2019 is off to an eventful — if inauspicious — start in Ontario politics. With new year barely three weeks old, the Doug Ford government has announced a range of cost-cutting and deregulatory reforms that alter the shape of Ontario's social and environmental safety net. In stripping away tuition grants for low-income students, dissolving the oversight provided by regional health agencies, loosening childcare rules, and even reviewing the Endangered Species Act for "efficiencies," the Progressive Conservative government is leaving little on the table. Most everything, it seems, is now "open for business," including land use policy. Last week, the Ford government's vision for urban development continued to coalesce through newly proposed amendments to the 2017 Growth Plan for the Greater Golden Horseshoe.

As the Growth Plan is updated, what does it mean for the future of the Toronto region? Photo by Jack Landau.

Alongside the Ford government's bombshell 2018 announcements to scrap the carbon tax, reverse the sex ed curriculum, halve the size of Toronto's City Council, upload the TTC subway, and compromise the Greenbelt through Bill 66's "open for business" zoning, the new Growth Plan amendments are comparatively subtle. Tabled last week, the Growth Plan changes aim to bring new housing supply to the market — in part through looser density requirements for new greenfield development.

For many of the region's outer municipalities, density targets for new development have been halved. Under the existing Growth Plan (which was first enacted as a complement to Greenbelt legislation in 2005, and tightened in 2017), new development was required to create a minimum of 80 jobs or residents per hectare. For Brant, Dufferin, Haldimand, Northumberland, Simcoe, and Wellington counties, that target has been reduced to 40.

More urbanized parts of the Golden Horseshoe — including Hamilton, Peel region, Waterloo and York — will now have a minimum intensification target of 60 per cent, while developers in communities like Barrie, Guelph, Orillia and Peterborough will be required to provide 50 jobs or residents per hectare. Additionally, some small parcels of land outside of current municipal Growth Plan boundaries (including some farmland) would become open to development, further diluting the previous Liberal governments' gradual push for density.

Rules regulating development in the region's 'Employment Lands' are also subject to revision. Under the new regulations, municipalities will be able to use portions of their Employment Lands to build housing, although other Provincially designated areas will continue to remain protected for employment uses. 

Critics of the revised Growth Plan have been quick to argue that the new regulations stymie the region's ongoing efforts to create more functional and environmentally sensible urban environments. In a recent statement, Tim Gray, Executive Director of Environmental Defence, assessed that the changes are "favouring sprawl" over density. Together with Bill 66, Gray stresses that the new policies spell "an end to provincial rules that support smartly planned, transit friendly communities, and the protection of farmland, natural heritage areas, and clean water."

Victor Doyle, a retired urban planner who helped lead the creation of the Greenbelt, was similarly unsparing in his criticism of the new Growth Plan, which he warned constitutes "a big step back" for the region. As reported by the Globe and Mail's Jeff Gray, Doyle argues that "the new targets, when implemented, will see densities as low as those built in the 1990s, long before the Growth Plan."

According to the government, the updated density targets will help spur more construction, bringing greater housing supply to the market and ultimately easing pressure on home prices. "We believe there are too many barriers standing in the way of creating housing and attracting investment in the region,” said Steve Clark, Minister of Municipal Affairs and Housing in a statement outlining the updated growth plan. More acutely, Clark argues that the tiered density targets acknowledge that "one size does not fit all." 

Still, if the goal is to unlock the region's limited land to provide new housing, allowing low-density development that brings fewer homes to the market seems counterproductive in the long term. At best, the new regulations could spur supply gains in the short term, but at the expense of valuable land lost to suburban sprawl. By contrast, the previous target of 80 jobs or residents per hectare reflected a more urban and transit-oriented ethos.

The benchmark of 80 inhabitants per hectare was designed to ensure a level of density that could support 10-to-15-minute bus service, hopefully alleviating the Golden Horseshoe's inefficient and environmental destructive dependance on the car. No longer. Compared to the 'gentle density' championed under the previous Growth Plan, the sprawl facilitated by newly loosened regulations has similarly negative environmental impacts, both in its up-front carbon costs, and in the automobile-dependant lifestyles that it all but imposes.  

Yet, if the "open for business" ethos means creating an easier path for developers, more sprawl in outlying municipalities is met by more density closer to urban centres. Alongside the changes to greenfield density targets, the updated Growth Plan allows for more density around existing transit centres. New regulations more than double the maximum scope of 'Major Transit Areas' where density is encouraged: the previous radius of 500 metres is expanded to 800 metres (which is identified as roughly equivalent to a 10-minute walk). Bringing density to transit hubs — like TTC subway stops — will hopefully become easier. 

The updated Growth Plan encourages density in transit-rich areas, along with suburban sprawl. Photo by Marcus Mitanis

Facilitating transit-oriented development around existing infrastructure, the new regulations also reverse rules that allowed cities to insulate some transit-rich areas from development while intensifying construction elsewhere to meet overall density goals. Now, cities — including Toronto — will be pushed to spread density more evenly. This could help correct a skewed model of development that pushes extreme spikes of density into small pockets of the city, while much of the Toronto 'yellowbelt' of single-family homes loses population. Finally, the revised Growth Plan also closes a bizarre linguistic loophole that allowed any new development in rural areas — including single-family McMansion sprawl — to be considered 'intensification.'  

So how do we weigh the impacts of greater density within transit centres against the facilitation of outlying sprawl? The equation is further complicated when we consider that the Growth Plan's 80-per-hectare greenfield density targets weren't being met to begin with – and didn't need to be. As TVO's John Michael McGrath explains, the opt-outs facilitated by the previous Growth Plan jeopardized density targets long before any recent changes:

Municipalities were always permitted to apply for “alternative targets” if they didn’t think they could meet the 80-jobs-or-people number, and the government says that’s exactly what they did: not one of the outer-ring municipalities was close to meeting its target through new greenfield development.

Reversing protections for Employment Lands may prove to have similarly limited impacts. The 2017 land use regulations protecting Employment Lands were due for review in 2022, at which point municipalities could choose to build housing on industrial areas. For some municipalities, that change now merely comes three years sooner.

Although municipalities were always able to opt out of greenfield density targets, it doesn't invalidate those targets to begin with. In environmental terms, the weakness of the Liberals' 2017 Growth Plan was not its ambition, but its lack thereof. Retrospectively, was the 2017 push for transit-oriented density and environmental stewardship rooted in creating good optics with the Liberal base? Maybe, but it would have made good policy too.

If the embrace of sprawl merely hastens the collapse of a system designed with opt-outs to begin with, and the new transit centre regulations help create more urban density, are the Growth Plan changes cause for optimism? Probably not.  

Facilitating greater urban density around transit centres is a good thing; transit-oriented density is environmentally and socio-economically preferable to sprawl. But the policy is couched within an ethos of deregulation that fundamentally works against our ability to create an environmentally sustainable — and logistically efficient — urban region. The "open for business" mentality that guides the Doug Ford government's policies is rooted in dangerously short-term thinking.

While suburban sprawl and urban density are diametrically opposed in their geography, they also fall under the same free-market ethos. In both cases, the government is doing away with regulation to allow developers to operate with greater freedom. We should celebrate the promotion of transit-oriented urban density, but it's important to remember that it comes primarily as a by-product of "cutting red tape," rather than a policy goal in its own right. 

This type of deregulation is not inherently good or bad. Regulations can protect the environment and create better communities (think the Greenbelt and Growth Plan), and they can entrench privilege and exclusion (think Toronto's single-family zoning). The trouble is that Ford's "open for business" ethos seems predicated on the notion that regulations are inherently bad. 

While Bill 66 allows municipalities to bypass environmental regulations — including the Greenbelt Act – to attract new employment and industrial development, the updated Growth Plan makes similar concessions to businesses and commercial interests. Sometimes, those concessions can lead to good outcomes. As a blanket political ethos, however, Doug Ford's wave of deregulation cedes the government's responsibility to manage land use and environmental policy.

Couched alongside the Growth Plan's policy changes, new environmental language signals a subtle, but potentially meaningful shift in the government's approach to land use and environmental stewardship. Concrete goals of "low-carbon" communities and "net-zero" building are replaced with the more nebulous benchmark of "environmentally sustainable," while "lower density development" is replaced with "unmanaged growth." 

In the messy prelude to the 2018 Provincial election, Doug Ford mused about abolishing part of the Greenbelt — a move that drew pointed criticism from across the political spectrum. The Premier-to-be quickly walked back such claims, but his government has consistently set about finding ways to achieve similar goals without the same political repercussions. It means bypassing the Greenbelt without really bypassing it, and embracing sprawl while feigning otherwise. The lesson, then, is that the government rules by more than the buck-a-beer force of Fordian edict. Ontario is also changing through a quieter — but no less troubling — shifting of the goalposts. 


The government's proposed Growth Plan changes are open for a 45-day period of review, during which Ontarians can share their thoughts about the new plan. The deadline for feedback is February 28