Balancing Priorities for the Greenbelt, Oak Ridges Moraine and Niagara Escarpment

July 8, 2016

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Big changes are coming for Ontario planners. Changes to growth planning strategies, proposals for inclusionary zoning, the reform of the Ontario Municipal Board and all the action related to the implementation of Bill 73 are creating a crescendo of new planning activity. Put together, they represent major change in the content and process of Ontario planning. Urban Strategies will be keeping you up-to-date on all these initiatives in a series of blog articles we hope are both informative and speak to the issues involved. This is the third post in the series. Previous posts can be found here:  Planning in Ontario, The Quiet Revolution and Urban Growth in the GGH: A Big Change or More of the Same?

In May 2016 the Province released proposed updates to the Places to Grow: Growth Plan for the Greater Golden Horseshoe (‘Growth Plan’), the Greenbelt Plan, the Oak Ridges Moraine Conservation Plan (ORMCP), and the Niagara Escarpment Plan (NEP). Whereas the Growth Plan provides guidance on where and how to grow, these other Plans establish protection measures for significant areas where urban growth and development is not considered appropriate. The Greenbelt Plan area encompasses the previously existing ORMCP and NEP areas. The three plans work together to achieve a delicate balance between protection of key natural heritage systems, agricultural areas, aggregate and other natural resources, infrastructure corridors, and areas that support tourism and recreation.

Urban Strategies undertook two regional community consultation exercises in Niagara and Durham leading up to the review of the Greenbelt, NEP and ORMCP. Participants often pointed to inconsistencies between these layered Plans that can confuse their implementation. The Province’s coordinated review has in part been a major housekeeping exercise, adjusting terminology and policies to ensure consistency between the four plans and the Provincial Policy Statement, 2014. In itself this was a significant undertaking that should help to clarify interpretation and improve consistent implementation across upper and lower tier municipalities.

Beyond ensuring consistency between Plans, participants of our consultation programs in Niagara and Durham also often pointed to the tension between some of the Plans’ priorities. For example, natural heritage protection can potentially conflict with agricultural viability, aggregate extraction and/or tourism and recreation priorities. A number of broader policy changes have been proposed to clarify and adjust the balance between some of the Plans’ key priorities.

Fields in Durham

Fields in Durham

Growing the Greenbelt: a number of proposed changes to the Greenbelt Plan seek to expand the Greenbelt boundaries. This includes incorporating 21 river valleys and 7 associated coastal wetlands, as well as municipally-identified boundary expansions in Hamilton and Niagara. Of particular interest, municipal support will no longer be required to add lands to the Greenbelt. The Province’s previous attempts to grow the Greenbelt placed the onus on municipalities and did not receive significant uptake. In providing an avenue outside the realm of municipal politics, this signals an increased sense of ownership and willingness by the Province to play a more active role in Plan implementation. It should be noted that a number of municipalities had previously evaluated the benefits of adding these river valley/wetland systems to the Greenbelt, and determined that their existing policies actually provided stronger protection. As currently written, the Greenbelt stipulates that where there are other regulations or standards that apply to areas or features within the Greenbelt, the more restrictive provisions prevail. As such, there is likely a degree of political motivation for adding these systems to the Greenbelt so that the Province can report progress on the objective of growing the Greenbelt. However, the move to incorporate these natural heritage systems should also be considered in relation to the proposed changes and new policies to strengthen protection for natural heritage and water systems.

Geese on pond in Uxbridge

Geese on pond in Uxbridge

Protecting Natural Heritage and Water: proposed changes to all four Plans place a much greater emphasis on taking a systems-based approach to understanding and managing natural heritage and water resources. There is a much greater emphasis on watershed, subwatershed, and stormwater planning, which is proposed to be required in relation to serviced settlement areas and major development activities both within and outside the Greenbelt. This could contribute to stronger evidenced-based decision-making, providing a baseline of existing conditions and pointing to the carrying capacity of integral natural systems. Beyond enhanced planning, proposed new policies within the Greenbelt work to enhance actual protection for water systems. Proposed changes to the Growth Plan would require the Province to identify a natural heritage system outside of the Greenbelt Plan area, which would also be protected by enhanced Greenbelt-like protection for these areas. The new focus on a system-based approach is likely a key part of the rationale for growing the Greenbelt to include new river valleys and coastal wetlands, and is also tied to new strategies to manage climate change*.

Bowmanview Farms, Enniskillen

Bowmanview Farms, Enniskillen

Supporting Agriculture: throughout our consultation work leading up to the review, we regularly heard that while the Plans’ had been successful in protecting the agricultural land base from urban development, land use conflicts at rural/urban interfaces and overly restrictive policies within the Plan areas were negatively impacting the viability of the agricultural sector. In particular, stakeholders regularly pointed to restrictions and additional ‘red-tape’ for new farm structures, on-farm diversified uses like agri-tourism, and key agriculture-related uses like food processing and farm equipment servicing. Proposed changes work to understand the ‘agricultural system’ as opposed to just the land base, introducing much greater flexibility to permit on-farm diversified uses and agricultural-related uses that would broadly support the viability of the sector. To address land use compatibility concerns, the Plans propose ‘agricultural impact assessments’ which would be triggered by the introduction of non-agricultural uses within the agricultural system, as well as major activities such as boundary expansions and major infrastructure projects. Here again, the Province is working to take a more active role in implementation, accepting responsibility for identifying the agricultural system which includes ‘prime agricultural areas’, ‘specialty crop areas’, ‘rural lands’, and an ‘agricultural support network’. This would trigger a Municipal Comprehensive Review exercise, requiring municipalities to refine their official plan mapping accordingly.

New system-based policies work to rebalance the Plan’s priorities and would seemingly provide a stronger framework for evidence-based decision-making and management of integral natural systems and resources. However, the efficacy of proposed policies will ultimately be tied to their successful implementation at the municipal level. The Province has previously been criticized in relation to a lack of support during the initial implementation of these complex layered Plans. Initial municipal conformity exercises triggered a huge expenditure of time and resources for municipalities with little assistance from the Province. Some municipalities are still working to resolve conformity matters at the Ontario Municipal Board over a decade later.

On a positive note, proposed policies point to a trend of the Province playing a greater role in regional planning and the implementation of the Plans. Provincial leadership in growing the Greenbelt and identifying natural heritage and agricultural systems may help to ease the burden of implementation for municipalities, as would the efforts to ensure consistency between the Plans. Through Bill 73, the province has also identified matters that are no longer appealable to the Ontario Municipal Board, including portions of official plans that identify boundaries of the Greenbelt. However, municipalities will still be required to update their own official plans to incorporate all of the new protection policies, as well as undertaking a Municipal Comprehensive Review to ensure mapping incorporates the provincially-identified agricultural and natural heritage systems. As such, proposed changes would trigger another major implementation exercise for municipalities. It remains to be seen if the Province is prepared to take a leadership role and dedicate necessary resources and support to ensure more efficient and successful municipal implementation of proposed changes.

* Coming soon: proposed climate change policies will be explored in a future blog post!