Comments on ERO 019-5952 –…

Comments on ERO 019-5952 – Approval to Amend a Municipality’s Official Plan
Amendment No. 6 to the Waterloo Region Official Plan

I strongly support Amendment 6 to the Waterloo Region Official Plan. This amendment strengthens and modernizes policy in several areas (e.g. climate action, equity and inclusion, growth management, and housing mix); updates plans for major transit station areas and local economic growth; and updates a number of policies, objectives and mapping to conform to the Growth Plan and Greenbelt Plan.

I urge the Minister of Urban Affairs and Housing to: a) approve Amendment No. 6 without changes and, b) use it as a model for other municipalities in Ontario. I further recommend that the Minister and other Cabinet colleagues review their numerous proposed legislative and policy changes (e.g. Bill 23; changes to the Planning Act, Provincial Policy Statement, Greenbelt, Conservation Authorities Act and wetland evaluation system; removing the rights of third parties to appeal; and downloading the costs of new infrastructure from developers to municipal residents) and put them through a rigorous analysis similar to the one underpinning the Waterloo Region’s planning process.

The following are the main factors contributing to my support for Amendment No. 6:

1. Waterloo Region engaged with local Indigenous peoples and in the process strengthened the relationship and improved the Official Plan by including language that respects Indigenous values and history, protects the natural environment and recognizes the significance of the Grand River.

2. Waterloo Region engaged extensively with the community; this confirmed strong support for the Region’s vision and policy direction, particularly with regard to tackling climate change; building compact neighbourhoods that combine housing, employment and services in a small footprint; protecting the environment, agricultural land and heritage; and supporting a balanced mix of affordable housing, achievable within the existing municipal boundaries (i.e. retaining the “hold the line” policy.) On this last point, I firmly believe that:
a. urban sprawl should be resisted until all other options to develop additional housing within current urban boundaries are exhausted;
b. urban sprawl requires costly new highways, urban infrastructure, etc.; funding that would go into these items should be diverted to expand and electrify the commuter rail system and to develop the infrastructure needed to transition from the individually-owned personal internal combustion vehicle to a mix of rental and individually-owned electric vehicles;
c. provision of more rural housing should not be done at the expense of valuable natural ecosystems or prime agricultural land;
d. building new housing in naturally hazardous areas should be avoided;
e. farming and agribusiness are major component of the Ontario economy and should be protected at all costs;
f. natural hazards are only increasing under climate change and mitigation should be a major priority; and
g. conversion of employment lands to new residential and mixed-use development must ensure that new residences (sensitive receptors) and the employment activities are compatible and don’t lead to ongoing disharmony between residents and environmentally intrusive businesses.

I would also like to take this opportunity to urge the Province to enact legislation giving Municipalities the authority to adopt policies to better accommodate competing land uses within their boundaries.

Waterloo Region is rich in good quality aggregate resources; this is both a blessing and a curse. Aggregates are an important and essential material in the construction and maintenance of infrastructure, but the aggregate industry is not an environmentally benign industry like the Province’s policies seems to suggest. Aggregate mining operations are large emitters of dust and noise, which impair human health. Furthermore, the dust settles on indoor and outdoor surfaces posing an ongoing nuisance. Gravel trucks driving through the centre of towns pose a danger to the safety of other drivers and residents. The land is often left un-rehabilitated for a long time after extraction has stopped, and when rehabilitation is undertaken the land is never returned to the previous agricultural condition. This entire process needs to be revamped to provide more clarity and assurance to residents and industry; reduce adverse impacts and the number of cases that end up in the Land Tribunal; and rehabilitate the land progressively, as extraction takes place. This could be accomplished by providing the Region of Waterloo Council (and other similar bodies in the Province) with the authority it needs to:
• Establish buffer zones (e.g. 1 – 2 km) around residential and other sensitive neighbourhoods where aggregate mining would be prohibited;
• Set the fraction of total municipal land that would be available for aggregate extraction at any one time;
• Set the fraction of mined land that must be rehabilitated relative to total aggregate licensed land at any one time; and
• Prohibit gravel truck traffic from specific neighbourhoods and urban centres.

Finally, I would urge the Province to recognize and accept that Nature is very complex, that everything is connected to everything else, that past human activity has caused severe ecological stress (e.g. global warming and vanishing species), and that a more holistic approach to planning, that respects natural limits to growth is required. Better planning requires that:
• Available science be used to guide decisions:
• There should be a hierarchy of plans, starting with Provincial, then Regional and finally Local plans (e.g. flooding hazards assessments need to start with predicted future climate, progress to considerations of total watersheds like the Grand River Basin, and then consider impacts in specific neighbourhoods and find the best overall way to mitigate impacts.)