Getting Real About Climate Change in Planning Policy

July 13, 2017

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By Danny Brown

Over the past two weeks, Urban Strategies has begun to provide an overview of the significant overhaul of the provincial land use and planning framework in Ontario. Two weeks ago, we looked at the changes to transit area planning in the Growth Plan for the Greater Golden Horseshoe and last week we reviewed and raised questions about the proposed changes to the land use planning appeals process, otherwise known as reforms to the Ontario Municipal Board. This week we’ll be looking again at changes to the Growth Plan (and Greenbelt Plan), focusing on the integration of climate change into planning practice in Ontario.

Of course, the Growth Plan, the Greenbelt Plan, and the other associated land use policy plans already addressed – indirectly – climate change. With their emphasis on limiting urban sprawl and encouraging intensification, prioritizing public transit and active transportation while discouraging automobile use, and protecting natural assets like Ontario’s prime farmland and freshwater resources, the provincial land use policy framework oriented planning practice towards building sustainable communities that minimized our collective impact on the environment. However, whereas the old framework addressed climate change implicitly, the new framework – which came into effect on July 1, 2017 – makes explicit the need for planning practice in Ontario to acknowledge, account for, and consider climate change in a comprehensive and direct manner. In fact, the Growth Plan’s updated preamble states that:

The impacts of climate change are already being felt. Communities and infrastructure must be adapted to be more resilient, greenhouse gas emissions across all sectors of the economy need to be reduced, and valuable water resources and natural areas need to be protected.

More concretely, the guiding principles of the Growth Plan have been amended to include the following direction:

Integrate climate change considerations into planning and managing growth such as planning for more resilient communities and infrastructure – that are adaptive to the impacts of a changing climate – and moving towards low-carbon communities, with the long-term goal of net-zero communities, by incorporating approaches to reduce greenhouse gas emissions.

This new emphasis on climate change is recognized not only at regional level of the Greater Golden Horseshoe, but province-wide through an amendment to Section 2 of the Planning Act itself which now includes “the mitigation of greenhouse gas emissions and adaptation to a changing climate” as a matter of provincial interest.


Overview of the Proposed Changes

So what concrete changes to planning policy and practice does this renewed focus on climate change entail? The biggest and most visible change to the Growth Plan is the introduction of a new section, 4.2.10, which is simply titled “Climate Change”. This new section does two things: requires municipalities to integrate climate change into their Official Plans and encourages them to develop greenhouse gas mitigation strategies. The full text of the new section is worth quoting in its entirety:

  1. Upper- and single-tier municipalities will develop policies in their official plans to identify actions that will reduce greenhouse gas emissions and address climate change adaptation goals, aligned with the Ontario Climate Change Strategy, 2015 and the Climate Change Action Plan, 2016 that will include:

a) supporting the achievement of complete communities as well as the minimum intensification and density targets in this Plan;

b) reducing dependence on the automobile and supporting existing and planned transit and active transportation;

c) assessing infrastructure risks and vulnerabilities and identifying actions and investments to address these challenges;

d) undertaking stormwater management planning in a manner that assesses the impacts of extreme weather events and incorporates appropriate green infrastructure and low impact development;

e) recognizing the importance of watershed planning for the protection of the quality and quantity of water and the identification and protection of hydrologic features and areas;

f) protecting the Natural Heritage System and water resource systems;

g) promoting local food, food security, and soil health, and protecting the agricultural land base;

h) providing direction that supports a culture of conservation in accordance with the policies in subsection 4.2.9; and

i) any additional policies to reduce greenhouse gas emissions and build resilience, as appropriate, provided they do not conflict with this Plan. (

2. In planning to reduce greenhouse gas emissions and address the impacts of climate change, municipalities are encouraged to:

a) develop strategies to reduce greenhouse gas emissions and improve resilience through the identification of vulnerabilities to climate change, land use planning, planning for infrastructure, including transit and energy, green infrastructure, and low impact development, and the conservation objectives in policy;

b) develop greenhouse gas inventories for transportation, buildings, waste management and municipal operations; and

c) establish municipal interim and long-term greenhouse gas emission reduction targets that support provincial targets and reflect consideration of the goal of low-carbon communities and monitor and report on progress made towards the achievement of these targets. (

As Policy’s list of subpoints indicate, addressing climate change is a multidimensional and complex problem touching on matters as varied as urban form, stormwater management, agriculture, and energy. It follows then, that Official Plans will be updated to with policies that “reduce greenhouse gas emissions and address climate change adaptation goals” that similarly target a wide range of topics. Ultimately, it will be up to the upper- or single-tier municipality to decide how broadly or narrowly this requirement is applied.

Here, the Growth Plan provides direction. In the same way that climate change is now to be integrated into municipal Official Plans, it is also integrated throughout the provincial land use plans. Broadly speaking, there are two main “thrusts” to the integration of climate change in land use policy – mitigation and adaptation. Mitigation refers to actions that address the root cause of climate change, greenhouse gas emissions, and that seek to limit them. Topics under the mitigation umbrella would include those that speak to energy conservation, limiting sprawl, and reducing congestion. Adaptation refers to actions that address the effects of climate change such as extreme weather, increased rainfall, and prolonged drought, and that seek to protect and insulate our communities from these and other environmental challenges. The key policy changes in the Growth Plan that demonstrate the integration of climate change are (emphasis added):

  • Additions to the policy describing complete communities as follows: Applying the policies of this Plan will support the achievement of complete communities thatmitigate and adapt to climate change impacts, build resilience, reduce greenhouse gas emissions, and contribute towards the achievement of low-carbon communities [and that] integrate green infrastructure and low impact development. ( (f) and (g));
  • Updates to the policies informing infrastructure planning stating:
    • Planning for new or expanded infrastructure will occur in an integrated manner, including evaluations of long-range scenario-based land use planning and financial planning, and will be supported by infrastructure master plans, asset management plans, community energy plans, watershed planning, environmental assessments, and other relevant studies where appropriate, and should involve…identifying the full life cycle costs of infrastructure and developing options to pay for these costs over the long-term; and considering the impacts of a changing climate. ( (c) + (d));
    • Municipalities will assess infrastructure risks and vulnerabilities, including those caused by the impacts of a changing climate, and identify actions and investments to address these challenges, which could be identified as part of municipal asset management planning. (;
  • An amendment to the transit planning and investment criteria described in Section 3.2.3 to state: All decisions on transit planning and investment will be made according to the following criteriacontributing towards the provincial greenhouse gas emissions reduction targets. (; and
  • Changes to stormwater management policies requiring municipal action: Municipalities will develop stormwater master plans or equivalent for serviced settlement areas that…are informed by watershed planning…examine the cumulative environmental impacts of stormwater from existing and planned development, including an assessment of how extreme weather events will exacerbate these impacts and the identification of appropriate adaptation strategies…[and] incorporate appropriate low impact development and green infrastructure. ( (a), (d), and (e));

The key changes in the Greenbelt Plan include:

  • Amending the “Protected Countryside Goals” as they relate to “Settlement Areas” to include the statement “support for the achievement of complete communities that promote and enhance human health and social well-being, are economically and environmentally sustainable, moving towards low-carbon communities, with the long-term goal of net-zero communities”;
  • Adding the following statements to the “Protected Countryside Goals” under a new “Climate Change” section:
    • Integrating climate change considerations into planning and managing theAgricultural System, Natural Heritage System and Water Resource System to improve resilience and protect carbon sequestration potential, recognizing that the Natural Heritage System is also a component of green infrastructure;
    • Integrating climate change considerations into planning and managing growth that includes incorporating techniques to reduce greenhouse gas emissions, and increasing the resilience of settlement areasand infrastructure within the Greenbelt;
  • Updating the description of “Natural Heritage System” to state that it “provides essential ecosystem services, including water storage and filtration, cleaner air, habitat,support for pollinators, carbon storage and resilience to climate change”;
  • Adding the following policy to Section 3.4.2 “General Settlement Area Policies”: Municipalities shall integrate climate change considerations into planning and managing growth in settlement areas in accordance with the policies in subsection 4.2.10 [Climate Change] of the Growth Plan. (; and
  • The addition of several Urban River Valleys (including the Don, Humber, Credit, and Rouge Rivers) into the Greenbelt Area.

Ontario Climate Change Action Plan and Strategy

Before turning to what these policy changes could mean for planning practice and policy at the municipal level and within the building and development industry, recall that the updated Growth Plan, in Policy, requires climate change policies in Official Plans to be “aligned with the Ontario Climate Change Strategy, 2015 and the Climate Change Action Plan, 2016”. Given this clear direction, an overview of the Ontario Climate Change Action Plan and Strategy is necessary. In brief, the Strategy/Plan identifies greenhouse gas reduction targets and describes a range of actions and strategies to meet those targets. These actions and strategies are funded, in part, by the establishment of a “green bank” which is funded, in turn, by a cap-and-trade system.

Here’s how cap and trade works: Essentially, greenhouse gas emissions are “capped” each year and industry actors can “trade” their emissions within that cap. So, for example, an aggressively energy efficient manufacturing company can sell their remaining emissions under that cap to a company that needs to exceed the cap. The annual “cap” is lowered each year to incentivize the reduction of greenhouse gas emissions. Those companies that are performing well in this regard thus stand to profit while those that are lagging are forced to spend to continue business-as-usual; the cap-and-trade mechanism is both carrot and stick. By participating themselves in this system, the Province estimates cap and trade will net approximately $1.8 to $1.9 billion annually. These funds are pooled in a “green bank” whose purpose will be to fund the actions and strategies identified in the Climate Change Action Strategy/Plan. These include research and development of energy efficient technology and practices, investment in public transit and active transportation, home energy retrofits, energy planning, electric vehicle infrastructure, and myriad other initiatives that closely mirror the matters addressed in the updated Growth Plan and Greenbelt Plan vis a vis climate change.



Turning back to the changes to the new climate change policies in the Growth Plan and Greenbelt Plan, what might these changes mean in practice? For one, it is more than likely that new funding streams will become available for projects and initiatives – both public and private sector – that are environmentally focused and address climate change. It is also likely that accessing this funding will be tied, especially for municipalities, to demonstrating how they will meet the greenhouse gas reduction targets identified in the Climate Change Action Strategy/Plan. As such, Policy of the Growth Plan which encourages, but does not require, municipalities to develop greenhouse gas emission reduction strategies, is stronger than its wording implies. Simply put, if municipalities want to access provincial funds, they will likely need to comply.

Obviously another major implication of the updated policy framework is the requirement for municipalities to explicitly integrate climate change into their Official Plans. As with other complex problems, such as affordable housing, the devil will be in the details. Some municipalities will be more aggressive than others and ultimately this direction will be implemented on a case-by-case basis. Expect knock-on effects to the Official Plan updates as well. It would not be surprising if new urban design guidelines are created, zoning reviews initiated, flood mapping updated, and municipal approvals processes amended. Recent experience suggests this is already occurring. Urban Strategies, through our technical partners, has seen municipalities requiring more stringent stormwater and servicing analyses as a matter of course in development approvals. Some approval authorities are now requiring that these reports identify impacts from extreme weather events and are raising their baseline requirements for approval in acknowledgement of the “new normal” that is the result of climate change. It would not be a stretch, especially given the updated criteria for infrastructure planning to account for climate change and full lifecycle cost assessment, to assume that the calculation of development charges and similar fees will be amended as well. While addressing climate change is a costly endeavour, the alternative is certainly not cheaper.

The rigour with which the updated climate change policies, both at the provincial level and at the municipal level through updated Official Plans, are applied and enforced will likely be resolved through the land use appeals process. Since “the mitigation of greenhouse gas emissions and adaptation to a changing climate” now a matter of provincial interest as described in the Planning Act, the door is open to appeals on those grounds for policy, infrastructure, and development projects. However, given the significant changes proposed through Bill 139 as described in the preceding blog post in this series, it is unclear how this question will be resolved, procedurally at least. Regardless of how the ultimate decision is made through the approvals process, it is clear that developers and municipalities both will now be able to be held to account for their impact on the climate.

Climate change, the updates insist, is not a far off problem to be solved through incremental tinkering at the edges, but rather a direct threat to our collective prosperity that requires new thinking how our cities and communities are planned, designed, built, and managed. And although the updated Growth and Greenbelt Plans demonstrate an urgency to make meaningful changes to avoid the worst of the impacts of climate change, it will fall to local actors, namely municipalities and the private sector through each development project, to translate and implement this urgency into day-to-day practice. Recent projects, such as Mississauga’s stormwater charge or Toronto’s Minimum Backup Power Guidelines for Multi-unit Residential Buildings, provide an early indication of what these changes may look like on a case-by-case basis. As these policies are tested and translated over the next five years, how the public and private sectors respond to this new provincial direction will become clearer. In the meantime, we will continue to monitor the changes to the land use planning policy landscape and provide our insight and expertise to our public and private sector clients.

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