October 31, 2016
Hon. Kathleen Wynne, MPP Premier of Ontario
Hon. Bill Mauro, MPP Minister of Municipal Affairs
Hon. Kathryn McGarry, MPP
Minister of Natural Resources and Forestry
RE: Co-ordinated Land Use Planning Review (CLUPR)
Dear Premier and Ministers,
The Federation of North Toronto Residents Associations (FoNTRA) provides its comments on the proposed changes to the four provincial Land Use Plans:
- The Growth Plan for the Greater Golden Horseshoe,
- The Greenbelt Plan,
- The Oak Ridges Moraine Conservation Plan, and
- The Niagara Escarpment Plan.
The proposed changes follow a provincial review aimed at improving the laws passed to permanently protect agricultural and natural lands, and promote smart development in the Greater Golden Horseshoe. They are intended to allow communities to continue to grow while minimizing impacts of urban growth on productive farmland, heritage buildings and landscapes, archeological resources, green spaces, and important natural areas.
The more than 40 proposed changes (which are listed in the Appendix to this letter) span the following themes:
- Building Complete Communities
- Supporting Agriculture
- Protecting Natural Heritage and Water
- Growing the Greenbelt
- Addressing Climate Change
- Integrating Infrastructure
- Improving Plan Implementation, and
- Measuring Performance, Promoting Awareness and Increasing Engagement
We have examined the proposed changes and in principle we support them. However, we have some comments and concerns particularly with respect to the Growth Plan and the Greenbelt Plan:
A. The Growth Plan and Toronto
The Growth Plan and the proposed changes are focussed on the growth of communities and their impact on farmland. This is appropriate in the “905” but we question whether and to what degree the Growth Plan addresses Toronto’s issues, which involved already developed lands, not farmland?
In the City of Toronto, which we understand is exceeding its Growth Plan population and density targets, the municipality has been unable to control the density and spatial expression of intensification, and is allowing major growth in previously stable communities without adequate comprehensive planning for physical infrastructure (transportation, utilities) and social services. A recent article in the Toronto Star (Yonge corridor can’t handle more development1) identified this problem, and the failure of City Planning to address it. (No doubt the prevalent fear of the OMB among planners and politicians is at least partly to blame). The over-development in the Yonge Eglinton area is identified in the Midtown in Focus Study, and is now being experienced in conjunction with the Eglinton LRT. New development applications approved along Eglinton Avenue are far exceeding the planned levels of intensification approved by City Council in 2014 (see Eglinton Connects Study and Plan).
Based on Toronto’s experience we would caution against overly zealous implementation of growth targets. Growth needs to be monitored, moderated, and managed according to municipal secondary plans, to achieve provincial targets, but in a way that allows for balanced growth that complies with Official Plan policies such as maintaining neighbourhood character. And growth needs to be in harmony with required expansion of physical (water, sewage, hydro, etc) and social and educational services. And a fair ways of paying for this services expansion, that does not penalize existing residents, needs to be found.
We suggest that it is high time that the Province turned its attention to assisting municipalities with this process.
B. Integration with Regional Transportation Planning
A frequently cited planning principle is that regional transportation planning needs to be integrated with regional land use planning. The success or failure of the Greenbelt in protecting needed green space without at the same time leading to overdevelopment within the central portion of the GTA is crucially dependent on developing growth centres such as Barrie, beyond the Greenbelt, that are linked to the central city by high-quality fast transit. (Note that this also ties in with concerns about housing prices in the GTA. The more transit- served development opportunities created beyond the Greenbelt, the more competition will dampen price growth in Toronto and adjacent areas).
The Province, through Metrolinx, is making major investments in transit to develop frequent and regular (“all day”) service on GO corridors. However this shift to transit will be undermined by MTO and GTA municipalities who are still planning car-dependent growth which will encourage sprawl and pressure on the greenbelt.
In December 2015, the Ministry of Transportation (MTO) suspended work on the environmental assessment of the Greater Toronto Area West Highway Corridor (GTA West), in order to review the work undertaken to date and to ensure the project still aligned with changes in government policy and emerging technologies. GTA West has attracted objections for its anticipated environmental impacts, including concerns about its footprint on designated farmland in the Greenbelt and allegations that it will encourage urban sprawl and induce road traffic. It appears that the Panel appointed by MTO in the spring of 2016 has not yet reported.
We recommend that the province develop additional growth centres and reserve land for transit corridors that can serve them.
C. Concerns identified by the Ontario Greenbelt Alliance
Environmental groups have expressed concerns about the ability of the recommendations to prevent urban sprawl incursions into the protected Greenbelt. According to the Ontario Greenbelt Alliance (OGA), the Greenbelt is threatened by requests to remove protected land from the Greenbelt that have come forward through the provincial government’s review of the Growth Plan and the Greenbelt Plan.
The OGA recently released a map (below) showing the location of over 200 out of more than 650 requests by developers and municipalities to remove protected land from Ontario’s Greenbelt, which currently has about 1.8M acres of protected farmland and green spaces surrounding the Greater Golden Horseshoe. The portion mapped is almost 11,000 hectares (27,000 acres). The map also shows existing towns and villages in the Greenbelt that could be ringed with more sprawl subdivisions if developers get their way.
The OGA have urged the province to make sure the new Greenbelt and Growth Plans stop urban sprawl from getting into the Greenbelt:
- Not allow any land swaps or land removals from within the Greenbelt. We support the OGA in opposing the removal of land from the Greenbelt. There is already a huge amount of land already allocated for future growth. In the GTHA alone, there is more land already approved for development than the size of Mississauga and Oakville combined. However we feel that there may be site specific situations where changes are required as identified in the CLUP:
- Resist efforts to water down municipal density targets in the Growth Plan that are designed to promote smart growth that prepares us for climate change. We support this recommendation, but from the perspective of our previously stated concerns about “unbalanced growth” (see Growth Plan and Toronto comments above).
- Do not proceed with draft changes to the Greenbelt Plan and the Growth Plan that allow towns and villages within the Greenbelt to expand their urban boundaries to allow more development. We support this recommendation for careful consideration by the province.
We appreciate the opportunity to review and comment on the proposed changes.
129 Hanna Road
Toronto, Ontario M4G 3N6
57 Duggan Road
Toronto, ON M4V 1Y1
C.c: Mayor John Tory and Councillors
Jennifer Keesmaat, Chief Planner and Executive Director, City Planning Division
Ontario Greenbelt Alliance
Confederation of Resident and Ratepayers Assns
Federation of Urban Neighbourhoods (Ontario
Proposed Provincial Changes that Affect the Greenbelt (summary) – Toronto Environmental Alliance