Bill 97 & PPS changes: A Recipe for more Sprawl

More significant changes have been announced to Ontario’s Planning Policy: Bill 97: The Helping Homebuyers, Protecting Tenants Act 2023, a new proposed PPS (Provincial Policy Statement) and the revoking of the Greater Golden Horseshoe Growth Plan. The initial announcement was made on Thursday April 6, 2023 (immediately before the long weekend…again) but changes just keep coming…

The headlines are very concerning and opposition to these changes is growing

Sprawl for all? What Doug Ford's proposed changes to planning rules might mean for future growth

There is a general consensus that these proposals for the changes to the planning and growth rules for southern and rural Ontario are significant and have the potential to do a lot of damage.

It is worth noting that the section(s) of the PPS related to Natural Heritage were not included in the proposals released April 6. Despite the lack of this critical piece of the policy, the Ford government has indicated they plan to implement the changes in the Fall of 2023. Recently the Ontario Auditor General Bonnie Lysyk released a scathing report that pointed out the worsening degradation of wetlands in southern Ontario is among the immediate threats facing Ontario’s environment. The Ministry of Natural Resources told the auditor’s general office that it cancelled a 13-year wetland-conservation strategy initiated in 2017 under Premier Wynne that set targets aimed at eventually ending the net loss of wetlands in southern Ontario by 2025, and achieving a net gain by 2030. The Auditor General indicated the ministry no longer has a way to measure the “quality and function of remaining wetlands”.

Planning experts, including the Housing Affordability Task Force appointed by the Ford government have continued to point out that finding more land is not the solution to build enough affordable and attainable homes to meet Ontario’s needs for at least the next 30 years. Nevertheless Doug Fords’ government proposals continue to involve opening up land for residential development. This approach will contribute to even greater losses of protected land, wetlands, forests and natural heritage, as well as farmland.

In a significant and unprecedented move, on May 18, 2023 a large group of Ontario farm organizations issued a joint statement expressing strong concerns about these proposed changes and requesting the Ford government to put the changes on pause. That same day the Alliance for a Liveable Ontario issued a report indicating the proposed changes will worsen the province’s housing crisis.

With weakened environmental oversight, there is no doubt the result of these changes will be even more expensive unsustainable sprawl locked into Ontario’s future – primarily at the expense of our precious agricultural land, wetlands, forests and wildlife habitats.

Some of these changes include:

Making it easier to convert farmland to employment or residential zoning, and to convert employment land to residential
Allowing up to 2 additional residences (in addition to the primary residence) to be added to every farm without a severance
Allowing up to 3 lot severances per farm with no minimum size established for a farm property
Allowing municipal boundary expansions without Municipal Comprehensive Reviews (MCRs)
Further weakening (possibly eliminating) the protections for most wetlands and forests.
Revoking the Greater Golden Horseshoe Growth Plan – removal of the plan, which included population and employment density targets established to help curb sprawl, will be a major setback, if not a death blow to Smart Growth in southern Ontario.

One of the most disturbing changes is the proposal allowing prime farmland to be able to have three land severances and then also an additional two homes (ARUs) on every farm. Given that we are already losing 319 acres of farmland in Ontario every day, chopping up our intact farms into many smaller parcels for housing will dramatically worsen this loss. These changes have the potential to result in the fragmentation and permanent loss of tens of thousands, possibly hundreds of thousands of acres of Ontario farmland.

Map of Middlesex County, ON. Each red mark indicates a potential new severance location made possible by proposed PPS changes. Note: The area that has no red marks southwest of the centre of the map is the City of London.

Image Source: Ontario Farmland Trust webinar presentation slide (See below).

The proposed changes have rural municipalities already seeing a land rush of inquiries. Based on what we can see in the map of Middlesex County it is clear that devastating long-term consequences to farmland are possible throughout the rural areas of the Grand River Watershed – in the County of Brant, Wellington County, the Region of Waterloo, Norfolk County and the rest of rural Ontario. On top of the loss of farmland, there will be dramatic increases to the price of farmland for new farmers and the fragmentation will make it far more difficult for the next generations to farm on the agricultural lands that still exist.

Remember: We rely primarily on ground water in our communities. We rely on agriculture for local food and for our economy. We need greenspace. Wildlife needs habitat. These changes put all of this at risk! And these changes will result in expensive sprawl – our municipal taxes will go up too!

What can we do?

We Need Submissions to the ERO (Environmental Registry of Ontario) – We need to speak up very loudly and protest these proposed changes to planning, our communities, and precious farmland. We have provided resources below to learn more, and to reference in your comments.

Important: You don’t need to be an expert and you don’t need to submit a lengthy submission in order to comment – even just a few words of concern is enough to send a message to indicate you are not supportive of these provincial changes and policies.

Comment on Bill 97 by May 6, 2023: https://ero.ontario.ca/notice/019-6821 – Now Closed
Comment on the Provincial Policy Statement until June 5, 2023: https://ero.ontario.ca/notice/019-6813

2. Write a letter to your MPP and elected representatives – some helpful tips and several terrific letters written by advocacy groups that make it easy for you.

Ontario Farmland Trust (Highly Recommended toolkit with tips & easy-to-use template to send your message)
Ontario Nature
Environmental Defence
Tips for contacting your MPP from Yours to Protect

3. Write a Letter to the Editor or Op-Ed for your local media.

4. Tell your family, friends, neighbours and colleagues! Let them know what is being proposed and encourage them to submit comments. Post information and links in your social media and share with your network. Don’t forget to share a link to this page and encourage others to join our mailing list.

5. Participate in Rallies and Events!

Resources:

A must watch webinar for everyone in Ontario from Ontario Farmland Trust featuring Dr. Wayne Caldwell, Professor in Rural Planning and Development at the University of Guelph, and Dr. Pam Duesling, General Manager of Development Services in the County of Brant. Hosted by Margaret Walton, Ontario Farmland Trust Board Member and a Senior Associate in the planning firm, Planscape.

Joint Statement by Ontario Farm organizations on Bill 97 and proposed changes to the Provincial Policy Statement

Province poised to deliver fatal blow to agriculture and the environment while worsening the housing crisis Report by the Alliance for a Liveable Ontario

Presentation by Planning Expert Victor Doyle, Lead Planner for the Ontario Greenbelt to PALS (Preservation of Agricultural Lands Society, based in Niagara on the Lake) Annual General Meeting April 27, 2023

Sprawling Chaos: Ontario’s Latest Attacks on Prudent Planning – Environmental Defence Webinar (recorded April 26, 2023)

We know that Bill 23, the Greenbelt grab & a hidden 4 1/2 year campaign for sprawl were huge setbacks. Now, Ontario wants to scrap the Growth Plan altogether! This webinar features Environmental Defence’s Ontario Environment Program Manager, Phil Pothen, and More Neighbours Hamilton spokesperson, Michelle Tom. Learn what to do and say to save smart growth in Ontario.

Review of Existing Housing Unit Capacity Identified in Municipal Land Needs Assessments Prepared for Upper- and Single-Tier Municipalities in the Greater Golden Horseshoe – Report by Planning Expert Kevin Eby

Report of the Ontario Housing Affordability Task Force – Task Force appointed by Ford government. From Page 10 “The Greater Toronto Area is bordered on one side by Lake Ontario and on the other by the protected Greenbelt. Similarly, the Ottawa River and another Greenbelt constrain land supply in Ottawa, the province’s second-largest city. But a shortage of land isn’t the cause of the problem. Land is available, both inside the existing built-up areas and on undeveloped land outside greenbelts. We need to make better use of land.” and “Most of the solution must come from densification. Greenbelts and other environmentally sensitive areas must be protected, and farms provide food and food security. Relying too heavily on undeveloped land would whittle away too much of the already small share of land devoted to agriculture.“