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The Neptis Foundation—a Toronto-based charitable organization which conducts and disseminates research about Canada's urban regions—has released their response to proposed amendments of the 2016 Growth Plan for the Greater Golden Horseshoe. Noting that the revisions reflect progressive planning policies that would slow the growth of low-density development, the foundation states that many oversights and loopholes included in the original 2006 Plan still remain in place, threatening to counteract these latest improvements.
While the Greenbelt controls where development cannot occur, the Growth Plan's objective is to redirect growth to more appropriate areas in the Greater Golden Horseshoe. The Greenbelt alone will not stop urban sprawl; Neptis maintains that the Growth Plan, acting in concert with the Greenbelt, is critical to reaching the province's land use and sustainability objectives.
A briefing posted to the Neptis website mentions that some of the proposed amendments reflect the recommendations resulting from the advisory panel for the coordinated provincial land use review, also known as the Crombie Panel. The Plan promotes the redirection of growth to transit-accessible areas by instituting new language such as "strategic growth areas" and "priority transit corridors". The briefing explains that this is a shift from the broader approach in the original document, which promoted intensification in built-up areas, but not specifically in locations well-served by transit. Zoning bylaws in identified "priority transit corridors" will now need to be updated to meet minimum density requirements for the type and frequency of transit service anticipated.
Currently, municipalities must direct 40% of new development to existing built-up areas. Under the proposed revisions, that intensification target would jump to 60%. That will significantly reduce expansion at the urban edge while minimizing the region's greenhouse gas emissions. Density requirements for new developments on greenfield land would also increase from 50 people and jobs per hectare to 80.
Further positive changes include a thorough identification and mapping of the natural heritage and agricultural systems located outside the Greenbelt, with the goal of ensuring greater consistency across municipal official plans. The province also intends to develop a standard approach to "land budgeting", the method municipalities use to manage land to accommodate future growth. Finally, the updated document would include stronger provisions regarding integrated watershed planning.
Though these amendments are a win for responsible and sustainable development, Neptis explains that the first phase of the Plan — which has already allocated over 107,000 hectares of land at lower intensification and density targets than those now proposed — manages growth all the way to 2031. The proposed amendments would only apply to the 2031–2041 planning horizon.
Neptis has also identified a number of worrying loopholes from the original Plan that have not been closed in the revisions. The current Plan allows Outer Ring municipalities, including Simcoe and Brant Counties, to take advantage of lower intensification and density targets due to the technical absence of an Urban Growth Centre. Despite Barrie and Orillia functioning as Urban Growth Centres, they are administratively and politically separate from Simcoe County. This loophole allows Simcoe and Brant to pursue low-density growth seemingly contrary to the Growth Plan's stated objectives.
In addition, Neptis notes that the revisions fail to address key employment zones in the Greater Toronto and Hamilton Area, including the area around Pearson Airport. As a significant source of the region's congestion, Neptis has previously pushed for a "prime employment area" designation on these lands, which the Minister of Municipal Affairs and Housing has the authority to do under the Growth Plan.
Finally, Neptis recognized the rocky implementation of the Plan's first phase, which was plagued by appeals of municipal official plans to the Ontario Municipal Board, some of which are still yet to be settled. The lack of a framework for monitoring and implementation of the Plan was identified as a substantial problem. Municipalities and the province each approved developments that challenged the vision outlined in the Plan, which a monitoring program may have prevented. Though the amendments do include a mechanism allowing the province to request data from municipalities for the purposes of monitoring implementation, questions linger over whether that data will be made public.
A key recommendation from the Crombie Panel calls on the province to push back the deadline for municipalities to conform with Amendment 2 from 2018 to 2021. Amendment 2 is an update of the Growth Plan's population and employment forecasts, also extending the planning horizon to 2041. York Region has already begun designating more land under Amendment 2's longer planning horizons, despite contrary opinions that the current land supply is sufficient beyond 2031. To counter this "rush", Neptis argues that a halt to the designation of more land is needed until we can take stock of "the big picture".
Neptis asserts that the Growth Plan's past issues can be traced to the province's "abdication of its role as regional planner." If the province assumes that important guiding role, embarks on a robust monitoring exercise, and provides support to municipalities when needed, the Greater Golden Horsehoe will become the economically-competitive and environmentally-sustainable region envisioned in the Growth Plan.
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