Please Respond to the Provincial Planning Statement by Midnight on Monday, June 5
By Sheila Clarke
Respond to the PPS here:
https://ero.ontario.ca/notice/019-6813 |
Upcoming is another Environmental Registry of Ontario Hearing. It deals with the Provincial Planning Statement, a document designed to lay out a blueprint for land use, community and housing planning in Ontario. Its goal is to create a planning framework that subsumes numerous regulations and previous planning documents into one overall multifaceted “Statement.”
It is remarkable in its intent to destroy decades of careful planning in Ontario. Previous planning gradually developed remarkable regional strategies based on protection of farmland, wetlands and environmental habitat, and carefully planned housing concentrations where municipal services of power, water and sewage were available. The new Statement disregards that previous framework and while there is some municipal decision-making, control of all land use decisions rests with the government.
The financial implications for municipalities needing to support sprawl infrastructure without development fees are staggering. As well, removal of farmland, green space (habitat/carbon sink) and wetlands (habitat /flood control) leaves us extremely vulnerable to food insecurity and climate crises.
Sadly, the following list is not complete! I’ve put the most alarming PPS proposals first. Others that are also important are at the end, but also I’ve put further links that will give more information! You are encouraged to take any of the following points that are meaningful to you and submit a comment to the ERO by June 5th. You could simply pull the recommendations into a letter, or you could speak to one of the areas in particular. The important part is to speak up, even when it seems no one is listening. Your comments are being noticed, and we know, Silence is Permission! 🙂
Major issues are Food Security, Appropriate Land Use, and Environmental and Climate Protection and Safety.
1) The PPS proposes a remarkable permission for farm land severance, that would enable multiple dwellings and severances leading to reduction of farmland, housing sprawl on prime farmland, multiple urban dwellers living next to farms, serious questions of ground water safety and the need for water, and hydro and water/sewage services for housing in the midst of farmland. Again, food security would be severely compromised as farmland disappeared to multiple severances. The PPS proposes that each farm may have three severances, as well as two other extra dwellings on retained land. As well, this policy would make it all but impossible for a young person to be able to afford farmland. ALL the farm federations in Ontario are speaking against the proposed farm severance policy.
Recommendation: S.4.3.3 should be removed in its entirety as it undermines and contradicts overall connected farm resources and protection of farm land.
2) In 2.3 under Settlement Areas and Settlement Area Boundary Expansion, language requiring densification and mixed land uses has been changed from “shall” to “should,” weakening policies aimed at intensification and use of current lands available.
A recent report identified ample lands available to meet government housing targets, without the removal of farm, wetland and habitat areas surrounding municipalities. See it here
As well, previous planning statements recommending land use patterns should “minimize negative impacts to air quality and climate change, promote energy efficiency” and “prepare for the impacts of a changing climate” have been removed. Given the climate crisis we are facing and that agriculture relies on healthy and stable ecosystems to produce a consistent supply of quality local food, environmental impact should remain a part of planning policy.. By removing this language, the province is threatening both food security and the agricultural sector.
Recommendation: Section 2.3 should retain mandated intensification targets for increased housing, and should incorporate language minimizing environmental effects of expanded housing development.
3) The New PPS would allow municipalities to expand their urban boundaries more easily, by either identifying new settlement areas or allowing the expansion of existing settlement area boundaries. There would no longer be a requirement for municipal comprehensive reviews, and municipalities would not be required to demonstrate the need for expansion under a new, simplified and flexible approach for settlement boundary expansion. Municipalities would be required to permit more residential development on rural lands, including farmlands and other greenfield sites.
Recommendation: Maintain growth plans that include comprehensive municipal review, and protect farmland and greenfield sites.
4) MZO (Ministry zoning Orders) would no longer be required to be consistent with any provincial policies/plans or municipal official plans. The Minister may require an MZO for lands beyond those designated by a municipality for housing. That use of an MZO would be final, and could include infrastructure requirements.
Recommendation: MZO’s must be consistent with provincial policies and with municipal official plans.
5) In the area of water policy, there are several points:
The PPS would abandon the policy prohibiting Great Lakes water pipelines to inland communities (except in cases of health concerns).
It would abandon the requirement for environmental assessments for sewer/water infrastructure to accompany urban boundary expansions
It would weaken the commitment to watershed planning and would rely on municipalities rather than on conservation authorities to prepare watershed plans.
It would remove the requirement for watershed plans to be completed in advance of urban boundary expansions.
Recommendations:
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- Continue to prohibit water pipelines to take Great Lake Water to inland municipalities.
- Continue to require environmental assessments for sewer/water infrastructure for urban boundary expansions.
- Enable Conservation Authorities to prepare watershed plans.
- Continue to require watershed plans in advance of urban boundary expansions.
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6) Definitions of affordable housing and low/moderate income households are removed.
Recommendation: Return affordable housing and low/moderate income household definitions to the provincial planning statement.
7) The PPS would weaken commitment to planning in relation to life-cycle costs of infrastructure (i.e. changed from requiring to encouraging)
Recommendation: Maintain required planning for life-cycle costs of infrastructure.
8) s.4.3.1.2 removes the requirement that agricultural planning must be consistent with provincial planning standards. Lack of consistent standards may lead to a patchwork of definitions, a lack of consistency in agricultural planning, and unreliable Ontario food supply chains.
Recommendation: that municipalities use the guidelines developed by the province to designate prime agricultural areas and specialty crop areas.
https://ero.ontario.ca/notice/019-6813
🌟🌟🌟 ERO Response Link 🌟🌟🌟
Thank you for whatever you are able to do!
ADDITIONAL RESOURCES
- Ontario Nature Action Alert
https://ontarionature.good.do/no-sprawl/email/
- Alliance for a liveable Ontario
- Comment through the Environmental Registry of Ontario (ERO) until June 5. Even a short statement of your concern and opposition about the planned changes is important.
https://ero.ontario.ca/notice/019-6813
Check out this link if you want to say more in your submission. Template to send ERO letters and comments: https://ontariofarmlandtrust.ca/2023/05/17/ero-comment/
- Inform your local media about this affront to Ontario’s farmland and our future food security.
