Thank you for the…

Thank you for the opportunity to comment on the proposed Amendment to the Growth Plan. I am a resident of Toronto and a Registered Professional Planner. I am writing on my own behalf as a concerned citizen of Ontario.

While I understand that the intent of the amendment, to some degree, is to simplify the policy framework and provide some flexibility in the Plan's implementation. I am concerned that the proposed changes have gone too far, to the point that it has almost rendered the Plan redundant. Despite the detailed policy direction provided, when it comes to implementation, the outcomes are likely to be no different than what would otherwise result if only applying the policies of the Provincial Policy Statement.

One of the most significant impacts of the award winning Growth Plan, 2006 was that it established a level playing field for development in the Golden Horseshoe, all municipalities were held to the same targets, which meant that a developer looking for "something different" while still capitalizing on the benefits of being located in or near the GTHA, was not going to be able to do so. With the proposed changes, however, that level playing field is removed and that is a significant step back for growth management in the GGH.

Below are some more specific comments:

Section 2.1 Context

The proposed modifications in this section include statements such as “there is a lack of housing supply and a record low vacancy rate.” These statements are misleading. The low vacancy rates apply to rental housing, not all housing forms/tenures. Also, there is no evidence of a lack of housing supply overall. What is lacking in the housing supply is housing that is appropriately priced in relation to income. Over the last two decades we have seen a much higher rise in house prices than that of household income. As such, the language in the Plan should be clarified. Furthermore the Provincial response should be to lower housing costs or find a means to increase income or undertake a combination thereof, simply increasing housing supply through greenfield development will not result in more affordable housing.

Major Transit Station Areas (MTSA)

The proposed amendment indicates that the purpose of proposed policy changes related to MTSAs are to provide: “A streamlined approach that enables the determination of major transit station areas to happen faster so that zoning and development can occur sooner.”

The targets for MTSAs are not proposed to change. However, the definition of Major Transit Station Area has been amended to expand the boundary of MTSAs to be “within an approximate 500 to 800 metre radius of a transit station.” This change in the definition creates some ambiguity. If the interpretation of this policy is to set a minimum radius of 500 metres from the transit station, this will expand MTSA boundaries significantly and will have the effect of opening up significant amounts of land to higher density redevelopment, potentially destabilizing existing residential neighbourhoods, and giving municipalities limited ability to phase development and align growth with necessary infrastructure improvements.

Recommendation 1: To minimize ambiguity, maintain the definition of MTSA as it currently is.

Intensification and Density Targets

The proposed amendment indicates that the purpose of proposed policy changes related to intensification and density targets are to provide: “A simplified approach to minimum intensification and density targets that reflects the objective of supporting provincial transit investments, the planned growth rates and local realities of different communities in the region, including market demand for housing. The application of the different levels of targets recognizes that "one-size does not fit all" and makes it easier to understand and measure the impacts of growth in the region.”

Amendment 1 proposes that regions have different intensification targets. While York, Peel, Waterloo and Hamilton are required to apply a minimum 60% intensification target, places like Durham and Halton are held to a 50% target, and other municipalities like Simcoe and Dufferin have no fixed intensification rate.

Recommendation 2: To ensure that there is a level playing field across the GGH, and to minimize urban sprawl at the GGH level, there should be a single intensification target across the GGH.

Amendment 1 proposes to lower the minimum density targets for designated greenfield areas. Here again, places like York Region, Peel, Waterloo and Hamilton are required to plan for more dense development, while Durham and Halton Regions are provided with a target of 50 residents and jobs per ha., and places like Simcoe and Dufferin Counties are provided with a target of 40 residents and jobs per ha. Given that any employment area within the DGA is excluded from the density target, the proposed targets of 40 and 50 are even lower than what the Growth Plan 2006 required.

Recommendation 3: To ensure that there is a level playing field across the GGH, and to minimize urban sprawl, there should be a single minimum density target across the GGH that is at least comparable to what had been required under the Growth Plan 2006. Furthermore, a request for an alternative target should have to demonstrate how the alternative target will ensure the ability to create transit supportive communities.

Employment Planning

The proposed amendment indicates that the purpose of proposed policy changes are to provide: “A modernized employment area designation system that ensures lands used for employment are appropriately protected while unlocking land for residential development.”

The proposed amendment seeks to protect employment areas. However, the concept of “unlocking land for residential development” is in conflict with that principle.

I support the following proposed policy changes:
• Policy 2.2.5.12 which introduces the identification of Provincially Significant Employment Zones (PSEZ), signifying a higher level of protection of employment lands, in lieu of the Prime Employment Areas contemplated in the 2017 Growth Plan.
• Policy 2.2.5.5 which enhances Growth Plan 2017 policy regarding the employment areas located proximate to highway corridors and major interchanges, as it would direct municipalities to designate these areas for employment uses, whereas the current policy encourages this designation.
• The new policy direction to avoid, or where avoidance is not possible, to mitigate adverse impacts on industrial uses resulting from adjacent more sensitive land uses, major retail or major office uses that may be permitted within employment areas. This proposed change further promotes the need to ensure land use compatibility.
• The proposed new Policy 2.2.5.14 which directs that outside of employment areas, where redevelopment is proposed, new development should provide for land uses that would, at a minimum, retain space for a similar amount of jobs to be accommodated.

Of concern, however, is the proposed Policy 2.2.5.10. This policy allows for employment conversions of non-PSEZ employment areas to occur outside of an MCR, using only some of the criteria that is required to evaluate those requests through the MCR process. This interim piecemeal employment conversion process undermines the MCR process that otherwise provides for comprehensive long term employment land protection.

Recommendation 4: The permission for conversion of Employment Areas outside of municipal comprehensive review should be removed from Amendment 1, in order to ensure that MCR processes intended to provide long-term protection of employment areas are not undermined during intervening years. Accommodation of residential needs should occur outside of these areas through intensification and direction for greater density of development within the DGA.

Recommendation 5: Proposed Policy 2.2.5.16 (d) Employment – This policy suggests that within “Existing office parks” new non-employment uses could be permitted. This policy needs to be clarified. As it reads now, it seems to suggest that “Existing office parks” are not afforded the same protections regarding the conversion of employment lands both under the Growth Plan and the Planning Act that other employment areas are afforded. In other words, this policy addition seems to imply that new “non-employment uses” are permitted within an Existing Office Park Employment Area.

Settlement Area Boundary Expansions

The proposed amendment indicates that the purpose of proposed policy changes are to provide: “A system that enables local municipal decisions on reasonable changes to settlement area boundaries in a timely manner so as to unlock land faster for residential and commercial development that supports more jobs and housing.”

If the proposed policy changes come into effect, that would permit municipalities to more easily expand their settlement area boundary, without the full benefit of analysis that is required by the Growth Plan 2017. Additionally, proposed policies 2.2.8.4 and 2.2.8.5 allow municipalities to modify or expand (by no greater than 40ha) their settlement area boundaries outside of the MCR process. Such an expansion would be subject to fewer criteria than would normally be required when considering a settlement area boundary expansion through an MCR. The criteria for these new methods to expand the boundary solely focus on the ability to meet (or continue to meet) the minimum density targets, and the ability to be serviced by municipal water or wastewater systems. Furthermore, it appears that these boundary changes need not be subject to the current population and job forecast.

Recommendation 6: The permission for a settlement boundary expansion should not be taken lightly. The proposed policy changes to the criteria and permission for an expansion outside of an MCR process should not take effect. Once a boundary has been expanded, its current rural and/or agricultural status is time limited, thereby destabilizing the existing uses of that area. Given the long history of boundary expansions and the current infrastructure deficit that municipalities in the GGH are facing, a more rigorous analysis should be undertaken before a boundary expansion is permitted. In so doing, there is greater opportunity for redevelopment to occur within the built up areas where investment in infrastructure, including public transit, is being made.

Climate Change

Climate change was not identified as a key theme related to the proposed Amendment, however, references to this terminology are proposed to be removed from the Growth Plan 2017, and references to efforts by the previous government to address climate change are also proposed to be removed. This is a significant change given that when the four Plans were brought into effect, Climate Change mitigation and adaptation was a high priority and driver of the updated plans. This focus on Climate Change was in response to the advice provided by the 6-member co-ordinated review panel led by David Crombie. The Panel consisted of a diverse range of interests/disciplines including the development industry, the environment, the agricultural sector, and municipal sector. Collectively, they highlighted the need for the Provincial Plans to address Climate Change in order to build more resilient communities and minimizing/eliminating greenhouse gas emissions. The Amendment, however, proposes various language changes in the plan to eliminate references to “net-zero” and “low-carbon” and replace them with a less specific term: “environmentally sustainable”.

Recommendation 7: It is important for the Growth Plan to continue to be clear regarding its direction to protect the environment in terms of managing growth; protecting natural heritage and agricultural areas and operations, and addressing climate change. Direction regarding achieving net zero or carbon neutral development should remain in the Growth Plan to minimize ambiguity regarding the standards all municipalities should be moving forward to achieve over the long term. Again, this is a matter of creating a level playing field, whereby all municipalities are working together to provide cleaner, safer and more sustainable development, while growth continues to occur.

Schedule 5 – Moving People

Presently, the Amendment 1 does not propose any changes to the schedules of the Plan.

Recommendation 8: Given that the Metrolinx Regional Transportation Plan 2041 has since been updated and that the Yonge Street expansion is now listed as a “in development rapid transit project” to be completed by 2041, this expansion should also be shown on Schedule 5. Identifying it on Schedule 5 ensures that proper planning is in place at the municipal level to accommodate and facilitate the subway expansion.