Thank you for the…

Thank you for the opportunity to review and comment on the Environmental Registry of Ontario (“ERO”) posting 019-8462 regarding the review of proposed policies for a new provincial planning policy instrument (proposed PPS, 2024).

Please note that the following comments and recommendations are provided by City of Mississauga staff and have been endorsed by City Council at its meeting on May 1, 2024. The report to City Council is provided in the supporting link below.

The following contains a summary of the City of Mississauga's comments on ERO 019-8462. In addition, detailed comments on the proposed changes are provided in the attached table (supporting document) below.

INTRODUCTION

Addressing Ontario’s housing challenges will require coordinated effort from all levels of government. The City of Mississauga is committed to doing its part to help address the housing crisis. This includes making sure there are no municipal barriers to develop 120,000 homes in Mississauga by 2031, and releasing an Action Plan for New Housing to help get us there.

We support the Province’s efforts to address housing supply, however we continue to have concerns with a few areas of the PPS, 2024 and suggest the following recommendations noted below. Detailed comments are included in the attached table.

CHANGES TO EMPLOYMENT POLICIES

Mississauga has the second largest employment node in Canada and its supply of serviced and flexible employment lands is the prime reason why it’s been so successful attracting major businesses.

PPS, 2024 proposes to move towards more of a site-specific approach to removing lands from employment areas rather than the current periodic comprehensive approach. A site-by-site application approach to employment land conversions does not allow for a more comprehensive analysis of the impacts to existing and future success of employment lands. For Mississauga, the current municipal comprehensive review every five to ten years works well. Recently, Peel Regional Council approved the removal of approximately 250 hectares (618 acres) of employment lands in Mississauga to support the building of more homes after comprehensive study. This approach allowed for consideration of potential impacts to surrounding industry, changes in land supply, trends in employment space and market conditions.

Secondly, most municipal official plans have identified areas targeted for new residential development and have correspondingly planned to service these areas with important community infrastructure (e.g. schools, parks, community centres, libraries). A site-specific application process is not the best tool for planning future communities. Random approval of residential uses within an employment area would likely destabilize its overall functionality and create situations where future residents need to travel to access community services.

Additionally, the proposed PPS would place limits on new office or retail uses in employment areas. The City suggests that office and retail uses have their place in employment areas. They provide jobs, access to services and amenities, and help attract investment to Ontario. They also help provide a transition between neighbourhoods and industries that may emit noise or fumes. Office developers often prefer employment areas since land is cheaper compared to residential areas making it easier for investment.

Key Recommendations:
• Consult further with industry, business and municipal leaders that could be significantly impacted by proposed changes.
• Maintain the existing approach for the removal of employment lands that can only be considered through a municipal comprehensive review process at 5-10 year intervals, unless municipally initiated.
• Another option would be to shorten the interval between comprehensive reviews to every five years.
• Allow small-scale office and retail services that complement and strengthen the function of the employment areas and provide services and amenities to the employees in those areas (e.g., essential office and retail uses such as restaurants, pharmacies, medical offices, etc.). They should also allow for commercial uses where other PPS policies do not permit sensitive land uses (e.g. adjacent to the Airport), or where they provide a transition to nearby residential communities.
• Policies should recognize commercial uses may continue to be permitted where they are lawfully established as per Bill 97.

PERMITTING AND FACILITATING RESIDENTIAL INTENSIFICATION ON COMMERCIAL SITES

The Province is also proposing to make it easier to redevelop existing commercial sites outside employment areas with residential uses. In Mississauga many commercial plazas, malls and aging office buildings are already facing significant redevelopment pressures. Commercial sites are critical to meeting the daily needs of residents, providing nearby amenities, services and local employment. Staff suggest that stronger policy language to maintain a mix of uses on these sites would still allow for the introduction of residential uses, while preserving access to amenities and services in communities.

Key Recommendation:
• PPS, 2024 should direct municipalities to facilitate mixed-use, walkable communities by retaining/replacing significant non-residential floor space on commercial sites as part of any future redevelopment.

VISION

The City supports efforts to increase housing supply. The City recognizes that solving the housing affordability crisis will take significant effort, bold moves from all those involved in housing approval and development, and innovative approaches to planning and construction.

Measures to expedite housing supply should balance different planning priorities. The Province of Ontario (Province) should not implement measures that would generate short-term benefits while creating long-term negative impacts on the natural environment, agricultural systems, infrastructure and transit delivery, economic prosperity, and the creation of complete communities.

While it is important to create more housing in the GGH, new developments should not undermine access to services and jobs near where residents live, and that major cost savings can be achieved by coordinating growth and infrastructure delivery.

Key Recommendation:
• Redefine complete communities to include "healthy, liveable and safe", or revise vision to include this language.

GROWTH MANAGEMENT

The changes would make it more difficult to align growth with infrastructure planning.

Key Recommendations:
• Carry forward policies that:
o relate to building strong, healthy communities, and managing and directing land use; and
o allow growth to be tied to the efficient use of existing and planned infrastructure.

PLANNING FOR PEOPLE AND HOMES

City staff support the Province allowing municipalities to keep using the approved growth forecast to 2051 as this forecast is already being used for infrastructure master planning.

There are associated risks with using the Ministry of Finance 25-year projections to forecast growth that may not consider land supply and water and wastewater servicing constraints. Every municipality will be adopting their individual approaches to forecasting with the potential for inconsistencies and without considering overall growth in southern Ontario.

Key Recommendations:
• Confirm what assumptions are included in Ministry of Finance 25-year projections (e.g. servicing and land supply).
• Provide a growth forecasting methodology to ensure consistency between municipalities.
• Re-insert the following policies and/or wording:
o Promoting development and land use patterns that conserve biodiversity.
o Avoiding development and land use patterns which may cause environmental or public health and safety concerns.

HOUSING

The City generally supports introducing residential uses on underutilized commercial and institutional sites as part of a mix of uses where appropriate, but has concerns the proposed policy does not reference a mix of uses.

Key Recommendations:
• Policies should direct non-residential floor space on commercial sites be retained as part of any future redevelopment, wherever possible.
• Policies permitting and facilitating residential development of underutilized commercial and institutional sites should include “as part of a mix of uses that supports the achievement of complete communities”.
• Include minimum affordable housing period of 25 years for rental and up to perpetuity for ownership.
• Define what is meant by “underutilized” in reference to institutional and commercial sites and "equitable housing” (e.g. equitable access to affordable housing? If so, how?).

SETTLEMENT AREAS AND SETTLEMENT AREA BOUNDARY EXPANSION

The proposed removal of minimum density requirements for greenfield development may result in fewer homes being built. The development industry has demonstrated that they can build new greenfield communities in excess of current mandated minimums in the Growth Plan.

Allowing residential growth in areas not planned for would affect a municipality’s ability to optimize resources including unplanned social and physical infrastructure upgrades.

Key Recommendations:
• Carry forward settlement boundary expansion criteria in the Growth Plan (i.e. section 2.2.8).
• Retain policies requiring municipalities to create intensification strategies, focusing growth and intensification in SGAs, establishing minimum intensification targets, and requiring new development to occur adjacent to existing built up areas.
• Retain requirement for a minimum greenfield density target to facilitate the achievement of complete communities; while avoiding the need to develop on natural areas and prime agricultural land.

STRATEGIC GROWTH AREAS

Comments provided under Housing on the development and redevelopment of underutilized commercial sites are also applicable to this section.

Key Recommendations:
• Retain Provincially delineated UGCs which could be modified through a municipal comprehensive review.
• Provide a definition for “Downtowns” that recognizes they are created through an Official Plan review and/or Provincially delineated UGC.
• Reconsider implications of policy 2.4.3 on frequent transit corridors:
o This policy is too broad and may compete with a municipality’s ability to attract development in MTSAs and Downtowns.
o Clarify that “where appropriate” provides flexibility for municipalities to determine which, if any, frequent rapid transit corridors should be included in a SGA.
o Clarify what is meant by “adjacency” and “transit frequency” as it varies according to many factors such as: changes in the seasons, overall ridership, and transit networks. A frequent local bus route is not as fixed as a higher-order transit line and may not always support intensification.
• Consider including policies on the following: o Focusing growth in SGAs (e.g. UGC, MTSA) where infrastructure investments (e.g., transit) would be optimized and where there are more opportunities to create complete communities. If growth is being redirected elsewhere, the achievability of minimum targets within SGAs, such as MTSAs, would be more challenging. o Identifying, planning for, and directing growth to urban growth centres. Most large municipalities have already centred

AIRPORTS

The City supports the Province’s proposal to have stronger policy language prohibiting land uses which may cause a potential aviation safety hazard.

LAND USE COMPATIBILITY

Key Recommendation:
• The Province should re-emphasize avoidance as opposed to mitigation for development proposing sensitive land uses adjacent to major facilities. The proposed policies appear to place the burden on industry through regulatory approvals, which may frustrate their ability to continue to operate or expand.

NATURAL HERITAGE

The City supports the retention of the Natural Heritage policies.

Key Recommendations:
• Clarify whether there are any additional/refined criteria and procedures being developed.
• If the Province chooses to release criteria and procedures on significant wetlands and woodlands, the City welcomes collaboration on their development.

NATURAL AND HUMAN-MADE HAZARDS

The City supports the inclusion of policy requiring the identification of hazard lands and the management of development in these areas. The City will continue to coordinate with conservation authorities when evaluating development applications to assess the limits of development near hazard lands.

The City has no concerns with the removal of policy language regarding on-site and local re-use of excess soil.

CULTURAL HERITAGE AND ARCHAEOLOGY

Key Recommendations:
• Clarify the meaning of “proactive strategies” in regard to identifying properties for evaluation under the Ontario Heritage Act. Will there be an opportunity to discuss examples? Additionally, would this language apply only to archeology or to all historic properties?
• Clarify engagement requirements with Indigenous communities. What is meant by "ensuring interests are considered" and what is the expectation of municipal staff?
• Policies on engagement with Indigenous communities should be clarified to facilitate more substantive municipal-Indigenous relationships.

IMPLEMENTATION AND INTERPRETATION

Each Official Plan conformity exercise requires a significant amount of resources for staff to conduct research, policy development and engage with Council, Indigenous communities, community, and stakeholders. The City is at the final stage of completing its 10-year Official Plan Review. Having to review the City’s Official Plan again and in a short time frame to be consistent with a new PPS would require additional time and resources. In addition, the period in-between conformity could create more uncertainty for development and could impact the success of several City planning initiatives.

Key Recommendations:
• Policies should include a transition extending the timeline for the completion of official plan reviews to address changes to be consistent with the proposed PPS.
• Restore the policy that the official plan is the most important vehicle for implementation of this PPS and that comprehensive, integrated and long-term planning is best achieved through official plans.

COORDINATION

Mississauga welcomes the opportunity to coordinate on student housing matters with post-secondary institutions. This is reflected in our housing supply pledge – Growing Mississauga. In addition, the City is supportive of the local HomeShare program. However, our experience to-date has been that post-secondary institutions prefer to rely on the secondary rental market to satisfy demand.

Key Recommendations:
• Clarify what is requested for engagement with Indigenous communities. What is meant by "ensuring interests are considered" and what is the expectation of municipal staff?
• Policies for collaboration with school boards should also involve development industry.