Response to proposed Provincial Policy Statement

Hon. Steve Clark
Minister of Municipal Affairs and Housing
Provincial Land Use Plans Branch
777 Bay Street, 13th Floor
Toronto Ontario M7A 2J3

ERO Nr. 019-6813: Review of Proposed Policies adapted from A Place to Grow and Provincial Policy Statement to form a new Provincial Planning Policy Instrument

Dear Minister:

ABC Residents Association (“ABCRA”) is an incorporated volunteer body that has been in existence since 1957. ABCRA represents the interests of residents who live in the area between Yonge Street and Avenue Road and Bloor Street to the CPR tracks.

ABCRA appreciates the opportunity to bring to your attention its concerns regarding the proposed Provincial Planning Statement (“PPS”) within the “streamlined” planning system and wants to indicate our support for the Overall Conclusions raised by The Federation of North Toronto Residents’ Associations (“FoNTRA”) letter dated May 25, 2023.

  1. The Ministry does not have effective procedures and systems in place to ensure that land use planning in the Greater Golden Horseshoe is consistent with good land-use planning practices, and opportunities remain for land-use planning to be better integrated with planning processes for infrastructure and services, such as highways, transit, schools, and hospitals, according to the Auditor General of Ontario.
  2. The assertion that the housing affordability crisis is the product of Ontario’s land use planning and environmental protection framework, and municipalities slow to approve planning applications is objectively false, according to the Association of Municipalities Ontario (AMO).
  3. Data does not support the popular narrative that a lack of supply is the cause of the affordability crisis, and the solution is to build more houses, according to Professor Fallis of York University.
  4. The housing supply inventory contains currently – in year 2 of the province’s 10 – year horizon – 1,276,960 units in 21 municipalities that represent 70% of the province’s population, according to the Regional Planning Commissioners of Ontario (RPCO).
  5. No valid statistical analysis supporting the call for 1.5 million new housing units by 2031 has been made public, according to Professor Doucet of the University of Waterloo.
  6. Recent changes to the statutory planning framework limit meaningful public engagement, impede protections for the environment, and negatively impact coordination of infrastructure and growth planning across regions, according to the Ontario Professional Planners Institute.
  7. The new PPS eliminates density targets and removes restrictions on the expansion of municipal settlement boundaries, effectively, encouraging low – density sprawl on natural and agricultural land with car – reliant subdivisions – all moves directly counterproductive to intelligent climate change adaptation.
  8. The exclusive focus on housing supply anywhere overlooks the basic requirement of the Planning Act that the Minister, in exercising his or her authority, shall have regard to all 20 provincial interests listed in the legislation, not just “the adequate provision of a full range of housing, including affordable housing.”

The direction for regional planning implied in the draft Provincial Planning Statement represents a seminal change in the land use planning system in the GGH that together with recent and potential future governance changes pose risks to the widely recognized benefits of coordinated and integrated land use, resource and infrastructure planning and calls into question progress toward widely understood and desirable outcomes around climate adaptation, inclusion, economic and financial stability over the next decades.

ABCRA respectfully, urges the government to withdraw the proposed Provincial Planning Statement and to maintain the Growth Plan for the Greater Golden Horseshoe.

Yours truly,

The ABC Residents Association,
Ian Carmichael and John Caliendo,

CC. Councillor Dianne Saxe

Photo: randreu, CC BY 3.0, via Wikimedia Commons

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