The New Growth Plan Puts Sprawl Over All

We can no longer treat land use as its own issue, nor can we always assume that growth is always a net benefit to our communities. This is simply not true. We can grow our communities in ways that provide affordable housing, protect our natural spaces and water and aspire to create healthy, vibrant centres where people can live and work.

The Ford government is rolling back progress on building healthier communities.

How Did We Get Here?

The transition from 1950s sprawl development to smart growth policies as a provincial concern was really solidified by Premier Mike Harris. 

Yes, that Mike Harris. 

Despite his first term, which gave municipalities more freedom to grow as they wish, by the second term key grassroots movements to protect the Oak Ridges Moraine demonstrated to the public how sprawling growth patterns were hurting our water, our land and our health. 

In response, the Harris government decided to get sprawling growth patterns under control and set up a series of Smart Growth Panels across Ontario. 

That was in 2002.

Central Zone Smart Growth Area map.
Central Zone Smart Growth Area map.

The Central Zone panel, which included Simcoe County region, concluded early on in its mandate that the status quo sprawl and growth at all costs mentality would lead to dire consequences for the region by 2035 including: commuting trips that would take 45 percent longer, mostly due to congestion; a marked deterioration in air quality; worsening delays in the movement of goods; and higher taxes.1Neptis: Smart Growth and Places to Grow

Complete Communities Connected by Public Transit

The panel sketched out a concept of how growth in this area should go to avoid those outcomes – its vision relied heavily on compact, complete communities connected by public transit: TTC rail, GO rail, bus rapid transit, and inter-city and inter-regional rapid transit. There were also delineated areas for protected natural zones and an awareness of agricultural lands that were under increasing pressure from growth. 

When the Liberals came into power in 2003, they used a lot of the concepts from the Smart Growth Panels to form Ontario’s first Growth Plan. The award-winning Growth Plan directed growth to form complete communities and stop sprawl.

Ontario's Growth Plans, through the years.

Cover of Ontario's Growth Plan 2020

Growth Plan (2020)

This is the most recent version of the Growth Plan, revised by Doug Ford’s government, which contains many of the problems pointed out in this post.

Cover of Ontario's Growth Plan (2017)

Growth Plan (2017)

The plan as it was under the previous Liberal government.

Cover of Ontario's Growth Plan (2006)

Ontario's Growth Plan (2006)

The original the Growth Plan, titled “Better Choices, Better Future.”

Unfortunately, these efforts were short lived.

A series of amendments and regulations watered down the objectives over the years, but at its core it still aspired to keep sprawl in check through limiting growth in rural areas, ensuring large developments were on municipal services, promotion of public transit, climate change considerations and rigorous criteria in order to expand settlement areas.

So why the history lesson on planning? 

Well it’s important to note that governments, over previous decades, have been trying to avoid the situation the province is now promoting, which is sprawling subdivisions, and with a very little strategy to deal with climate impacts, water impacts, and loss of farmland and biodiversity that come with it.

What is Happening Now?

It’s not hyperbole to say that the changes  made recently by the province with respect to growth and planning take us back to the 1990s. Some of the problematic changes include:

  • Density targets for our region have been scaled back tremendously.

This calculation outlines how efficiently we use land to house people and places of employment.   

  • The limits that were put on growth, previously known as population allocations, are now set as a minimum target, not as a maximum as they were before.
  • Formerly, settlement areas could only be expanded during the Official Plan (OP) process, so long as evidence is presented to demonstrate need. Now  they can be expanded up to 40 hectares outside of the OP period.
  • New developments no longer need to prioritize being serviced by municipal water or wastewater – septics and communal septics are now allowed more easily.

This enables development to get into more natural, rural areas, and puts water quality at risk.

  • Calculations to determine how much land must be set aside for new growth outside of built upon land have changed too.

The municipality must now plan for growth to 2051. This means that in the middle of a pandemic with no knowledge of how work/commute/travel patterns will change, municipalities must decide by June, 2022, how much new land to give up to development.

It also means that due to COVID restrictions this Municipal Comprehensive (MCR) process, that requires public consultations, is limited to online interactions. That’s why many communities are asking their local government to delay these decisions until people can properly consult with staff and neighbours.

  • Municipalities are now forced to calculate how much land based on market needs.

Simply put, there are two ways to calculate this – looking to see what you will need in the future based on changing demographics, what you already have planned, and anticipated need (e.g. more rentals/apartments/seniors residences etc.)…

OR

…you can look back to what has historically been provided by the market (e.g. detached homes, McMansions) and then just extrapolate that forward. 

The current government chose the second option.

This means that in places like Simcoe County where large homes dominate housing stock, we can expect more of that despite more people requiring smaller units and apartments (seniors downsizing, youth, low income).

This also means that more of our green spaces and farmland will be sacrificed to provide for McMansions and sprawl, while people who need housing types that are more affordable (laneway homes, stacked townhomes, apartments) will be mostly ignored.

Photo of "McMansions". Credit: Brett VA - CC BY 2.0.
Photo of "McMansions". Credit: Brett VA - CC BY 2.0.

Why Is It A Concern?

In all of this we need to understand one simple truth – how we grow and where we grow has a massive impact on climate change, water health, biodiversity and our health consequently. 

Growth patterns lock in centuries of impacts and GHG emissions. We can no longer treat land use as its own issue, nor can we always assume that growth is always a net benefit to our communities.

This is simply not true. We can grow our communities in ways that provide affordable housing, protect our natural spaces and water and aspire to create healthy, vibrant centres where people can live and work.

Or, we can grow our communities in ways that use 1950s thinking to deal with 21st century challenges – which will lead to more sprawl, more highways and less public oversight.

One path chooses the needs of the people and our natural communities, the other helps line the pockets of speculative developers at the community’s expense. 

Unfortunately, the province’s policies are 60 years behind the evidence and science, and our communities, now and in the future, will be worse for it.

How Can You Get Involved?

  1. Push back against mega-projects, such as the Bradford ByPass, The Orbit, and the Upper York Sewage Solution.
  2. Share your concerns on social media.
  3. Sign up to our newsletter to stay informed on developments with growing the Greenbelt and limiting sprawl.

Links to Further Reading

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Open Letter - Ramara Must Officially Rescind Request for MZO

Ramara has requested a MZO for developments in the Rama Road Corridor. Without an official letter from the municipality rescinding that request it remains in play.

Dear Mayor and Council.

As you are aware, we have grave concerns about the power of Minister’s Zoning Orders (MZO) – how they cut out public consultation and undermine the role that environmental studies play in ensuring developments don’t result in a net loss of value to the public, being two key issues.

The use of a tool that is as blunt and powerful as a MZO is especially concerning in places where landscapes and watersheds are shared, with their ecosystems or flows extending beyond a single jurisdiction.

Image showing the watersheds in and surrounding Lake Simcoe and Simcoe County.
Image showing the watersheds in and surrounding Lake Simcoe and Simcoe County.

Return to the Planning Process

To ensure development provides a benefit to the community, by which we mean both our human communities and the natural communities that we are a part of and rely upon, it is crucial that they meet a high level of rigour in determining their ‘fitness’ in a given location. Projects such as what is proposed for the Rama Road Corridor must, at minimum, meet the requirements set out under the Planning Act process.

MZOs Cause Inconsistency and Confusion

Confusion remains, however, regarding whether a MZO has been requested by Ramara for projects in the Rama Road Corridor. Our coalition was relieved to hear, during the Orillia special meeting this week, that Ramara does not want to proceed with a MZO request.

It is important to be very clear that the Township of Ramara has initiated a MZO request, and that until and unless Council officially rescinds this request with a letter to the Minister, this request stands.

Ramara Has Requested a MZO

The fact that Ramara has initiated a MZO request, which is all that is required since there is no formal application process outlined under Section 47 of the Planning Act for MZOs, is evidenced by the following:

First, a motion was passed by the Township of Ramara on November 2, 2020. In item 6.1 of the agenda council passed a motion to allow Mayor Clarke to sign a letter to accompany the Rama Road Economic Employment District package. Although the letter does not mention a MZO application in its body, within the package the request for a MZO for this project was bluntly stated:

“The municipality is requesting that the Minister ​enact​ a Minister’s Zoning Order for the three proposed developments in order to commence the growth and development within the Rama Road Corridor.”1Township of Ramara. Minutes of the Committee of the Whole Meeting Dated: Monday, November 2, 2020.​ ​(Emphasis added.)

With a motion of council to endorse this package, it most certainly can be considered an official municipal request for a MZO. Further, it doesn’t state it wants to explore a MZO discussion or open up the feasibility of a MZO, but enact one.

Simcoe County Has Backed This Request

Second, a request was made by the Township of Ramara to the County of Simcoe Council to endorse Ramara’s MZO request.

It first went to the Committee of the Whole on November 10, 2020. Mayor Clarke moved a motion “that the County of Simcoe supports the letter dated November 3, 2020, titled Rama Road Economic Employment District.”2County of Simcoe. Minutes of Committee of the Whole Meeting Dated: Tuesday, November 10, 2020.​ As a reminder, this letter accompanies the ​Rama Road Economic Employment District package which explicitly requests a MZO to be enacted.

Screenshot of the section of the Rama Road Corridor Package that requests a MZO.
Screenshot of the section of the Rama Road Corridor Package that requests a MZO.

Next, this recommendation was brought forward to County Council at a Joint Committee of the Whole and Council Meeting on November 24, 2020. From there, Resolution 2020-705 was passed by County Council which resulted in a letter dated December 7, 2020 to MMAH Minister Steve Clark from the County of Simcoe. The body of this letter further outlines that, in fact, a request to enact a MZO was made by Ramara Township AND that County Council supports their request:

Recommendation CCW-132-20

“That the County of Simcoe supports the letter dated November 3, 2020, titled Rama Road Economic Employment District.”

The County of Simcoe is pleased to inform you [Minister Steve Clark] that County Council supports the above proposal within the Rama Road Corridor, in the Township of Ramara, and their request for a Minister’s Zoning Order.”3County of Simcoe. Letter to Minister Clark – Subject: Township of Ramara – Rama Road Economic Employment District: Request for Ministerial Zoning Order (MZO

Only Approval Left Is By Province

Ramara’s MZO request now has two – township and upper tier – of the three approvals it needs to proceed. ​The only approval authority remaining is the province.

Evidently, if Ramara is reconsidering its MZO request for the Rama Road Corridor, then it is clear that the procedural motions that have been put in place need to be rectified.

Officially, regardless of intent, two levels of government have endorsed this MZO request. Saying otherwise is disingenuous to the process both councils have undertaken since November 2, 2020.

Ramara Must Rescind Its MZO Request

Public platitudes about intention do not rectify the official acts of council that have been completed thus far. Therefore, we are requesting that the Township of Ramara rectify this situation officially to align with its comments publicly that a MZO was not applied for. Specifically, the Township of Ramara should reopen the issue before council and pass another motion to send written correspondence to the province directing it to disregard its Rama Road Economic Employment District package and that Council will proceed with these lands through the standard process outlined in the Planning Act, not through a MZO.

Further, since the County of Simcoe is the recognized planning authority in the region, its endorsement of the MZO must also be rescinded. We suggest that a recommendation be made within the Committee of Whole for County Council to notify MMAH that County Council is revoking its support of the Rama Road Corridor MZO letter it sent to Steve Clark dated December 7, 2020. From there, County Council must adopt this recommendation and send formal written correspondence to Minister Clark.

In Conclusion

We hope that the Township of Ramara does not break faith with its public comments in the media and in front of a neighbouring council about not wanting a MZO for these properties. By not officially undoing councils’ actions, this MZO request will still be considered by the province. Further, the developers of this project will still have two levels of endorsement for their projects under a MZO and therefore the province could proceed with the MZO request without further input from either the County or Ramara.

Finally, we must go on record that regardless of the MZO application for the Rama Road Corridor, this project, as it stands, is incompatible with a net benefit for Lake Couchiching, Ontario’s significant wetlands, climate, residents of the Lake Couchiching area or the long-term fiscal health of Ramara Township.

We appreciate your attention to this matter and look forward to council actions that ensure this MZO application does not proceed.

How Can You Get Involved?

  1. Send a message to Council using our form.
  2. Share your concerns on social media.
  3. Sign up for alerts to stay up to date.

Sign Up to Receive Alerts for Ramara Township

Links to Further Reading

Help us fight MZO requests.
Send a message to your council and MPP, and report MZOs in your community.
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Growth Plan Submission

Low density development on greenfields or elsewhere is a net cost to society and should be curtailed accordingly. Strategies should be developed and implemented to account for and to factor into decision making the actual cost of sprawl, reflecting its negative impact on the environment, on the social fabric of our communities and neighbourhoods, on our physical health, and on our political economy.

Cordelia Clarke Julien
Assistant Deputy Minister
Ontario Growth Secretariat (OGS)
Ministry of Municipal Affairs and Housing
777 Bay Street, Suite 2304, 23rd Floor
Toronto, ON M5G 2E5
growthplanning@ontario.ca

Re: Proposed Amendment to the Growth Plan, ERO 013-4504

Dear Ms. Clarke Julien,

First, as members of the Ontario Greenbelt Alliance (OGA), we support their submission on this consultation and have included their recommendations at the end of this document. In addition, we feel there are unique concerns that our constituency has with the proposed changes, which demand a Simcoe-specific response.

With our 35 member groups from both urban, rural and semi-urban communities, we aim to promote community development that is financially, environmentally and socially sustainable, such that provides a net benefit to residents. A major part of this is to recognize the value that natural heritage, agriculture and water gives to our communities, including the numerous benefits and co-benefits of ecosystem services. Ensuring the people of Simcoe County, and Ontario broadly, continue to receive these benefits requires an approach to land use planning that is evidence based, transparent and accountable to the public, and with full consideration of the long-term impacts that communities will either have to deal with or benefit from.

Density and Intensification Targets

Low density development on greenfields or elsewhere is a net cost to society and should be curtailed accordingly. Strategies should be developed and implemented to account for and to factor into decision making the actual cost of sprawl, reflecting its negative impact on the environment, on the social fabric of our communities and neighbourhoods, on our physical health, and on our political economy.

For Simcoe County, including Barrie and Orillia, the proposed density and intensification targets effectively continue the status quo approach to long term growth planning. Simcoe County would be allowed to keep the intensification and density targets that were established under alternative targets given for its 2008 Official Plan. These changes beg the question – what is the vision that the province has for the communities of Simcoe County? Is it a political vision, changing according to the whims of the government of the day, or is it evidence-based planning, utilizing established best-practices done with the best interests of the public in mind?

Currently, low density sprawl dominates Simcoe County. Densities around the county range from the 50 ppl/hectare to well below that in some of the more rural communities. We know that greater densities are needed to support transit and move communities away from car dependency – a development pattern that is costly, inequitable, unhealthy and results in high carbon emissions. The Ministry of Transportation’s own guidelines for building a transit supportive community suggests that to provide basic bus service, a minimum of 50 people per hectare is needed, otherwise the transit service is inefficient and difficult to sustain economically. Even a bus service supported by 50 people per hectare, such as in Barrie, isn’t the kind of transit that is widely available to all residents or allows enough reliability and flexibility to shift transportation patterns away from single vehicle use toward more efficient modes of mass transit.

The proposed “status quo” targets literally cement a development pattern that increases pollution, inequity and municipal debt for the long term. Simcoe County’s population could increase 96% by 2041 from 2011 level. As Hemson Consulting outlined, this could mean that our region could see as many as 900,000 residents by 2041 with Barrie alone growing to 253,000 people. So how we encourage growth in Simcoe County cannot be predicated on how we’ve grown in the past, but rather needs to be based on how we should build communities of the future. We would prefer that the province recognize the growth that Simcoe County will be facing and help support and usher in policies that ensure this growth is not a burden on our future economy.

If the province allows the proposed targets to stand, and allows Simcoe County communities to build mostly as they have for the past few decades, a pattern of growth will proceed that values development of spread out lots with single-detached homes with larger lawns over the preservation of farmland, more expensive road and water infrastructure over ecosystem services, longer commutes and higher fossil fuel emissions over active transportation, increased inequality and poorer health outcomes over a healthy economy. This will negatively impact our economy by reducing our ability to rely on the many benefits provided by clean water, farmland, and green spaces. This effect could be seen clearly over one decade ago as outlined in the Intergovernmental Action Plan (2006):

“Unique growth and development challenges exist in Simcoe County and the Cities of Barrie and Orillia (study area). South Simcoe and Barrie, in particular, are experiencing increased development pressure, and are expected to continue to have rapid growth. A number of the municipalities in the study area rely on inland water systems which have been demonstrated to be under strain (for example the Lake Simcoe watershed has known issues as a result of phosphorous loadings). Without intervening action, the available potable water and aquaculture of these watersheds are threatened.”

This quote has aged well and could easily have been written today instead of over one decade ago. The effects of ill-managed growth continues to wreak havoc on our water systems.

The impacts are also seen in our loss of farmland and greenspace. According to Statistics Canada, Barrie’s footprint grew 550% over the past 40 years mostly gobbling up farmland and semi natural space for a total loss of roughly 150 km2. Neptis Foundation determined that from 2006-2012, Simcoe County zoned 13,000 hectares of green space (mostly farmland) to designated greenfield areas – the most in the Greater Golden Horseshoe. This despite the fact that they were experiencing a fraction of growth compared to York, Waterloo and Peel and with an existing oversupply of land for development. Under the current proposals to the Growth Plan, this pattern of low density development will continue. Unbelievably, it is proposed to continue while we know that the province loses hundreds of acres of farmland per day to development; while Lake Simcoe struggles to assimilate urbanization to the detriment of its ecology and dependent industries; while we know that the assimilative capacity of the Nottawasaga River has already been maxed and while Simcoe County already sits on an excess amount of land zoned for development and employment.

Where is the balance in this approach? Where are the limits that ensure that communities are growing sustainably? Where are the aspirational policies that support the economies and communities of the future?

Density and Intensification Recommendations

  • Density targets from the 2017 Growth Plan should be upheld without alternative targets for DGAs.
  • Intensification targets should be considered based on current population and future growth potential. For example, Orillia (pop. 31,166) will be held to a higher minimum intensification target than two larger and faster growing communities of Bradford (pop 35, 325) or Innisfil (pop. 33,079). Why?
  • Communities that are rural and with low growth projections should also be encouraged to infill their development to provide a range of housing and to best utilize minimal tax revenues. Intensification should not be seen simply as a panacea for city centres. It is important to smaller communities too.
  • Remove the opportunity for lower alternative targets. Allow municipalities to exceed targets if they so choose.
  • Unless the province wants to ensure car dependency in most of Simcoe County’s larger city centres for the near term, there must be more support and information about the benefits of intensification and density. At the current rate, very few communities in Simcoe County will have the density to feasibly support transit. Provincial planners should be working with communities, both urban and rural, to help them communicate and calculate the benefits of intensification vs. sprawl. This would go a long way to change our damaging development patterns.

Rounding Out and Settlement Area Expansions

Allowing “rounding out” of rural settlement areas and allowing for settlement boundary expansions up to 40 hectares outside of an MCR – even if a municipality has an excess of lands – does not promote efficient use of land, nor does it prioritize intensification, which is a more efficient and equitable way to grow.

We would like to know the policy rationale for these suggestions. What is the cumulative impact on our communities, many of which are already financially unsustainable, in almost inescapable infrastructure deficit, low growing or experiencing population loss? How is loosening the proper growth management policies and resulting investments in new infrastructure going to help already struggling communities?

“Rounding Out” Recommendations

  • Rounding out should only be considered if infill development within the built boundary and does not require new infrastructure;
  • Rounding out should provide a full life cycle cost accounting to ensure that the expansion is financially feasible for the community;
  • Rounding out should not exceed the population allocations for the municipality for 2041 forecasts.

Settlement Area Boundary Expansions

Settlement Area Boundary expansions should not be undertaken lightly. As the footprint of the community grows, the density lowers. As we’ve mentioned earlier, this means that servicing the community becomes more expensive, including transit and infrastructure maintenance and repairs. Moving away from evidence-based planning is not necessary and hurts the long term success of communities.

Settlement Area Boundary Expansion Recommendations

  • Expansions should only be considered within an MCR process;
  • Expansions should not be considered if there is an excess of lands. The municipality should de-designate the excess lands before asking for an expansion;
  • The addition of 40 ha to a settlement boundary is reckless and should not be a considered policy. It does not promote evidence based planning. The target seems arbitrary and we question the problem this policy is trying to solve;
  • Rural settlement areas should not be considered for settlement boundary expansions as they should not be receiving significant (if any) growth. This includes hamlets and villages in the Greenbelt.

Lorem ipsum dolor sit amet, consectetur adipiscing elit. Ut elit tellus, luctus nec ullamcorper mattis, pulvinar dapibus leo.aWe recognize that there is more than metrics and numbers when building strong communities that meet the needs of citizens. Our goal is not to be anti-development, rather we seek to encourage community development that meets the needs of the community. This should be the primary objective of all levels of government when they look at planning and development.

Other Ideas to Increase Housing Supply and to Create Stronger Communities

Remove parking minimums for developments. Parking minimums should also not be a mandatory component for infrastructure projects such as hospitals or schools. Parking minimums force more space to be used than necessary and add to the cost of housing.They also severely limit the ability of businesses to expand, and for new business to emerge in urban downtown areas. For infrastructure projects, it requires a large footprint that is generally not found within city centres thereby forcing new hospitals or schools to move to the fringes of a community. This only encourages sprawl and moves services away from people who need it.
Consider hard urban boundaries for all towns and cities within the Greater Golden Horseshoe. Use existing municipal mapping to determine the boundary.

Expand the Greenbelt over areas of hydrological and ecological significance. This would ensure that those areas are protected while putting boundaries delineating where growth can and cannot go. This helps achieve balance between the places we can use to grow and the places we need for our current and future health and prosperity.

Increase data gathering to understand the effectiveness of the Growth Plan. This will allow for implementation and future policy development that is data and evidence driven, ensuring costly mistakes aren’t made and taxpayers realize maximal return. Include data to determine vacancy rates of existing housing, demographics to best prepare for the boomer generation’s exit from the housing market and available land supply that is approved and serviced.

Consider policies that encourage rental development, co-ops and “missing middle” housing. This could be providing DC deferrals so purpose built housing is incentivized.

Link new infrastructure funding to where job growth is projected and give priority to those projects that will support transit, prioritizing infrastructure for active transportation to realize the many co-benefits it provides.

Research the link between different types of development patterns with climate impacts. Consider including carbon emission calculations in development proposals so that the full impact of a development pattern on a community’s long term health can be properly understood.

Stop building new highways on greenfield within the GGH and reconsider highway expansions. Redirect funds earmarked for inefficient car infrastructure toward transit, active transit, and more efficient commercial transportation infrastructure projects that help keep people and goods moving. New highways or wider highways have been shown to only induce demand, and eventually gridlock returns to previous levels. Reducing car traffic to ensure goods can be quickly moved on our existing highway network is a more prudent approach, particularly in light of the fact that transportation accounts for the largest share of Ontario’s greenhouse gas emissions, and the necessity of reducing these emissions in the most cost effective manner. Shifting from built infrastructure that prioritizes the use of cars and trucks toward communities that prioritize people and the ecosystems we rely on for our health, well being, and economic prosperity, which is in no way conflicting with economic sustainability, is the only way to create a future for Ontario that we can all equally rely on.

We thank you for your time and consideration of this submission. Please feel free to contact us if you have any questions or comments. Please find attached below, the recommendations by the Ontario Greenbelt Alliance which we fully support.


Sincerely,

Margaret Prophet
On behalf of the Simcoe County Greenbelt Coalition

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