The proposed Growth Plan amendments of 2016 codify the approach taken by Simcoe County through a change in the definitions (contained in Section 7): "Where the built boundary is undelineated, the entire settlement area is considered built-up area."
This wording would allow residential development in 31,200 hectares of unbuilt land in rural settlements (UBUAs) without full municipal servicing to be counted as intensification. The Built Boundary was never meant to include large quantities of undeveloped land, yet including the UBUA in the definition of the Built Boundary would do just that.
Table 1: Policy differences between the 2006 Growth Plan and the 2016 Proposed Growth Plan in the treatment of undelineated built-up areas
Current Growth Plan (2006)
Proposed Growth Plan (2016)
"All land within the built boundary."
"All land within the built boundary. Where the built boundary is undelineated, the entire settlement area is considered built-up area."
"The limits of the developed urban area as defined by the Minister of Infrastructure in accordance with Policy 184.108.40.206."
"The limits of the developed urban area as defined by the Minister in consultation with affected municipalities for the purpose of measuring the minimum intensification target in this Plan. The built boundary consists of delineated and undelineated built-up areas."
Designated Greenfield Area
"The area within a settlement area that is not built-up area. Where a settlement area does not have a built boundary, the entire settlement area is considered designated greenfield area."
"The area within a settlement area that is required to accommodate forecasted growth to the horizon of this Plan and is not built-up area. Designated greenfield areas do not include excess lands."
"Urban areas and rural settlement areas within municipalities (such as cities, towns, villages and hamlets) where:
"Urban areas and rural settlement areas within municipalities (such as cities, towns, villages and hamlets) that are:
The proposed amendments to the Growth Plan also raise the intensification requirement from 40 percent to 60 percent. This change, if approved, could create pressure on municipalities in the Outer Ring to direct more development to small towns, villages and hamlets to attain the higher target, effectively "gaming" the requirements of the Growth Plan. The result? Leapfrog development in areas without full municipal servicing or supported by expensive servicing schemes.
Beyond Simcoe County, the pressure will be particularly intense in municipalities that have no urban settlements with a Built Boundary, such as Hamilton Township in Northumberland County or Douro-Dummer Township in Peterborough County. Since these municipalities have no urban areas of their own, growth can be accommodated only in UBUAs. After Simcoe County, Northumberland and Peterborough counties have the largest amounts of unbuilt UBUA in the Outer Ring - 14 percent and 15 percent, respectively.
During the analysis for this Brief, it became clear to Neptis researchers that the change had been proposed for the amended Growth Plan without a clear understanding of just how much unbuilt greenfield land remains within the UBUA and the sheer scale of growth that is being directed towards rural settlements in the name of "intensification."
 Ontario Land Use Planning Review, Proposed Growth Plan for the Greater Golden Horseshoe, Toronto, 2016, section 7. Retrieved from: https://www.placestogrow.ca/index.php?option=com_content&task=view&id=42...