Regional PlanningUrban Development

Catching up with Growth Plan Changes

By January 22, 2019 No Comments

Changes to Ontario’s planning and land use policies are occurring at a dizzying pace. In a brief span of time we’ve seen sweeping changes to regulations and governance via Bill 66, the plan to upload Toronto’s subways, the announcement of a regional governance review, the potential privatization of Ontario Place, and more. It’s a challenge to keep up, let alone take time to understand the details and implications of each change.

Of all policies undergoing changes, I am most familiar with the Growth Plan, so let’s start there.

Mixed Signals on Transit Densities

For far too long, we have built subways to low-density communities, not to satisfy ridership demand but to curry future votes. This type of misguided investment has happened under all political parties, resulting in the Sheppard Subway, the York Extension and today, the Scarborough Subway.

So, it’s positive to see the Ontario government nodding to higher densities for development at transit station areas. The proposed revisions to the Growth Plan expand the density radius around transit station areas from 500 to 800 metres, increasing the opportunity to add more multi-unit housing and employment close to transit, getting more people on transit and out of their cars.

But curiously, the revisions will also make it easier for municipalities to argue for lower transit station area densities, and have weaker targets approved without a municipal comprehensive review. Specifically, section allows the Minister of Municipal Affairs to set alternative (i.e. lower) density targets for transit station areas. Where applied, this revision would make it easier to build or not intensify car-oriented stations surrounded by parking lots in low-density areas (think of the new HWY 404 stop on the York subway extension, or most commuter GO Transit stations in the outer parts of the GTA).

Weaker Intensification Targets Overall

The greatest problem I see is the weakening of targets for intensification. The revised Growth Plan directs less new growth to occur within our already urbanized footprint and instead allows more growth to proceed in fresh greenfields. Policy reduces the intensification rate for Cities of Barrie, Brantford, Guelph, Orillia and Peterborough and the Regions of Durham, Halton and Niagara from 60% to 50%. Even larger reductions are permissible for the City of Kawartha Lakes and the Counties of Brant, Dufferin, Haldimand, Northumberland, Peterborough, Simcoe and Wellington.

The Province’s proposed new density targets for greenfields are also weaker than in the current 2017 Growth Plan, particularly for municipalities where sprawl currently predominates. Allowances to expand greenfield boundaries will push car-dependent sprawl further outward, when we should be reining it in. Previously a target of 80 residents and jobs per hectare applied to all new greenfield developments. Under the proposed changes, this target is reduced to:

  • 60 residents and jobs per hectare for the City of Hamilton and the Regions of Peel, Waterloo and York
  • 50 residents and jobs per hectare for the Cities of Barrie, Brantford, Guelph, Orillia and Peterborough and the Regions of Durham, Halton and Niagara
  • 40 residents and jobs per hectare for the City of Kawartha Lakes and the Counties of Brant, Dufferin, Haldimand, Northumberland, Peterborough, Simcoe and Wellington

More sprawl could also negate any gains in regional mode shift generated by the increase in the footprint for transit station areas.

Part of a Bigger Development Push

If the Growth Plan changes don’t effectively unfetter development, the Open for Business Bill (Bill 66) provides another avenue for developers to access lands tied up in regulation, for example by waiving clean water regulations or Greenbelt protections in the purported interest of job creation or economic benefits.

In the region, there are vast “Whitebelt” lands that sit outside municipal settlement boundaries. They are not protected in the Greenbelt, and they are excluded from the extensive greenfield lands across municipalities that the Growth Plan deems developable. The Whitebelt in effect preserves lands for future uses, so that they’re not all gobbled up at once.

However, developers own land or options to buy land within a given amount of time in the Whitebelt. Some developers also own or have options on lands that became locked up when the Greenbelt was protected. The new Growth Plan changes make it easier for municipal boundaries to be expanded into the Whitebelt, while Bill 66 allows municipalities new powers to bypass protection acts, including sections of the Clean Water Act, Great Lakes Protection Act, the Greenbelt and Lake Simcoe Protection Acts. Both legislative reforms could serve to access stranded land assets. (See #2 in

Reversing Sprawl – Building the Missing Middle

Unlocking protected or undesignated land for development would make sense if we actually needed that land to build homes. In recent years, clear evidence has concluded that we are not running out of land to build homes, nor are we bumping up against the Greenbelt. In fact, we are sprawling more slowly due to demand to live closer to urban centres near transit and employment, which itself is increasingly located in Downtown Toronto.

The solution isn’t more sprawl but more compact multi-unit family-friendly housing within our urban boundaries (including Missing Middle and medium-density housing). More sprawl further afield would only require longer commutes, generating more congestion and racking up costs of servicing new subdivision with municipal infrastructure. The need for Missing Middle housing has been supported by all sides of the political spectrum.

One solution would be to swap stranded land assets for density bonuses in downtown areas. Incentives to build Missing Middle housing in location-efficient neighbourhoods could also work. Why not innovate, instead of offering up more land further and further away from where residents wish to live and where employment growth is occurring?

Future-Proofing Our Region

Rather than hurry to dispose of lands protected in the Greenbelt or “maintained” in the Whitebelt, we should preserve these resources and future-proof our region. These lands may be critically needed by future generations for housing, for farming or for uses we cannot yet predict.

With climate change a pressing reality, we need to protect our drinking water headlands and local agricultural lands from being paved over. Climate change is shrinking our aquifers and impacting food production around the world (and our agricultural imports). We need policies to protect, not weaken, our own agriculture and food security to feed our region.

Let’s not forget that the original intent of the Growth Plan was “to plan for growth and development in a way that supports economic prosperity, protects the environment, and helps communities achieve a high quality of life.”  The current amendments to the Growth Plan are intended “to address potential barriers to growth, namely increasing the supply of housing, creating jobs and attracting investments.” Forgetting the environmental sustainability part of our planning policy will come at our economic peril.

Our New Policy Landscape

In the last review and update to the 2006 Growth Plan, the Province led a two-year process that involved an advisory panel chaired by David Crombie. The revisions were then based on public and expert consultation. Like or dislike the result, it was based on democratic input. Over two decades ago, the Mike Harris conservatives undertook an equally lengthy process of consultation and panels to develop their Lands for Life land use strategy deemed “the most ambitious public involvement initiative ever launched by MNR” and later the Oak Ridges Moraine Protection Act, a precursor to the Greenbelt Protection Act

Today, we are moving too fast, unravelling past work that was developed with careful democratic input—which has played a strong role in policy development in Ontario and in Canada. It used to be that public and stakeholder consultations took time; they were thoughtful and they informed the policy itself. My biggest concern is that we are asked to respond briskly to a series of proposed reforms created with the input of a few interest groups, when we need to consider the long-term challenges facing our province.