Why has so little changed?

The outcome that the Province had hoped to avoid – the over designation of land for development at low average densities and in areas not well served by infrastructure – has in fact occurred, not in spite of the Growth Plan, but because of it.

The reasons for this outcome are related to the many exemptions allowed under the Growth Plan and permitted by the Province. What were intended to be minimum requirements were treated by most municipalities and by the Province itself as maximum requirements.

In its own five-year (2011) review of the Growth Plan, the Province states, “Computer modelling indicates that the Growth Plan will help to curb sprawl. Comparing two future scenarios – one that assumes that the Growth Plan will be fully implemented and one that does not take the Growth Plan into account – suggests that the Growth Plan could help to conserve as much as 800 square kilometres of agricultural and rural land by 2031” (emphasis added).[1]

But the Growth Plan is not being fully implemented. Many municipalities are not intending to achieve 40% intensification or to plan new developments to accommodate 50 people and jobs per hectare. And many municipalities have calculated designated greenfield area densities in a way that is not the same as that described in the Growth Plan, which has the effect of further reducing densities and may  increase the demand for urban area expansions.

Furthermore, since the requirements of the Growth Plan are not fully in effect across the GGH, even seven years after the Growth Plan was established, development continues in many places under older policies. Even after the Growth Plan is in full force in every municipality in the region, low-density development approved under the pre-Growth Plan policies will be considered to be “in the pipe” and will be permitted to proceed under the old rules.

What happens now?

The findings in this report will, Neptis hopes, alert decision makers in the Greater Golden Horseshoe to the fact that the need to manage growth in the region remains urgent. The introduction of the Growth Plan in 2006 may have changed the conversation in Ontario on growth management and regional planning, but it has not (yet) solved the problems it was intended to solve. Very little progress has been made in the area of easing traffic congestion, for example, or in addressing the region’s infrastructure deficit.

At this time, it is not possible to tell whether the Plan’s policies have changed development trends, because the Plan has not been fully implemented by all municipalities. However, the analysis in this report shows that the Growth Plan’s original vision and goals have been compromised by the many exemptions and exceptions allowed to its original provisions.

Municipalities across the GGH have invested a substantial amount of time, effort and resources over the past seven years to ensure that their official plans reflect the Growth Plan policies, targets and forecasts. A lot of work has been done, but the outcome is not clearly preferable to the planning regime that preceded the introduction to the Growth Plan, except in a few instances. Meanwhile, as indicated in Figure 5.1, the GGH continues to grow.

Figure 5.1: Historic and forecast population growth in the Greater Golden Horseshoe

Maintaining the vision for growth in the Greater Golden Horseshoe    

The analysis in this report suggests a number of actions that the Province could take to ensure that the vision and objectives of the Growth Plan for the Greater Golden Horseshoe are not compromised. Although the Province may have embarked on some of these actions already, in advance of the ten-year review, it could go farther in engaging the public in its work.

For example, parts of the Growth Plan have not yet been acted upon by the Province. These include:

  • Developing “a set of indicators to measure the implementation of the policies” in the Plan (policy
  • Monitoring the implementation of the Plan and making the results public (policy
  • Developing guidelines that municipalities can use to monitor and report on the implementation of the Plan (policy
  • Carrying out sub-area assessments for areas within the Greater Golden Horseshoe, to support appropriate forms of growth management in the widely varied sub-regions covered by the Plan (policy 5.3.4).

Completing these tasks would support the work of growth management at a region-wide scale. The Province might also consider establishing a consistent methodology and standards for municipal land budgeting exercises and disallowing appeals of municipal land budgets to the Ontario Municipal Board; such appeals account for the many delays in implementing the policies of the Growth Plan. The Province might also consider allowing lower-tier municipalities to exceed the minimum designated greenfield area density and minimum intensification rate targets set by the upper-tier municipality.

Many other supportive actions are possible, and have been suggested by other writers. These include revising development standards that act as a barrier to planning compact, complete communities (such as standards for roads, schools, and parking), supporting intensification with better incentives for brownfield redevelopment or adaptive reuse of heritage buildings, and ensuring water conservation measures are in place prior to the expansion of new or the expansion of existing treatment facilities.

Finally, the Province could revisit some of its earlier studies on growth management, which note that regulation can do only so much to change development patterns. This point is also made by Pamela Blais in her book Perverse Cities:

It is very difficult, if not impossible to achieve higher densities through regulation alone, particularly in the absence of accurate, transparent pricing. Minimum density regulations are exceedingly difficult to implement: unless the development economics supports efficient densities, more compact development cannot simply be regulated into existence.[2]

The discussion paper cited earlier in this chapter mentioned fiscal tools that support growth management.[3] These included true-cost pricing for infrastructure, development charges that reflect the different costs of development in different locations, land transfer taxes, and property tax reform. These financial instruments may be equally, if not more effective than land use regulation in ensuring compact development. Their deployment is beyond the scope of this document, but it appears that more than regulation may be needed to avoid the continuation of low-density, dispersed development in the Greater Golden Horseshoe.


[2] Pamela Blais, Perverse Cities: Hidden Subsidies, Wonky Policy, and Urban Sprawl, UBC Press, 2010, p. 169.
[3] Government of Ontario, A Growth Plan for the Greater Golden Horseshoe: Discussion Paper, 2004, p. 50.