ERO POSTING NUMBER 019-6813…

ERO POSTING NUMBER 019-6813
Review of proposed policies adapted from A Place to Grow and Provincial Policy Statement to form a new provincial planning policy instrument.

Need for Differentiation of Planning Across all of Ontario:
As the Provincial Planning Statement applies provincewide, there should be a clear delineation between urban, rural, and northern communities and the differences in planning for them respectively.

Support for the Ontario Federation of Agriculture (OFA):
The Provincial Planning Statement proposes large-scale changes to prime agricultural and rural areas by allowing additional severances and rural residential development. These changes risk adversely impacting the long-term viability of farms due to the sometimes-disruptive nature of farming operations, including raising livestock. Additionally, rural municipalities which have limited fiscal resources, will be shouldered with additional infrastructure burdens to support this low-density growth in agricultural areas when there are other opportunities for lands to be used for residential development.

I support the following comments issued by OFA in a January 6, 2023 statement:
“OFA supports the current lot creation policies under Section 2.3.4.1 of the PPS (2020) as is. OFA is utterly opposed to any re-introduction of lot creation policies in the agricultural area that may resemble policies in previous versions of the PPS. We desire to work with the Ontario government to increase density and housing in rural Ontario in ways that do not sacrifice farmland. Anywhere low-density housing already exists presents critical opportunities to advance “gentle density” that addresses the provincial housing supply, preserves farmland, and builds complete communities characterized by smart growth principles in land use planning. OFA believes that in prime agricultural areas, the only permitted uses should be agricultural uses, agriculture-related uses, and on-farm diversified uses.“
Based on initial early feedback from the OFA, it is understood that there are indications that the Province will be pulling back from the initial direction that would have over-ridden municipal planning policies and would have allowed for additional severances. With the distance separation requirements between livestock buildings/barns and manure storage, through the Minimum Distance Separation (MDS), the presence of additional dwellings in agricultural areas would also further constrain the potential for certain farm/livestock expansion. The trend in the area I work in has been for larger farms through a number of farm operators acquiring additional farm properties and severing the surplus existing dwelling as they need the land not the house. This provides the opportunity for retiring farmers and/or family members to remain near the farm. In the community in which I work and live there are many other areas better suited to residential development which need to be pursued and supported to increase density in those areas and support new affordable and attainable residential development. There are more options for lands suitable for residential development and less options for lands suitable for farming so we need to ensure that we protect the ability for farms to continue to operate, grow and expand.

It is recommended that the Province accept the OFA position on this issue and revised the proposed policy change as farming can only occur in areas that are suitable for agriculture while residential development has other options on where to locate. There are other approaches that the Province needs to implement in order to achieve an increase in affordable and attainable housing.

Additional Policy Clarity Required and Education and Support:
As noted in the comments issued by the Ontario Professional Planners Institute (OPPI) in the July 24, 2023 comment letter to Minister Clark, “Though the Provincial Planning Statement strives to streamline the planning process in Ontario to speed up the delivery of new housing, the simplification of numerous policies and removal of core policies compared to the Growth Plan and Provincial Policy Statement may have the opposite effect. By providing less clarity and direction across numerous policies and chapters, the document may create unintended ambiguity which can delay the planning process and subject planning applications to political, rather than policy-based approval processes and decisions. This ambiguity may also lead to more appeals and hearings to argue the intent of the Provincial Planning Statement, which represents the opposite of streamlining the planning process.

To ensure effective communication of these foundational changes, the Province should develop a robust communications and education plan that reaches a wide audience, including the public, development community, and elected officials. The responsibility for introducing and defending the new provincial planning policies should not solely rest on local municipalities. Additionally, Municipal Services Offices within the Ministry of Municipal Affairs and Housing should be adequately staffed to provide support to municipal planners with navigating new policies and legislation. These offices should also be authorized to offer interpretations, provide “one window” comments, make Minister’s modifications and, where necessary, make appeals in order to respond to the Auditor General’s December 2021 recommendations regarding monitoring and implementation. Since there is no appeal mechanism for the provincial policy changes, the Province should prioritize transparency and accountability to the public. Providing a detailed response with the notice of decision, outlining how all feedback was considered and addressed (or reasons for non-addressal), would foster this transparency.”

All of the comments from OPPI set out in the July 24, 2023, letter to Minister Clark need to be considered and addressed.

It is noted that with past significant PPS reviews, the Province engaged in more robust consultation programs with municipalities and stakeholders, including workshops for gathering input and discussion with planners, the public, municipal representatives and other stakeholders. The approach to simply post a draft on ERO for a comment period without full details, prior to adoption places a heavy burden on municipal staff and stakeholders to review and comment, particularly during this time in Ontario where planning departments are experiencing unprecedented workloads and challenges that include keeping up with changes as a result of constantly changing provincial legislation. Opportunities to be engaged in sessions and workshops where provincial staff can provide explanation and overviews of changes, prior to round table inputs would help streamline processes and allow for more meaningful and collaborative comments from municipalities to the Province on proposal for legislative changes. There are concerns that the changes being proposed will not actually achieve the objectives of streamlining process to achieve more affordable and attainable housing in Ontario but rather will create new problems and increase the tax burden on taxpayers in areas that cannot afford for existing residents to supplement the costs of new development that will still not assist in addressing the issues around the housing crisis in a meaningful way.

With the current legislative approach of the Province many changes are occurring with little consultation with municipal stakeholders and others professionals involved in the housing and development processes particularly in the areas outside larger urban centres such as the GTA, Ottawa, etc. Unfortunately, this approach misses out on opportunities to gather important insights on what the issues really are that are contributing to the housing crisis and why developers are not building affordable and attainable housing. More meaningful collaboration between the Province and municipalities would benefit all Ontarians in the joint goal of finding ways to address the supply issue of affordable and attainable housing.

Thank you for consideration of the comments.