Proposed Change: 1.2 is…

Proposed Change:
1.2 is amended by adding “, work and play”. It is further amended by deleting “, a clean and healthy environment” and “social equity” and replacing it with “an approach that puts people first”. It is further amended by deleting “long-term” and deleting “net-zero” and replacing it with “environmentally sustainable”.

Comment:
An “approach that puts the people first” should recognize that people need, in addition to strong economy, a “clean and healthy environment and social equity” – the exact language that is proposed to be removed. A “clean and healthy environment” does not happen without intention and should not be taken for granted. These components should not be deleted. Further, changing the reference from “net zero” to “environmentally sustainable” takes something that is tangible and makes it nebulous. To enable both the incremental and transformational change that is needed to improve communities and the quality of life of those within them, measureable aspirations are needed.

Proposed Change:
1.2.1 is amended by deleting “low-carbon” and replacing it with “environmentally sustainable” and deleting “, with the long-term goal of net-zero communities,”. The bulleted point would read “Integrate climate change considerations into planning and managing growth such as planning for more resilient communities and infrastructure – that are adaptive to the impacts of a changing climate – and moving towards environmentally sustainable communities by incorporating approaches to reduce greenhouse gas emissions.”

Comment:
Changing the reference from “low carbon” to “environmentally sustainable” and deleting the reference to the “long-term goal of net-zero communities” takes tangible concepts and replaces them with unmeasurable ones.

Proposed Change:
2.2.7.3 a) is amended by italicizing “natural heritage systems”. The sub-policy would read “natural heritage features and areas, natural heritage systems and floodplains, provided development is prohibited in these areas;”

Comment:
The Province should confirm that the buffers identified to protect natural heritage features would be captured under the definition of “natural heritage systems” and could therefore be excluded from the area subject to density calculations.

Proposed Change:
2.2.8.3 e) is now 2.2.8.3 d). It is amended by deleting “watershed planning or equivalent has demonstrated that”, adding “water, wastewater and stormwater” and deleting “not negatively impact” and replacing it with “be planned and demonstrated to avoid, or if avoidance is not possible, minimize and mitigate any potential negative impacts on watershed conditions and”. The sub-policy would read “the proposed expansion, including the associated water, wastewater and stormwater servicing, would be planned and demonstrated to avoid, or if avoidance is not possible, minimize and mitigate any potential negative impacts on watershed conditions and the water resource system, including the quality and quantity of water;”

Comment:
Based on proposed policy 4.2.1.3d), watershed planning would still be required to inform planning for water, wastewater, and stormwater infrastructure. However, the test that is established through the new 2.2.8.3d) is weakened, creating conditions that could be detrimental to the integrity of a watershed through cumulative impacts.

Proposed Change:
3.2.1.2 is amended by adding ",environmental planning”, by deleting “infrastructure master plans, asset management plans, community energy plans, watershed planning, environmental assessments, and other” and by deleting “where appropriate."
The lead-in for the policy would read “Planning for new or expanded infrastructure will occur in an integrated manner, including evaluations of long-range scenario-based land use planning, environmental planning and financial planning, and will be supported by relevant studies and should involve:”

Comment:
Given that the intent of the policy is to ensure planning for new or expanded infrastructure occurs in an integrated manner, the list of supporting plans and studies should remain, as it is an indication of what is needed to do things in an integrated manner.

Proposed Change:
4.1 is further amended by deleting “the long-term goal of net-zero” and replacing it with “environmentally sustainable”. The paragraph would read “The water resource systems, Natural Heritage System for the Growth Plan, and Agricultural System for the GGH also play an important role in addressing climate change and building resilience. Greenhouse gas emissions can be offset by natural areas that act as carbon sinks. Municipalities play a crucial role in managing and reducing Ontario’s greenhouse gas emissions and supporting adaptation to the changing climate. The Province will work with municipalities to develop approaches to inventory, reduce, and offset greenhouse gas emissions in support of provincial targets as we move towards environmentally sustainable communities.”

Comment:
Deleting the reference to “the long-term goal of net-zero” and replacing it with “environmentally sustainable” takes something that is tangible and makes it nebulous. To enable both the incremental and transformational change that is needed to improve communities and the quality of life of those within them, measureable aspirations are needed.

Proposed Change:
4.2.2.5 is deleted. It is replaced with a new policy that is added to the Plan: “Upper- and single-tier municipalities may refine provincial mapping of the Natural Heritage System for the Growth Plan at the time of initial implementation in their official plans. For upper-tier municipalities, the initial implementation of provincial mapping may be done separately for each lower-tier municipality. After the Natural Heritage System for the Growth Plan has been implemented in official plans, further refinements may only occur through a municipal comprehensive review.”

Comment:
The document entitled “Regional Natural Heritage System for the Growth Plan for the Greater Golden Horseshoe – Summary of Criteria and Methods” was released by the Province in February 2018. It describes the types of refinements that can be made to the Natural Heritage System mapping. The Province should confirm if this document still applies or if it will be revised.

Proposed Change:
A number of policies are proposed to be amended by adding “or equivalent” when watershed planning is referenced.

Comment:
The Draft Watershed Planning Guidance document released by the Province in early 2018 provided direction on what would be considered an equivalent study. Is the Province intending on finalizing this document?