Submission to ERO 019-6813…

Submission to ERO 019-6813 Review of proposed policies adapted from A Place to Grow and Provincial Policy Statement to form a new provincial planning statement
August 4, 2023

This proposal to replace the Provincial Policy Statement (2020) and the Growth Plan for the Greater Golden Horseshoe (Growth Plan) with a new Provincial Planning Statement (ERO #019-6813) is deeply concerning and I urge you not to proceed with these changes. I was born, raised, live and work in the Greater Golden Horseshoe. I participated in the initial public consultation process for “A Place to Grow: Growth Plan for the Greater Golden Horseshoe almost 20 years ago. I also attended and participated in the 2015 Consolidated Plan Review under David Crombie.

“The Growth Plan for the Greater Golden Horseshoe, 2006 was the first growth plan to provide a framework for implementing Ontario’s vision for building stronger, prosperous communities by better managing growth in this region. It established the long-term framework for where and how the region will grow, while recognizing the realities facing our cities and smaller communities and acknowledging what governments can and cannot influence. It also demonstrated leadership for improving the ways in which our cities, suburbs, towns, and villages will grow over the long-term.” The Vision for our GGH is as follows:
• The GGH will continue to be a great place to live, work and play
• A strong economy and an approach that puts people first
• Protects the Greenbelt and ensures a cleaner environment is passed on to future generations
• Supports the achievement of complete communities (transit, protected employment zones and an increase in the amount and variety of housing available)
Furthermore, our cultural heritage resources and open spaces in our cities, towns, and countryside will provide people with a sense of place.

I strongly oppose the creation of a new Planning Statement which is aimed at accelerating housing development at the expense of other matters of provincial interest. Eliminating the Growth Plan under the guise of incorporating its’ policies into a new Planning Statement jeopardizes years of land use policy and disregards the commitment and engagement in the development of the Plan.

Following are examples of Growth Plan (2020) and Provincial Policy Statement (2020) policies that will be weakened or eliminated should this proposal be put onto effect:

GGH 2020 (4.2.8.2 a) protects key natural heritage features and key hydrologic features in significant wetlands, habitat of endangered species and threatened species, and significant woodlands (subject to definition and demonstration) by PROBITING new mineral aggregate operations, ancillary and accessory uses.
- Sometimes you have to say NO and sometimes you have to say NO repeatedly (see ERO-019-1680 proposal and the subsequent decision)

PPS Proposed (4.5.4.2 a) b) all references to specialty crop areas (removed) consideration for other alternatives (removed) and protection of prime agricultural lands (removed through changes to rehabilitation in the proposed planning document)
- Prime agricultural lands and specialty crop areas (and recognition of their unique microclimates) must be IDENTIFIED and PROTECTED for long-term use. They are a finite and non-renewable resource)

PPS Proposed (3.5 Land Use Compatibility) has been significantly altered to favor major facilities without the need for a reciprocal assessment of sensitive land uses.
- Stressing a one-way impact assessment which favors major facilities without emphasizing a reciprocal sensitive land use assessment, will increase land use conflicts. The onus is on the major facility to initially, continually and permanently eliminate or minimize adverse effects to public health and safety on impacted sensitive land uses. This does not represent good planning.

In addition to the above, I am not in support of rewriting a Policy Statement and Growth Plan under a demonstrably false premise. “Land is available, both inside the existing built-up areas and on undeveloped land outside greenbelts” (Ontario’s Housing Affordability Task Force, 2022). What is presented here is short-sighted. Both the Provincial Policy Statement (2020) and the Growth Plan for the GGH (2020) are critical provincial policies that provide comprehensive, integrative, and balanced direction on land use planning in Ontario.

The proposed document has far-reaching, long-term and irreversible outcomes by proposing changes that would:
- Eliminate mandatory intensification and greenfield density targets
- Disregard decades of land use policy in favor of land development at a time when a changing climate is threatening and irreparably damaging our natural environment, our health, and our safety
- Allow municipalities to expand settlement areas at any time, while eliminating Municipal Comprehensive Reviews which promotes sprawl
- Redirect growth into unserviced areas, including prime farmland, and targets growth to cities that may not have the capacity to supply clean drinking water. The report from the Walkerton enquiry is comprehensive, extensive and critical to these proposals
- Removes the requirements for municipalities to undertake watershed planning. This is contrary to Policy 4.2 (Policies for Protecting What is Valuable, The Growth Plan 2020) which states that “Upper- and single-tier municipalities, partnering with lower-tier municipalities and conservation authorities as appropriate, will ensure that watershed planning will be undertaken to support a comprehensive, integrated, and long-term approach to the protection, enhancement, or restoration of the quality and quantity of a watershed.”
- Abandon Ontario’s long-standing commitment to promote compact, transit-friendly development and prevent sprawl
- Eliminate the Growth Plan which identifies and protects our natural heritage, water resources and agricultural systems, our cultural heritage resources and our sense of place

In conclusion, the frequency of the Environmental Registry of Ontario’s Proposals by the current provincial government is indicative of the numerous and recent law and policy changes. It is unsettling for the public, municipal and regional governments.

In the interest of the public and future generations of Ontarians, I urge you to exercise caution. DO NOT PROCEED with the replacement of these two key policies. “They have been developed over decades based on the experience of municipalities, expertise of planners and through intensive public consultation.” (Ontario Nature and Environmental Defence submission ERO 019-6177). The things that are being proposed are things you can’t take back (Bruce Arthur, Toronto Star April 11, 2023).