandra, and Members of the Legislative Assembly of Ontario,

We urge you not to enact Bill 185 and the proposed changes to the Provincial Planning Statement (PPS) without modifications to address our unique context in Waterloo Region for land use planning and environmental protection. As they currently stand, the changes your government proposes could cause irreparable harm to our communities and will hinder, not facilitate, the construction of new housing to address the housing crisis.

Unlike most other Ontario cities and communities, we have no Greenbelt protections and no freshwater pipelines to the Great Lakes. We are totally dependent on living within the carrying capacity of our watersheds and in response to this reality, Waterloo Region has developed robust planning processes, tools and environmental protections that safely balance smart growth, preserving farmland, and protecting essential groundwater recharge areas. Regional planning has been central to achieving the needed balance.

1. The Region of Waterloo is a facilitator – not an inhibitor － for urban development.

For over five decades, the Region has fostered collaboration and cooperation between all of our lower-tier municipalities to achieve coordinated urban development. This is fundamental for the efficient use of scarce resources such as available water and sewage capacity, transportation infrastructure, services, engineering, hydrology, and planning, to achieve visionary growth management. As such, the removal of Planning Authority from the Region of Waterloo, as cited in Schedule 12 of Bill 185, would have far-reaching negative consequences.

2. Need to Adequately Protect Groundwater Recharge Areas.

One of the most fundamental characteristics that sets us apart from other regional urban municipalities in the province is that, despite numerous requests and appeals, the Region of Waterloo was left out of the provincial Greenbelt. Without Greenbelt protections, we were nevertheless assigned the same significant growth targets as most GTA municipalities. In order to balance this significant development with the protection of valuable farmland and ecosystem services, the Region of Waterloo and member municipalities developed a series of protective measures. These include our visionary Countryside Line policy, our Protected Countryside designation on the essential Waterloo Moraine, our Environmentally Sensitive Landscapes (ESLs) protecting watershed ecosystems, and wellhead Source Water Protection areas.

What will the removal of regional planning authority mean for the rational coordination of urban development and for these vital environmental and water protection measures? There is no clear answer to this question, but we can only predict that the fragmentation of planning authority will put everything we have achieved in jeopardy. We foresee inconsistencies, erosion of environmental and farmland protections, and a lack of coordination to ensure availability of water, sewage, roads, and other infrastructure.

Eliminating regional coordinating authority to put all planning in the hands of seven very different lower-tier municipalities, with little incentive for cooperation and the potential for increasing competition over scarce resources, is a recipe for disaster. Removing regional authority won’t speed up the construction of more housing. Instead, it will significantly inhibit development, both by raising infrastructure costs as efficiencies are lost, and by endangering the water resources that could become an absolute limiting factor for our urban growth.

3. Potential Solutions

1) Retain Planning Authority. Ideally, Planning Authority would be retained by the Region of Waterloo, since our current systems are efficient and working well with plans to deliver far more housing by 2031 than provincial housing targets require.
2) Greenbelt Expansion. If we do lose regional environmental protections, we submit that the provincial Greenbelt must be extended to protect the Waterloo Moraine and our essential groundwater recharge areas.
3) Creative Delegated Planning. Alternatively, the Region of Waterloo could retain overall Planning Coordination and a Regional Official Plan, while Planning Approval Authority could be delegated to lower-tier municipalities to be more independent, provided approvals are in conformity to the overarching Regional Plan.

In Conclusion

Environmental protections are not just “red tape”. We depend on our farmland, our fresh water, and on the other ecological services provided by our unbuilt landscapes. Furthermore, the regional planning processes that have been carefully designed over decades should not be seen as barriers to building much needed homes. Instead, our regional government plays a vital role facilitating development and new housing, while balancing the protection of our critical water supply. We look forward to continuing to work collaboratively to identify opportunities beyond the hundreds of thousands of units already planned in our Regional Official Plan.

Thank you!

cc.

Mike Harris Jr, MPP Kitchener-Conestoga
Jess Dixon, MPP Kitchener-South Hespeler
Brian Riddell, MPP Cambridge
Catherine Fife, MPP Waterloo
Aislinn Clancy – MPP Kitchener-Centre
Marit Stiles, Leader of the Official Opposition of Ontario
Bonnie Crombie, Leader of the Ontario Liberal Party
Mike Schreiner, Leader of the Green Party of Ontario