Review of A Place to Grow…

Review of A Place to Grow and Provincial Policy Statement

ERO number 019-6177

Settlement Area Boundary Expansions and Rural Housing:
Introducing sprawl-based policy incentives into the municipal planning system has the power and potential to disrupt cohesive planning relationships between cities and counties. The City of Peterborough has sufficient land within its delineated boundary and encroachments into Peterborough County, enabled by these planning changes, encourages an urban sprawl approach to long-term planning.

In the case of the City of Peterborough, with the 2021 approval of its Official Plan, regional connections between the City and County to increase the Natural Heritage corridor linkages was an aspiration of the plan. This change in policy with its focus on sprawl and expansion can undermine any progress made on the local political level with regards to long-term environmental protections and ecosystems planning. Followed by the policy direction that increases “flexibility” to enable more residential development in rural areas, the increased pressures these proposed policy changes put on linkages and agricultural lands between Peterborough City and County are not in alignment with your claimed: “Protection and management of resources, such as aggregates, natural heritage, water, cultural heritage, recreation and prime agricultural areas.”

These policy concepts in the new policy document need to be retracted.

Environment and Natural Resources - Natural Heritage:
Using the housing crisis as a guise for removing regulations and protective structural components that gird sprawl-based development is irresponsible and dangerous. Given our larger, global biodiversity crisis and recent COP15 targets, this policy direction defies imperatives for the protection and enhancement of ecosystem functions and services, ecological integrity and connectivity. Further, these policy changes degrade the very structures, such as Conservation Authorities (CA) to effectively conserve and manage through ecologically representative, well-connected, and equitably governed systems of protected areas, and to implement effective area-based conservation measures. Essentially, your policy changes do not target intensification --the type of growth we need-- for urban centres and affordable housing.

The policy concepts introduced for “streamlined” and “flexibility” in [sprawl-based] development need to be retracted from the new policy document. I do not agree with developments impacting Natural Heritage features being authorized by the Planning Act to be exempt from CA approvals in any municipalities. Changes to the Conservation Authorities Act that will restrict the role of Conservation Authorities needs to be reversed. Technical review of Natural Heritage, Arborist, Hydrogeological, and Geotechnical studies on behalf of municipalities through specific standing agreements need to be enabled moving forward. Any core concepts and changes that negate this need to be replaced with commitments to the previous enforceable environmental legislation and vested authorities.