Housing and Natural Heritage…

Housing and Natural Heritage/Agricultural Land Protection

Thank you for the opportunity to comment on the proposition of combining the PPS with the Growth Plan policies for the Greater Golden Horseshoe (GGH) with a housing focus. I have been involved in land use planning in the Province over the past 45 years, and it is on this basis that I’m forwarding the following comments.

There has been a raft of significant planning policy, legislation/regulation changes in our planning system over the past 5 years. These changes are hard to comprehend in a total holistic manner (over or under-extending planning permissions for new housing), and so I’ve decided to concentrate my thoughts in the area that I know best – the Natural Heritage System (NH) and Agricultural Land (AL) protection planning areas. I would encourage the government to assess the current supply of potential housing development that can be feasibly developed without further massive changes to planning policy, i.e., planning permissions are easily given, but extremely difficult to remove.

As a general comment here, there has been a significant downplaying of the importance of NH and AL protection planning policy with the raft of changes made in the planning system. The impacts from a cumulative basis are hard to assess, and from available information (primarily from the Ontario Auditor General’s office), the Province is not doing an adequate monitoring function in this area. I would argue that in addition to the ‘housing crisis’ that we are facing, we are also facing a sustainability and resiliency crisis as it relates to the protection of clean air and water, and valuable scarce ag/natural feature lands within the GGH. The PPS/Growth Plan provides policy covering all aspects of life, and all policies are to be considered in a comprehensive and holistic manner, i.e., PPS Policy 4.2.

In terms of specifics, I disagree with the proposition that rural severance and estate residential areas are a needed housing resource; these areas individually and on a cumulative basis have immense detrimental impacts to NH and AL resource areas. In addition, loosening the provisions for permitting settlement boundary expansions without comprehensive need assessment undermines the creation of compact, walkable complete communities, and again substantive impacts can/and have occurred to NH and AL areas in the GGH. I am not aware of a defensible economic model that can distinguish between the provision of rural sprawl housing servicing a ‘local’ market versus one for a wide commuting distance (within a 2 hour distance within the GGH).

From the available provincial information, inadequate attention has been given to protecting our urban/rural areas from the existing and anticipated impacts of climate change. I have researched the associative capacities of having a resilient natural foundation to promote healthy human communities in my PhD studies. I would argue that greater planning emphasis is required to promote quality housing policy rather than simply quantity dimensions. I would urge the provincial planners to acknowledge the provision of ‘green infrastructure’ - the NH and AL resource areas to serve as a foundation for a long term stable and resilient urban/rural Toronto-centred megalopolis.
In the substantive rush to direct everyone’s attention to the need to construct more housing in the GGH, I would encourage the government to also be mindful of updating the systems environmental base on what the quality of life is based – clean air, water and land within the GGH. In the rush for more development land and housing, please remember to maintain a robust Natural Heritage System policy framework for the GGH. ERO 013-1014 from 2018 will need to be updated, and a monitoring system be enacted by the government to track changes/impacts to NH lands in the GGH. Similarly, the Agricultural System to acknowledge and protect AL within the GGH – ERO 019-1572 from 2018 will also need acknowledgement and support going forward.

One final thought, the approach to outlining general provincial policy and then allowing local municipalities to make decisions that implement that policy requires substantive co-ordinating and collaborative mechanisms, especially within regional districts and watershed areas. The government’s interest in doing away with regional planning bodies (regional planning departments, Conservation Authorities) will undermine environmental and resource land (NH and AL) interests. I am fearful that the current government’s ‘housing focus’ will undermine, in the long term, issues of human health and welfare as it relates to a clean and resilient environmental and farm land base. We need to be constantly mindful of history where the necessary checks and balances in the local municipal/provincial planning system needs to be provided or we can have catastrophic events/unintended consequences, i.e., the Walkerton clean water disaster; removal of green infrastructure in headwaters of watersheds with disastrous downstream flooding events (Toronto, Mississauga).

“Those who cannot remember the past are condemned to repeat it.” – George Santayana, The Life of Reason, 1905