The Growth Plan is notable for some of the things it does not contain.
The Plan contains no clear requirements for reporting on the targets by municipalities. It merely states, “Municipalities will monitor and report on the implementation of this Plan’s policies within their municipality, in accordance with guidelines developed by the Minister of Infrastructure.” There are no incentives for municipalities to achieve the minimum targets and no stated penalties for those that do not, nor are there any incentives for municipalities to exceed the minimum requirements of the Plan (although they are “encouraged” to do so). There is no minimum required ratio of jobs to people for development in greenfield areas or in the Urban Growth Centres. There is no standardized method for developing a land budget – the calculation required of each municipality to determine its future land needs, and no requirement to direct larger amounts of growth within each upper-tier municipality to already urbanized areas or more urban municipalities.
The Growth Plan also does not include a requirement that, before they expand existing water and wastewater systems or build new systems, municipalities should implement water conservation and demand management strategies. Nor is there any requirement to stage urban boundary expansions based on the achievement of the minimum intensification or greenfield development density targets, even though such a provision could have contributed to the achievement of the goals of the Plan.