Having reviewed the Proposed…

Having reviewed the Proposed Amendment to the Growth Plan for the Greater Golden Horseshoe, 2017, I have a number of concerns, not only with the amendment, but with my own township's submission as a further amendment.

I do not believe it is wise to allow settlement area boundary changes, or other changes of land use, outside of a comprehensive municipal review. Allowing such ad hoc changes undermines the extensive planning efforts and public consultations that go into the production of local official plans and secondary plans. At the local level, the stability of those plans is important to residents and businesses alike in planning their futures, and opening up the process to allow growth, expansion or re-designation of lands outside of these detailed processes only yields a community's future to opportunism.

My own township, part of the greenbelt northeast of Toronto, has already submitted a request to amend the proposal to allow such changes in greenbelt communities, just as in other parts of the GGH. This is justified by suggesting other protections are in place that will limit growth, but this is clearly the "thin end of the wedge," and further exceptions can be expected to be presented and supported by developers and others looking to capitalize on inappropriate growth opportunities.

This raises a concern about the new phrase, "puts people first" being implemented as a policy statement for growth. Please recognize that this phrase is effectively meaningless: it can be interpreted by any interest group to suit their own desire. Such language must be avoided, and clarity restored to the growth plan.

My township has also lobbied for authority for lower-tier municipalities to make changes to their plans, just as upper- or single-tier municipalities may do (referring to the ad hoc changes I mentioned above, outside of comprehensive municipal reviews.) I again do not support this, as final planning authority rests with the upper-tier municipality. Having the lower-tier municipality propose changes outside of the regular process sends a confusing message with regard to authority over land use and the robustness of official plans, and this is not helpful in setting development targets. It too easily plays into the hands of special interests and opportunists who look for loopholes to exploit.

There are some overall points I want to emphasize:

- the greenbelt must be protected, and this does not permit of relaxation of standards and restrictions regarding growth planning within the greenbelt

- requests, lobbying or bargaining by townships, developers, landowners or any other group in favour of any amendment that reduces protection of greenbelt or other sensitive lands must be viewed as jeopardizing said lands, no matter the other controls that may, for now, remain in place

- a stable community with a comprehensive official growth and development plan will not benefit from short-term or ad hoc changes to that plan; instead, such action fosters opportunism, erodes the confidence of the residents, and complicates the recovery of a stable plan

- as we move towards intensification and development of greenfield lands within settlement boundaries, we risk the loss of important intra-urban green space, which reduces the quality of life in a community