Ms. Cordelia Clarke Julien
Assistant Deputy Minister Ontario Growth Secretariat
Ministry of Municipal Affairs and Housing
777 Bay Street,
23rd Floor, Suite 2304
Toronto, Ontario M7A 2J3
Proposed Amendment 1 to the Growth Plan for the Greater Golden Horseshoe 2019
Dear Ms. Clarke Julien:
The Federation of North Toronto Residents’ Associations (“FoNTRA’) is an umbrella organization representing over 30 residents’ associations in central Toronto engaged in public policy debates on planning and development issues that directly affect our member organizations.
On 29 January 2019, FoNTRA submitted the attached brief commenting on the Proposed Amendment 1 to the Growth Plan for the Greater Golden Horseshoe 2017. Four members of FoNTRA’s Steering Committee also attended your Ministry’s Toronto Regional Round- table on Proposed Changes to Growth Plan on 13 February 2019, which you chaired. Un- fortunately, when the new Growth Plan for the Greater Golden Horseshoe 2019 came into effect on 16 May 2019, FoNTRA noted that few, if any, of its proposals had found their way into the new policy framework.
In FoNTRA’s view, the current Proposed Amendment 1 to the Growth Plan for the Greater Golden Horseshoe 2019 not only fails to address any of the significant deficiencies identified earlier, it adds additional layers of undesirable and counter-productive policies to guide sustainable development, including the following ones:
- the 2051 population and employment projections, according to the proposed language, are seen not as targets but as minimums – thereby leading to a vast over-supply of lands designated for further sprawl decades later and removed from agriculture;
- upper-tier and single-tier municipalities will be required to update their Official Plans by 01 July 2022 to accommodate the 2051 population and employment projections and any ongoing Municipal Comprehensive Reviews to demonstrate conformity will have to revise their projections to reflect the new minimums;
- comparing the government’s 2041 Growth Plan projections with figures based on the 2016 census from the Ministry of Finance shows that while the city of Toronto and the Region of Peel have exceeded the population and employment projections of the Growth Plan, those of other areas are well below – resulting in lands being designated for development that will never happen;
- conversions of employment areas to non-employment uses within a Provincially Significant Employment Zone would be newly permitted outside of a Municipal Comprehensive Review as long as the land is located within a Major Transit Station; and,
- amendments to the aggregate policies would eliminate the current prohibition on new mineral aggregate operations from habitats of endangered species and threatened species within the Plan’s Natural Heritage System.
FoNTRA is available to discuss these issues in more detail and looks forward to the government’s response.
Federation of North Toronto Residents’ Associations
CC: Gregg Lintern, Chief Planner and Executive Director, City Planning Division
Melanie Melnyk, Project Manager, Strategic Initiatives, Policy & Analysis
Philip Parker, Project Manager, Strategic Initiatives, Policy & Analysis
cc: Hon. Doug Ford, Premier of Ontario
Hon. Steve Clark, Minister of Municipal Affairs and Housing
Ms. Andrea Horwath, Leader of the Opposition
Hon. Steven Del Duca, Leader, Liberal Party
Mayor John Tory and Toronto City Council
Mr. Gregg Lintern, Chief Planner and Executive Director, City of Toronto
FoNTRA Members and Others
attachment: Proposed Amendment 1 to the Growth Plan for the Greater Golden Horseshoe 2017 – letter of Jan. 29, 2019