Ontario’s Growth Plan for the Greater Golden Horseshoe, a plan for managing growth in the Toronto region, makes a clear distinction between on the one hand, urban settlements with full municipal water and wastewater systems and on the other, rural settlements (small towns, villages, and hamlets) that depend on private or communal wells as a source of water and on septic tanks for wastewater disposal.

The distinction is crucial, because the Growth Plan explicitly states that “population and employment growth will be accommodated by… directing major growth to settlement areas that offer municipal water and wastewater systems and limiting growth in settlement areas that are serviced by other forms of water and wastewater services.”[1] This principle is consistent with the Provincial Policy Statement, which specifies that municipal sewage services and municipal water services are the preferred form of servicing for settlement areas.[2]

An analysis by the Neptis Foundation, however, shows that a contradiction in wording between the 2006 Growth Plan and a 2008 supplementary provincial document has created a policy gap that allows municipalities to direct growth to settlement areas without full municipal services. This contradiction was first noted and described by the Neptis Foundation in 2013.[3] Since then further Neptis research has shown that  decisions made by the Province during the Growth Plan implementation process have not only allowed subdivision-style development, mainly in the form of single-detached housing, in areas without full municipal servicing, but also allowed these developments to be counted as intensification.

The contradiction is important for three reasons. First, although individually most of these towns, villages, and hamlets are small, collectively they represent a sizable amount of land. Neptis analysis shows that as of spring 2016, across the Greater Golden Horseshoe more than 31,000 hectares (76,600 acres)[4] within hamlets, villages, and small towns remain unbuilt, most of them in the Outer Ring.

  • 5,100 hectares (12,600 acres) in the Greater Toronto and Hamilton Area,
  • 26,100 hectares (64,500 acres) in the Outer Ring 

Figure 1: Amount of unbuilt land in undelineated built-up areas (UBUAs) across the Greater Golden Horseshoe, 2016

Second, growth in these areas will lead to demands to extend water and wastewater pipes to partially serviced settlements, at considerable cost. Rural settlement areas are scattered across the Greater Golden Horseshoe and most are discontiguous from existing urban settlements, so pipes would have to be extended long distances to serve these settlements.

Third, and of greatest concern, is the prospect that changes to the 2016 Growth Plan, now under consideration by the Province, will entrench the practice of greenfield development in rural settlements being counted as intensification, thereby undermining the spirit and intent of the original Growth Plan.


[1] Ministry of Public Infrastructure Renewal, Growth Plan for the Greater Golden Horseshoe, 2006, section 2.2.2j.

[2] Provincial Policy Statement,

[3] Rian Allen and Philippa Campsie, Implementing the Growth Plan for the Greater Golden Horseshoe: Has the strategic regional vision been compromised? The relevant section is found at

[4] Note that the 31,000 hectares (more than 76,600 acres) of undelineated built-up area supply is distinct from and in addition to the more than 103,000 hectares (over 254,000 acres) of Designated Greenfield Area (DGA) set aside by GGH municipalities under the Growth Plan to accommodate growth between 2006 and 2031.