Land Use Planning: Blind-Eye Measurement and Milquetoast Monitoring

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Effective policy decisions need to be informed by the best available knowledge. Unfortunately, the Ontario government has neglected its responsibility to ensure that adequate information is collected on the practical functioning of the province’s land use plans. If the provincial government continues to make critical land use planning decisions in this information vacuum, Ontario’s land use planning system will be blind and unresponsive to the many challenges our province faces in the decades ahead.

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Ontario’s Land Use Planning System

Ontario’s land use planning system is governed by an array of interconnected legislation, policies and plans. At the provincial level, the Planning Act and the Provincial Policy Statement, 2005 (PPS) form the overarching legislative and policy basis for planning, while the Places to Grow Act, 2005 provides a framework for directing population and economic growth. The Ontario government has also developed a number of provincial land use plans that provide regional guidance (Figure 3.2.1), including:

  • the Growth Plan for Northern Ontario, 2011 (Northern Ontario Plan), under the Places to Grow Act, 2005;
  • the Growth Plan for the Greater Golden Horseshoe, 2006 (Growth Plan), under the Places to Grow Act, 2005;
  • the Greenbelt Plan, under the Greenbelt Act, 2005;
  • the Niagara Escarpment Plan (NEP), under the Niagara Escarpment Planning and Development Act (NEPDA);
  • the Oak Ridges Moraine Conservation Plan (ORMCP), under the Oak Ridges Moraine Conservation Act, 2001; and
  • the Lake Simcoe Protection Plan (LSPP), under the Lake Simcoe Protection Act, 2008 (LSPA).

The PPS and each of these plans contain explicit obligations, mainly for the provincial government, to establish monitoring programs and/or performance indicators in order to evaluate the implementation and effectiveness of policies and to inform review processes. While the PPS is currently subject to review on a five-year basis, regional plans are reviewed every 10 years. Monitoring and evaluation are particularly critical to inform these ongoing and upcoming reviews.

In the mid-1990s, the government introduced the One Window Provincial Planning Service, which made the Ministry of Municipal Affairs and Housing (MMAH) the lead ministry responsible for land use planning. This system greatly reduced the role that other ministries, such as the Ministry of the Environment (MOE) and Ministry of Natural Resources (MNR), had traditionally played in the planning process.

Monitoring and Evaluation

Monitoring and evaluation are important because they can give plans and policies public legitimacy, help politicians and planners in decision making, assist planning reviews, and promote better long-term planning practices. Monitoring can also serve as an early warning system for emerging problems. Without adequate monitoring and evaluation, it is difficult to assess whether planning policies are being properly implemented and whether they are effective. For further information see Chapter 6.4 of the ECO’s 2011/2012 Annual Report, Part 2.

The first step in establishing an evaluation framework is to clearly define a plan’s objectives. Second, the framework should identify indicators that provide a means of measuring performance. Third, there must be monitoring to evaluate whether outcomes on the ground are in line with the plan’s key objectives.

Indicators that assess a plan’s effectiveness on paper do not demonstrate whether objectives are being achieved on the ground. Indicators should measure the physical and ecological impact of policies. Indicators and monitoring strategies should also be clearly defined within plans to provide direction for planning and implementation, and to encourage better monitoring from the outset.

In order to provide a useful picture of land use change, monitoring should be carried out at spatial scales that are appropriate to the issues of interest. In addition, given the gradual effects of planning policies on the landscape, long-term monitoring is essential; this allows for repeated measurements and scientifically defensible conclusions. It is also important to ensure that monitoring takes place from the outset in order to establish baseline conditions. When planning goals are concerned with the protection of ecosystems and natural heritage, monitoring data should be shared among monitoring and planning participants. Many ministries, municipalities, conservation authorities, and environmental groups collect monitoring data, but this information may not be complete, shared or comparable.

Provincial Land Use Plans and Policies

The Provincial Policy Statement, 2005

The PPS is a core element of Ontario’s planning system, providing guidance on: land use patterns and infrastructure; public health and safety; and the management of natural resources, including the protection of natural heritage features. In March 2010, MMAH commenced a review of the PPS, which is currently underway.

The PPS requires the provincial government to identify performance indicators to measure the effectiveness of its policies and to monitor implementation. Municipalities are also encouraged to establish indicators to monitor the implementation of policies in their official plans.

In 2010, the government finalized a set of performance monitoring indicators through a process co-ordinated by MMAH. A small number of these indicators examine whether PPS policies have been effective on the ground, for example, by assessing the total area of land rehabilitated from aggregate extraction. However, the majority simply measure the number of municipalities that have incorporated a given policy into their official plans. For example, the number of municipalities incorporating significant wetland mapping into their official plans is an indicator, yet not whether wetlands are faring differently over time based on land use changes and policies. MMAH has not released the results of its PPS monitoring efforts. In October 2012, the ECO requested this information but, as of July 2013, MMAH had not provided any data, analysis or conclusions. However, MMAH informed the ECO that it is using the performance monitoring results to inform the current PPS review.

Growth Plan for Northern Ontario, 2011

Finalized in 2011, the Northern Ontario Plan provides a 25-year framework to guide decision making and investment planning in the North. Its policies focus on investment in infrastructure, as well as development in “economic and service hubs” and municipalities with “strategic core areas.” The plan’s broad environmental policies address the sustainable development of natural resources, environmental protection, and environmental leadership and conservation. For further information, see Part 2.2.2 of the ECO’s 2010/2011 Annual Report.

The plan requires the Minister of Infrastructure and the Minister of Northern Development and Mines to monitor and report on implementation and develop a set of performance indicators in co-operation with external partners. Part of the newly created Northern Policy Institute’s mandate is to monitor the plan’s implementation. As of July 2013, however, there was no indication that performance indicators were under development, nor have any implementation reports been publicly released.

Growth Plan for the Greater Golden Horseshoe, 2006

The Growth Plan sets out density targets and planning priorities to direct growth in the Greater Golden Horseshoe, an area undergoing intense development. The Greater Golden Horseshoe covers 3.2 million hectares around the western end of Lake Ontario.

The Minister of Infrastructure is required to develop indicators and to monitor implementation of the plan. In addition, municipalities must monitor and report on implementation within their jurisdictions. The Ministry of Infrastructure (MOI) amended the plan in January 2012 to provide direction for the Simcoe Sub-Area (see Chapter 3.5 of the ECO’s 2011/2012 Annual Report, Part 2). In June 2013, a second amendment was made to the plan, which extended the plan’s horizon from 2031 to 2041 and updated and extended the population and employment forecasts for municipalities from 2031 to 2041 (Environmental Registry #011-7468).

In 2011, MOI released a fifth anniversary update that summarized the progress in four areas of the Growth Plan. MOI has stated that it is undertaking research and analysis, and that performance measures will be developed; however, no substantive details have been released regarding the development of a monitoring and evaluation program.

Greenbelt Plan

The Greenbelt encompasses 1.8 million acres of agricultural and environmentally sensitive land between the Niagara Peninsula and Rice Lake, including lands in the NEP and ORMCP plan areas. The plan is intended to provide protection of prime agricultural land and environmentally sensitive areas from urban development.

The Greenbelt Plan requires performance measures to be established through MMAH’s Municipal Performance Measurement Program (MPMP). Under this program, municipalities are required to report annually on a number of service areas; however, only five land use planning measures are tracked, which largely focus on agricultural designations.

The government is also obligated to identify performance indicators to measure the plan’s effectiveness, to identify the roles of partners in the collection and analysis of data, and to provide for the collection, publication and discussion of results. In 2010, MMAH posted a draft Greenbelt Plan Performance Monitoring Framework discussion paper on the Environmental Registry (#010-9407). It proposes “an integrated and layered monitoring framework” under which the Greenbelt Plan, NEP and ORMCP would be assessed.

The draft framework provides a series of sample indicators that address Greenbelt policy themes. These draft indicators suggest that the framework may evaluate on-the-ground results rather than simply formal compliance, for example, by measuring the total change in the area of provincially significant areas of natural and scientific interest. However, the proposal also highlights the issue of data limitations, noting that the framework and sample indicators were selected on the basis of available data. Although the stated purpose of developing the performance monitoring program is to inform the 10-year review, there has been no indication of further progress since the draft framework was posted on the Registry.

Niagara Escarpment Plan

Designated as a World Biosphere Reserve in 1990, the Niagara Escarpment is a forested ridge of sedimentary rock that spans 725 kilometres (km) from Queenston to Tobermory. The NEPDA was enacted to maintain the Escarpment and surrounding area as a continuous natural environment and to ensure compatible development; it also provided for the establishment of the NEP. MNR administers implementation of the Niagara Escarpment Program. However, the Niagara Escarpment Commission (NEC), an agency of MNR, was tasked with preparing the NEP and administering development control in the region.

The NEP requires the development and implementation of an environmental monitoring program to assess and report on the effectiveness of policies, decisions and practices. The monitoring information is to be used in implementation as well as during the plan’s reviews. The NEC established the Ontario Niagara Escarpment (ONE) Monitoring Program to determine whether the plan is accomplishing its objectives. The program assesses the implementation and effectiveness of the NEP in several areas, including natural heritage, water, land use, tourism and recreation, and the Niagara Escarpment Parks and Open Space System. It employs landscape- and site-level monitoring to assess environmental change over time, as well as ecosystem function.

Oak Ridges Moraine Conservation Plan

The Oak Ridges Moraine stretches 160 km from the Trent River to the Niagara Escarpment. The ORMCP is intended “to provide land use and resource management planning direction … on how to protect the Moraine's ecological and hydrological features and functions.” It requires the government to: identify performance indicators; establish a monitoring network to assess changes in the Moraine’s ecological integrity; assess the plan’s effectiveness; and identify improvements.

However, to date, a formal monitoring program for the ORMCP has not been established. The Oak Ridges Moraine Foundation (ORMF), a non-profit organization, is the only group to have completed a comprehensive review of the plan’s effectiveness; in 2011, ORMF released an eight-volume report that measures the plan’s success. However, the provincial government discontinued funding for ORMF in 2012, effectively destroying its ability to continue this work and participate in the 2015 review. In addition, the Monitoring the Moraine project was a community-based initiative that helped track the progress of the ORMCP; however, the program concluded in 2012. For further information, see Part 7.2 of the ECO’s 2010/2011 Annual Report.

Lake Simcoe Protection Plan

The Lake Simcoe watershed is home to important ecological, urban and agricultural systems, and includes portions of the Oak Ridges Moraine and the Greenbelt. The LSPA and the LSPP were introduced to protect and restore the ecological health of the Lake Simcoe watershed. The LSPP provides a series of targets, indicators and policies for the management of aquatic life, water quality, water quantity, shorelines and natural heritage, and other threats/activities (i.e., invasive species, climate change and recreational activities).

The plan requires the design and implementation of a comprehensive monitoring strategy. The LSPA and LSPP require MOE to report every five years on the results of monitoring programs and whether the LSPP’s objectives have been achieved. The LSPA also requires the Minister of the Environment to prepare an annual report that describes implementation measures and summarizes the advice given by advisory committees. To date, two annual reports have been released. As of July 2013, neither report had been posted by MOE on the Registry as required.


Land Use Planning and Biodiversity: Both Need Monitoring
A consistent theme across the PPS and Ontario’s regional land use plans is the protection of natural heritage. Accordingly, these plans are recognized as playing important roles in Biodiversity: It’s in Our Nature, Ontario Government Plan to Conserve Biodiversity 2012-2020. It commits the government to a long-term biodiversity monitoring system, noting that it “is crucial to ensure that Ontario’s efforts are really making a difference to biodiversity.” As of July 2013, no co-ordinated biodiversity monitoring program had been established by the province.

Given the strong connection between land use and the protection of biodiversity, and the common need for monitoring, there is an excellent opportunity for co-ordinating monitoring activities in these two areas. The alignment of monitoring strategies and activities would not only offer efficiency, but could also assist in strengthening the mutually supportive relationship between Ontario’s land use planning system and the conservation of biodiversity.


ECO Comment

The ECO is astounded by the government’s ongoing failure to develop adequate monitoring and evaluation programs for the Greenbelt Plan and the ORMCP. In the case of Lake Simcoe, MOE’s failure to fully comply with statutory reporting and public notice obligations is equally troubling. Furthermore, the introduction of amendments to the Growth Plan in the absence of any comprehensive information on how the overall planning system is functioning is seriously disconcerting. Given this dismal lack of data across the board, the ECO is perplexed as to how any sort of principled and sensible review of the Greenbelt, NEP and ORMCP will occur in 2015.

Although, in principle, MMAH is the main ministry responsible for land use planning in the province, monitoring responsibilities and activities are fragmented between five main ministries (MMAH, MOE, MOI, MNR and the Ministry of Northern Development and Mines) and numerous third party organizations. This piecemeal approach has resulted in highly inefficient and inconsistent monitoring, with significant gaps in knowledge that preclude a comprehensive picture of land use beyond the boundaries of individual plan areas and in the province as a whole. These systemic failings bring into question the functioning of the One Window Provincial Planning Service, which has been the subject of much criticism since its establishment. The ECO believes that the time has come for public scrutiny and the review of the One Window system.

The Ontario government must restore the active role that MOE and MNR once played in the provincial planning process. The ECO believes that the Ontario government should enact a statutory commitment, along with the necessary resources, for MNR and MOE to establish a framework to collect and assess province-wide environmental monitoring data for explicit use in land use planning. The framework, along with all data and analysis, should not only be accessible to all monitoring participants, but should be open to the general public as well.

The establishment of a transparent monitoring and evaluation framework for Ontario’s land use plans is not only a question of sound land use planning – it is a fundamental issue of government accountability. Creating an open, comprehensive monitoring framework will lead to a more robust and defensible system, and allow the public to have a greater understanding of and engagement in Ontario’s land use planning process.


Recommendation 4:

The ECO recommends that MNR and MOE make a statutory commitment to long-term environmental monitoring to inform land use planning in southern Ontario.




This is an article from the 2012/13 Annual Report to the Legislature from the Environmental Commissioner of Ontario.


Citing This Article:
Environmental Commissioner of Ontario. 2013. "Land Use Planning: Blind-Eye Measurement and Milquetoast Monitoring." Serving the Public, ECO Annual Report, 2012/13. Toronto: The Queen's Printer for Ontario. 76-82.

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