Proposed Changes to the Greater Golden Horseshoe Growth Plan
The Province has recently announced changes to the Growth Plan which contain an important wording change that OSSGA has been lobbying for since 2017. The changes have been put out for consultation on the ERO, and the comment period deadline is July 31st.
OSSGA has prepared a submission that is on our web site that you can view here.
We are encouraging member companies to provide input into this process and submit their own comments on the changes, as this provides evidence to government that there is solid industry support.
Below are key details for submitting your comments; if you have any questions, please do not hesitate to contact me.
- Link to ERO for Growth Plan Request for Comments: https://ero.ontario.ca/notice/019-1680
- Deadline for comments is July 31, 2020
- In the link above there is a button to “Submit Comments” online. They also provide the information below in the posting:
Feedback can be provided by:
- Email at email@example.com
- Environmental Registry online form
- Mail to: Ontario Growth Secretariat
Ministry of Municipal Affairs and Housing
777 Bay Street
23rd Floor, Suite 2304
Toronto, ON M7A 2J3
Province Introduces Provincial Policy Statement 2020
On February 28, 2020 the Province issued a new Provincial Policy Statement (PPS) to replace the 2014 PPS. The new PPS takes effect May 1, 2020. The new PPS will apply to any future Planning Act application but it also applies to any existing Planning Act application where a final decision has not been made.
The majority of the changes to the PPS are focused on housing and employment areas. As it relates to natural heritage resources, water, agricultural and mineral aggregate resources, the new PPS is essentially unchanged from the 2014 PPS. The 2020 PPS maintains the protection of mineral aggregate resources and requires the availability of these resources close to the consumer. The only change related to the mineral aggregate polices of the PPS is confirmation that “where the Aggregate Resources Act applies, only processes under the Aggregate Resources Act shall address the depth of extraction of new or existing mineral aggregate operations.”
The 2020 PPS also include enhanced policies to protect existing and planned industrial uses. These policies should assist aggregate producers that are trying to protect their existing industrial operations, such as asphalt plants, ready-mix plants and cement plants from the encroachment of new sensitive land uses.
The draft 2020 PPS introduced two problematic policies for the aggregate industry. One related to the management / protection of locally significant wetlands, and another would have removed existing permissions that allowed for extraction in certain natural heritage features within the Greenbelt Plan Area. Their inclusion in the final document would have created real problems for the industry so I am happy to report that as a result of our consultations with staff in several ministries, MMAH decided to remove both these potentially damaging policies from the final 2020 PPS.
October 21, 2019
OSSGA's response to the Province's EBR posting on the Provincial Policy Statement focuses on achieving balance. When reviewing the proposed changes, OSSGA was mindful of the proven gap between the consumption rate of aggregates and the rate of licensing replacement reserves in key market areas. This is not sustainable. The ability to access new aggregate reserves depends on the ability of the PPS to provide a balanced approach in finding solutions to competing land and resource use interests. Read the full submission here.
Government's Proposed Changes to Growth Plan
The government has submitted a proposal to make Modifications to O. Reg. 311/06 (Transitional Matters - Growth Plans) made under the Places to Grow Act, 2005 to implement the Proposed Amendment to the Growth Plan for the Greater Golden Horseshoe, 2017.
OSSGA has made the point to the government that the current policy framework is not working. Approvals for new mineral aggregate operations in Southern Ontario are taking up to 10 years to complete the process. There are too many overlapping policies and inconsistent approaches between the Provincial Plans, Regional Official Plans, Local Official Plans and Conservation Authority policies regarding the management of this essential non-renewable resource.
Please see OSSGA Submission by clicking here.
Members who would like to submit their own submissions are invited to use a template letter located here.
October 2018 - Ensuring Economic Growth and Future Greenspace in the Greater Golden Horseshoe.
OSSGA's recommendations, submitted to the Minister of Municipal Affairs and Housing, for securing close-to-market aggregate.
OMAFRA Draft Agricultural Impact Assessment Guidance Document EBR No. 013-2454
Ontario's four provincial plans now have policy requirements for Agricultural Impact Assessments (AIAs) to support the long-term prosperity of agriculture.
Click here for the draft Guidance Document. Comments were due on July 13, 2018.
An AIA will be required under the Growth Plan, Greenbelt Plan, Oak Ridges Moraine Plan, and the Niagara Escarpment Plan for new mineral aggregate operations in prime agricultural areas. The goal of the AIA is to demonstrate that there will be no adverse impacts to prime agricultural land or that any such impacts will be minimized and mitigated.
OSSGA's Land Use and Rehabilitation Committees reviewed the EBR posting and the guidance document and identified a number of areas of concern which include the 1km area of study, potential inconsistencies with the PPS and harmonization with other regulatory instruments. A meeting has been held with OMAFRA to discuss OSSGA's concerns and we continue to work with them to resolve these issues.
Please view OSSGA's submission below.
July 11, 2018: View OSSGA's comments on the Agricultural Impact Assessment Guidance Document here.
The Ministry of Municipal Affairs is seeking input on a study area for potential Greenbelt expansion to protect water resources in the outer ring of the Greater Golden Horseshoe (GGH).
OSSGA's response to the EBR posting highlights the importance of close-to-market aggregate supply for the Greater Golden Horseshoe, duplication in the already complex and overlapping policies as well as concerns with the Natural Heritage Mapping in the Growth Plan and implications around steralizing future aggregate resources. Read the full submission here.
Coordinated Provincial Plan Review
Possible Expansion of Greenbelt
On December 14, 2017 the Ministry of Municipal Affairs announced it is undertaking a consultation on a study area for potential Greenbelt expansion to protect important water resources in the outer ring of the Greater Golden Horseshoe. MMA says that input received through this consultation will help inform decisions on how to move from a study area to a proposed Greenbelt boundary.
In their announcement they say that the purpose of this consultation is to seek input on:
- The province’s approach to identifying moraines, coldwater streams and wetlands as important features for protecting water in the outer ring
- The process followed for mapping a study area based on the locations of these features
- Other factors to be considered when mapping a proposed Greenbelt boundary.
OSSGA’s Land Use Committee will be preparing a response to the consultation paper. The deadline for feedback is March 7, 2018.
For more information about the consultation, please visit Ontario.ca/greenbelt.
Provinces Release new Provincial Plans - NHS and Agriculture Mapping Final Component
The Province's review of the Provincial Plans (the Niagara Escarpment Plan, the Oak Ridges Moraine Conservation Plan, the Greenbelt Plan and the Growth Plan for the Greater Golden Horseshoe) is now complete.
The updated plans can be found on the MMAH website here.
The final component of the Plans is the mapping of the Natural Heritage and Agriculture systems. This work is currently being undertaken and MNRF asked for input through the EBR. Responses were due October 4, 2017. Please find the EBR posting, and OSSGA's response below.
The link to the Natural Heritage Mapping is here.
The link to the Agriculture Mapping is here.
OSSGA Response to Ministry's EBR posting:
On October 4th OSSGA submitted comments to the MNRF regarding the proposed mapping of the natural heritage system in the Growth Plan. The comments focused on the need to protect resource areas and the inclusion of licensed sites in the proposed mapping. A copy of the comment letter can be found here.
The Province put in place four different plans over a 20 year period to help accommodate growth while protecting valuable farmland, water resources and natural heritage. The Coordinated Review of the four plans provided an opportunity to assess progress to date, address challenges and make improvements. The four plans are:
- the Growth Plan for the Greater Golden Horseshoe
- the Niagara Escarpment Plan
- the Oak Ridges Moraine Conservation Plan
- the Greenbelt Plan
The Province created an Advisory Panel to provide recommendations that would inform this review. Headed by David Crombie, the role of the Panel was to develop consensus-based recommendations to the Ministry of Municipal Affairs and Housing (MMAH) and to the Ministry of Natural Resources and Forestry (MNRF) on ways to amend and improve the plans.
The Crombie Advisory Panel released its report, and then, the Provincial Government released the proposed changes to the four provincial plans.
OSSGA, in coordination with MHBC Planning, developed a number of papers and submissions over the course of this review:
First, an industry discussed paper entitled The Future of Ontario’s Close to Market Aggregate Supply: The 2015 Provincial Plan Review as well as an executive summary report was created.
In December 2015 the Advisory Panel released its report Planning for Health, Prosperity and Growth in the Greater Golden Horseshoe: 2015-2041. OSSGA also provided comments on this report available below.
The Province of Ontario subsequently released its proposed changes to the plans. OSSGA's comments on the proposed changes to the plans can be found here.
OSSGA met with the Ministry of Municipal Affairs, the Ministry of Natural Resources and Forestry and the Growth Secretariat's office on July 11th to discuss our concerns with the Coordinated Provincial Plan review.
Present at the meeting were the director of the Growth Policy, Planning and Analysis branch at MAA, and the director of the Provincial Planning Policy branch among others from the ministries along with OSSGA executive director Norm Cheesman, Brian Zeman from MHBC and OSSGA staff.
At the meeting we discussed:
- The expansion of the provincial natural heritage system beyond the Greenbelt Plan, Oak Ridges Moraine Conservation Plan and Niagara Escarpment Plan;
- Prohibiting new mineral aggregate within significant woodlands without consideration of the 'no negative impact test';
- Prohibiting new mineral aggregate operations within endangered and threatened species habitat without consideration of the provisions of the Endangered Species Act;
- Discouraging extraction within Prime Agricultural Areas and requiring rehabilitation back to agriculture (which by definition will prohibit below water extraction within these areas of the GGH);
- Mapping and policy changes to the Niagara Escarpment Plan that will significantly restrict where new aggregate operations may be considered; and,
- Having the changes take effect immediately - which will effectively result in any outstanding licence application that have not yet been approved.
OSSGA provided context to our concerns and had a dialogue with ministry staff. We offered possible solutions to these issues for consideration during the review of the draft plans. In addition we have asked to continue dialogue with ministry staff, along with providing a policy by policy breakdown of our concerns.
Attached is the email follow up as well as marked-up excerpts from the four provincial plans highlighting our concerns.
OSSGA is currently completing a review of the proposed revisions to the four Provincial Plans. To-date a number of revisions have been identified that will significantly impact the licensing of new aggregate reserves within the GGH. These include:
The expansion of the provincial natural heritage system beyond the Greenbelt Plan, Oak Ridges Moraine Conservation Plan and Niagara Escarpment Plan;
Prohibiting new mineral aggregate within significant woodlands without consideration of the ‘no negative impact test’. This revision is also being proposed within the Niagara Escarpment Plan;
Prohibiting new mineral aggregate operations within endangered and threatened species habitat without consideration of the provisions of the Endangered Species Act, which may permit development within habitat if the application results in an overall benefit to the species. This revision is also being proposed within the Greenbelt Plan and Oak Ridges Moraine Conservation Plan;
Requiring immediate compensation for any habitat that would be lost from a site with equivalent habitat on another part of the site or on adjacent lands even if the habitat doesn’t qualify as a key natural heritage or key hydrologic feature.
Discouraging extraction within Prime Agricultural Areas and requiring rehabilitation back to agriculture (which by definition will prohibit below water extraction within these areas of the GGH);
Mapping and policy changes to the Niagara Escarpment Plan that will significantly restrict where new aggregate operations may be considered; and,
Having the changes take effect immediately – which will effectively make any changes for sites with licence applications that have not yet been approved retroactive.
OSSGA will be meeting with Ministry officials (MMAH and MNRF), staff and other stakeholders to raise our concerns and underscore the importance of these issues to the availability of close-to-market aggregate in the years to come. MMAH is hosting public meetings to help those interested learn more about the proposed changes. A list of public meetings is available here. Members are encouraged to attend the meetings. Background materials are available on OSSGA’s website. We will keep members informed of new developments through Rock Talk throughout the summer months.
In December 2015 the Crombie Advisory Panel on the Coordinated Provincial Plan Review released its report: Planning for Health, Prosperity and Growth in the Greater Golden Horseshoe: 2015-2041.
OSSGA's response highlights the importance of close to market supply and the continued availability of high quality aggregate in the Provincial Plan areas.
The Province has identified that over the next 25 years, 2.5 billion tonnes of aggregate will be required in the GGH of which 1.5 billion tonnes is needed in the GTA to implement the infrastructure and growth needs of the Growth Plan. Close to market reserves are depleting at alarming rates and new supply has not been keeping up with current production levels.
Read OSSGA's response here.
OSSGA wrote to NEC seeking clarification on its proposed updates to the Niagara Escarpment Plan (NEP) mapping based on the existing designation criteria (Scenario 2) and the NEC’s proposed designation criteria (Scenario 3). Download the letter here.
Submission to MMAH on Provincial Plan Review
OSSGA submitted the attached letter, as well as a discussion paper prepared by MHBC Planning, in response to the MMAH call for written comments on the Provincial Plan Review.
The letter begins with highlights of the submission presented in our discussion paper, which are then followed by the Association’s answers to the specific questions posed by the Review Panel in its public consultations.
The full discussion paper can be found at:
Far North Land Use Strategy: A Draft
MNRF has posted a draft Far North Land Use Strategy on the Environmental Registry (ER). Deadline for comments is December 28, 2015.
The Far North Act, 2010 provides for community based land use plans to be prepared and approved in a joint process with First Nation communities in the Far North. The Act also requires that the Minister ensure that a Far North Land Use Strategy be prepared to assist in the preparation of land use plans and to guide the integration of matters that are beyond the scope of individual planning areas. The input will help guide and shape the preparation of a final Strategy. Deadline for comments is December 28, 2015