Bringing the environment to the fore in land use planning

August 3, 2017

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By Anna Iannucci

This latest in our series of blog posts on the changes to the provincial land use framework in Ontario addresses natural heritage and agriculture, and therefore touches on the entire family of Greater Golden Horseshoe (GGH) land use plans – the Growth Plan, the Greenbelt Plan, the Niagara Escarpment Plan (NEP) and the Oak Ridges Moraine Conservation Plan (ORMCP). Collectively, these plans tell us “places to grow” and “places not to grow,” the reason for the latter being primarily the protection of natural heritage, water resources and agricultural land.

In the lead up to the Provincial Coordinated Review of the four plans, Urban Strategies undertook reviews of the Greenbelt Plan on behalf of Niagara Region and Durham Region, producing reports which articulated each municipality’s position on the successes, challenges, and areas for improvement of the Greenbelt Plan. The updated plans clearly respond to many of the municipalities’ concerns and suggestions, though as expected there are some areas where the Province has retained existing policy positions. This blog post will outline some of the ways that the plan updates address what we heard from the communities in Niagara and Durham.

The key changes to the plans discussed in this blog post are:

  • Greater coordination between the four plans
  • Expansion of the Natural Heritage System to the entire GGH through its incorporation in the Growth Plan, and associated questions around implementation
  • Greater emphasis on agricultural viability through a broader definition of the Agricultural System and its incorporation in the Growth Plan, along with new tools such as agricultural impact assessments
  • Greater emphasis on water resource planning as the foundation of all growth planning


A truly “coordinated” review

The first observation to make is that the updates to these plans make them function far more as a cohesive family of plans. The Niagara Escarpment Plan (1985) and Oak Ridges Moraine Conservation Plan (2002) both predate the Growth Plan (2006) and Greenbelt Plan (2005), and were basically just enveloped into the boundary of the Greenbelt when the Greenbelt Plan was created. The NEP and ORMCP each have their own land use designations and policies which continue to apply within their boundaries, however there has clearly been a concerted effort to improve consistency in overall messaging and definitions. The newly introduced references to climate change, for example, are consistent across the four plans, and the definitions have been brought into alignment across the plans and with the Provincial Policy Statement, 2014.

There are a number of examples of concepts from one plan that have now been reflected in others. The language of “complete communities” now appears in the Greenbelt Plan and ORMCP as well as the Growth Plan in reference to settlement areas. Similarly, “community hubs,” which were introduced in the updated Growth Plan to encourage the co-location of community infrastructure, are also referenced in the Greenbelt Plan and ORMCP. Most consequentially, the Greenbelt Plan’s Natural Heritage System and Agricultural System concepts have been expanded to the entire GGH through their incorporation into the Growth Plan (more on this below).

In coordinating the four plans, the role of the Growth Plan has been reinforced as the overarching land use framework for the GGH to which the other plans relate. The Greenbelt Plan, in particular, will often simply defer to the Growth Plan where previously an independent policy existed (it should be remembered that at the time of the original Greenbelt Plan the Growth Plan was still only a proposal). One example of this can be seen in the policies for settlement area expansions – in the 2005 Greenbelt Plan, a series of criteria were established for the consideration of settlement area expansions at the 10-year review of the Greenbelt Plan. In the 2017 Greenbelt Plan, settlement area expansions will only be considered as part of a municipal comprehensive review under the Growth Plan, and in accordance with the settlement area expansion policies of the Growth Plan.


Extending the Natural Heritage System beyond the Greenbelt

The most significant change relating to natural heritage is the commitment in the Growth Plan to a Provincially-defined Natural Heritage System outside of the Greenbelt Plan boundaries. Section 4.2.2 of the Growth Plan states that the Province will map a Natural Heritage System for the GGH, excluding areas within settlement area boundaries as of July 1, 2017. Municipalities are required to incorporate the Natural Heritage System as an overlay in their Official Plans, along with appropriate policies. The policies for the Natural Heritage System in the Growth Plan are virtually identical to the policies for the Natural Heritage System in the Greenbelt Plan, essentially incorporating another 1.18 million hectares (or 45% of the Growth Plan area excluding settlement areas)[1] into the Greenbelt, though without actually changing the Greenbelt Plan boundary. Natural Heritage Systems identified in municipal official plans in effect as of July 1, 2017 will continue to be protected until the Provincial Natural Heritage System has been issued. In implementing the Provincial NHS, upper- and single-tier municipalities may, through a municipal comprehensive review (MCR), refine Provincial mapping with greater precision. Municipalities can continue to protect natural features beyond the Provincial NHS in a manner consistent with the PPS.

The desire for a comprehensive approach to natural systems across the GGH was evident in the 2006 Growth Plan as well, but the Province has finally come through and done the work to make it a reality. There are numerous benefits of this top down approach, including introducing consistency in the definition of the NHS across municipal boundaries and bringing all municipalities up to a universal standard. However, there are also a lot of questions about how the GGH-wide NHS is defined and will be implemented.

The Ministry of Natural Resources and Forestry’s paper on the development of the proposed NHS makes it clear that it is intended to be a regional-scale system that does not necessarily capture all locally-important natural features and areas, and the draft mapping at the end of the report bears this out. However, the Province’s criteria in defining the NHS may not be the same as those used by the municipalities, meaning that their definition of regionally-significant features may not match up with what municipalities consider to be regionally-significant. In addition, it is unclear in practical terms what the difference will be between the Provincially-defined NHS and the other natural features that municipalities protect.

There are numerous questions about how this will be resolved. Will municipalities “refine” the Provincial mapping to the point that it matches their own as they incorporate it into their Official Plans? Or will there be a two-tier NHS protection system, with areas defined in the Provincial NHS having the added protection of the Growth Plan behind them, unlike the natural heritage features that are only defined in municipal Official Plans? What will happen to municipally-defined natural heritage systems between when the Provincial NHS is issued and when these implementation issues are resolved and Official Plans are brought into conformity? Changes made to the Planning Act under Bill 139 further complicate matters, in that appeals can only be made on the basis of inconsistency with a Provincial Policy Statement, Provincial Plan or upper-tier Official Plan. Could a municipality have its Official Plan appealed on the basis that the NHS fails to conform with the Provincially-issued NHS? Hopefully these questions can be resolved before the Provincial NHS is officially issued, which is supposed to happen by the end of 2017.


Promoting agricultural viability

One of the strongest messages we heard from the agricultural communities in Niagara and Durham Regions was that the Greenbelt Plan focused exclusively on preserving the agricultural land base without recognizing that there is a lot more to agricultural viability than the availability of land. The updates to the plans clearly attempt to respond to this concern, most notably by defining the Agricultural System as being made up of not only the agricultural land base, but also the agri-food network, a new concept that has been introduced. The agri-food network is defined as “the elements important to the viability of the agri-food sector such as regional infrastructure and transportation networks; on-farm buildings and infrastructure; agricultural services, farm markets, distributors and primary processing; and vibrant, agriculture-supportive communities.” While the policies on the agri-food network are quite thin, primarily consisting of an encouragement to municipalities to implement regional agri-food strategies, a great deal more detail on the agri-food network is provided in the Ontario Ministry of Agriculture, Food and Rural Affairs’ (OMAFRA) supporting materials, discussed further below.

Like the Natural Heritage System, the concept of the Agricultural System has been expanded from the Greenbelt Plan to the Growth Plan, with the Province promising to identify an Agricultural System for the GGH. The policies for the Agricultural System are again similar in the Growth Plan as the Greenbelt Plan, and the same requirements for municipal incorporation of the Provincial mapping and ability to refine Provincial mapping through an MCR are identified.

OMAFRA is currently consulting on draft implementation procedures for the Agricultural System, a draft Agricultural System Portal, and a draft Agricultural Land Base Map. The method for identifying the agricultural land base started with upper- and single-tier municipalities’ designated prime agricultural areas and added additional prime agricultural areas identified through OMAFRA’s Land Evaluation and Area Review (LEAR). It will hopefully be less controversial than the NHS mapping as it is rooted in municipalities’ existing designations, and the implementation procedures provide extremely helpful clarification on what is up for refinement (specialty crop areas are not, for example) and how the process of refinement is expected to take place.

The Agricultural System Portal maps the agri-food network to an astonishingly detailed degree. The implementation procedures envision that it will be an important tool to inform decisions, helping to identify potential impacts on the agri-food network, and that it can also be used for analyzing and planning for the agri-food sector and its economic development. The implementation procedures also include a lot more information about how municipalities can implement regional agri-food strategies as the updated plans direct, and how OMAFRA can support them in doing so.

Further to the goal of agricultural viability, a new tool has been introduced into all four plans to help avoid, minimize, or mitigate impacts on agricultural operations – an agricultural impact assessment (AIA). Though there is no guidance yet on a standardized agricultural impact assessment process, OMAFRA will be consulting on this in the fall of 2017.

An AIA is required to be considered in proposed settlement area expansions and infrastructure corridors. The Growth Plan positions the AIA as a tool to be used to evaluate and prioritize alternative locations for settlement area expansions. AIAs are also to be used when considering applications for non-agricultural uses in agricultural areas, though the requirement for an AIA gets less stringent depending on the “value” of the area. An AIA is required for non-agricultural uses in specialty crop or prime agricultural areas, but only “should be considered” for non-agricultural uses on rural lands, and is not required for applications for mineral aggregate operations on rural lands. This relates to another concern that we heard from communities in Niagara and Durham – there is often a conflict between agriculture and mineral extraction and the Greenbelt Plan, 2005, offered little to settle this conflict. Some direction can be deduced from the policy around AIAs – mineral extraction is discouraged in specialty crop and prime agricultural areas, but may be permitted subject to an AIA that sets out measures to mitigate impacts on the Agricultural System. In rural areas, however, it is expressly stated that an AIA is not required.

Beyond agricultural viability, the response to other concerns that we heard from agricultural communities in Niagara and Durham is mixed. Updated policies attempt to deal with the potential conflict between natural heritage and agriculture where the two collide, addressing a concern we heard that the high level of protection placed on the Natural Heritage System was in some cases inhibiting farmers’ ability to farm. The desire for a case-by-case boundary review appeals process, however, was not addressed.

Altogether, the updates to the agricultural policies of the plans, combined with OMAFRA’s supporting material, provide a very well thought through approach to tackling the issue of agricultural viability. If MNRF were to issue a similar set of implementation procedures for the Natural Heritage System it would go a long way to resolving some of the questions above.


Establishing water resource systems as a foundation for growth planning

Since the original Growth Plan and Greenbelt Plan were released, the Province has done a lot of work on water resource planning in the GGH. We now have the Lake Simcoe Protection Plan, a series of source protection plans prepared under the Clean Water Act, 2006, and the Ontario Great Lakes Strategy. This work has led to a greater understanding of the importance of water resource planning as a foundation of all other growth planning. Like with natural heritage and agriculture, the Water Resource System concept from the Greenbelt Plan has been incorporated into the Growth Plan, which states explicitly that the intent is to provide a consistent framework for water resource protection across the GGH with a similar level of protection as that provided by the Greenbelt Plan.

Municipalities, partnering with conservation authorities where appropriate, are required to identify water resource systems, informed by watershed planning. Decisions on allocation of growth and planning for water, wastewater and stormwater infrastructure will be informed by watershed planning. Settlement area expansions must demonstrate through watershed planning that the expansion would not negatively impact the water resource system. These policies may have far reaching implications on which areas of the GGH are able to grow, based on the capacity and sensitivity of their water resource systems.


Summary of other changes

Other changes relating to the four plans and natural heritage include:

  • Urban River Valleys – 21 urban river valleys and associated coastal wetlands are now included in the Greenbelt under the urban river valleys designation added in 2013. This grows the Greenbelt by approximately 9,000 hectares.
  • Key hydrologic areas – a new term defined as areas which contribute to the hydrologic functions of the Water Resource System, including significant groundwater recharge areas, highly vulnerable aquifers and significant surface water contribution areas. Policies establish criteria for development and site alteration to protect these areas.
  • Key natural heritage features and key hydrologic features – these concepts from the Greenbelt Plan have been expanded to the Growth Plan and Niagara Escarpment Plan.
  • Growing the Greenbelt – a new section articulates the process for Growing the Greenbelt, referencing the criteria developed in 2008.
  • Minor boundary changes – approximately 58 hectares of land were removed from the Greenbelt Plan, primarily based on the existence of prior planning projects, consistency of the Greenbelt boundary with the boundary of the Oak Ridges Moraine Conservation Plan, and making the boundary more logical (eg, aligning it with an existing road).
  • Climate change – as described in the previous blog post in this series, language and policies addressing climate change have been added to all four plans.

Reflections on what this means for planning in the GGH

In practical terms, the changes mean that the municipal conformity exercise which is about to begin will have another facet this time around. Not only will municipalities need to bring their urban policies in line with the new intensification target, major transit station areas, etc, they will also need to implement the Provincially-issued Natural Heritage System and Agricultural System, and, if they have not done so already, undertake watershed planning to identify water resource systems. With regard to day to day planning matters taking place within settlement areas, the updated policies will likely not have a big impact. But whenever planning leaves the settlement area – in considering a new infrastructure corridor, for example, or an expansion to a settlement area through a municipal comprehensive review, or a non-agricultural use on rural lands – there will be new requirements to consider.

The key takeaway from all these changes is that the Province is moving towards a more holistic approach to planning, with environmental considerations as the foundation. It is no longer as simple as one plan telling us where to grow and three plans telling us where not to grow. There is a recognition that planning is planning – there is no clean divide between planning for urban growth and planning for the health and resiliency of the natural environment.

[1] Size according to the Ministry of Natural Resources and Forestry’s paper on the draft Natural Heritage System, currently out for consultation.

There is no doubt this is a complex and complicated suite of policies and legislation.  At Urban Strategies, we are here to help you.  If you need to know more about these Plans and what they mean for you, your land, or community, please contact us:

Melanie Hare, Partner,, 416-340-9004 x 215

Pino Di Mascio, Partner,, 416-340-9004 x 210