Re: Proposed Amendment 1 to…

February 28th, 2019

Re: Proposed Amendment 1 to the Growth Plan for the Greater Golden Horseshoe, 2017 (2019)
The Ontario Public Health Association (OPHA) appreciates the opportunity to provide comments on the Proposed Amendment 1 to the Growth Plan for the Greater Golden Horseshoe, 2017 (the Growth Plan). OPHA is a member-based, non-profit, non- partisan organization, which has been providing an independent voice for public health for 70 years. We bring together a broad spectrum of individuals and groups from various backgrounds and sectors, all of whom are committed to promoting the health and wellbeing of Ontarians.

There is increasing evidence that healthy and complete communities, which are communities that are compact, pedestrian-friendly, transit-supportive, and conducive to a variety of uses, positively impact population health and health equity. Research indicates that low-density and automobile-dependent communities adversely affect the health of residents. For example, such communities can be associated with increased rates of obesity, diabetes, cardiovascular diseases, respiratory illnesses and increased exposure to environmental contaminants.

OPHA supports the guiding principles of the Growth Plan, especially the principles which contribute to health such as: the promotion of complete communities that are designed to support healthy and active living; intensification and higher densities to support transit and service viability; and protection of the environment. The Growth Plan is an important and valuable tool that OPHA members rely on when working with regions, counties, cities, and towns to develop local policies in support of healthy, complete communities.
OPHA is committed to advocating for a comprehensive and health-promoting Growth Plan, and as such, has been participating in written and in-person consultations regarding the Growth Plan since 2015. Recently, OPHA was invited to provide comments in-person at the Growth Plan for the Greater Golden Horseshoe Stakeholder Forum on November 8th, 2018 and at the Stakeholder Exchange on the Proposed Changes to the Growth Plan on February 11th, 2019.

OPHA supports Proposed Amendment 1 to increase flexibility and reflect the realities of various local contexts. However, it is critical that local-level policies encourage and contribute to the most healthy, complete, climate-resilient communities possible for each context (e.g., compact, pedestrian-friendly, transit-supportive, and conducive to a variety of uses.) This would require the establishment of clear criteria and performance measure indicators to evaluate implementation and impact of the Growth Plan and the Proposed Amendment 1 with respect to topics such as density, affordable housing, and land use mix. Below, we are pleased to offer a summary of our recommendations regarding Proposed Amendment 1. Please find more detailed comments regarding each recommendation in Appendix A in the attached document.

Our recommendations are based on the following central guiding principle of the Growth Plan: Proposed amendments shouldn’t compromise the vision to build healthy, complete communities.

OPHA urges your government to consider the following recommendations:

Intensification Targets and Designated Greenfield Area Density Targets
- Maintain minimum densities above 50 people and jobs per hectare to support transit, walkability, and mixed-use development.

Employment Planning
- Support the development of an Economic Strategy for the Greater Golden Horseshoe as employment areas may be part of an overall strategy for employment for the region and municipalities.

Settlement Area Boundary Adjustments
- To protect the natural environment, limit expansion of settlement area boundaries within white belt, greenbelt, natural heritage, or agricultural systems if there is an opportunity to intensify in already established boundaries.
- Avoid lessening the requirements for large settlement area boundary expansions as this may discourage intensification; intensification helps promote more active lifestyle.
- Provide more clarity about the amendment to allow municipalities to do boundary expansions of 40 hectares without an Official Plan review. For smaller municipalities 40 hectares represents a significant portion of land which could potentially hold 200-300 new homes, a large development for some communities.

Major Transit Station Areas
- Retain existing density targets, expanding the potential ratio of major transit station areas, and expediting designation processes to support transit.
- Consider clarifying the conditions/definitions under “Major Trip Generators” such that it is not used to enable lower density with unrealistic trip generation to support transit sustainability.

OPHA would welcome any further opportunities to be involved in this review and follow-up processes. We value being able to collaborate with your ministry to advance our shared interest in creating healthy, livable, complete and climate-resilient communities. OPHA, through its Build Environment Working Group will be contacting your branch to set up a meeting to discuss how we may assist your ministry in achieving healthy and complete communities in the Greater Golden Horseshoe.

Thank you for your consideration.