The perception of limited land south of the Moraine

Developers paint a dire picture of the GTA's prospects for accommodating growth. They argue that the supply of developable land south of the Oak Ridges Moraine is now dangerously low and the remainder is constrained by environmental protection measures. This situation, they argue, drives up housing costs and limits freedom of choice for homebuyers. Faced with the prospect of the GTA becoming full, population growth "will jump the moraine and Simcoe County is the landing point."102

Examples of this argument include:

  • "They [will] need to buy houses. Where are these people going to go? ... We need to accept the reality that the city growing and [housing] supply is getting tighter and tighter" (Joe Valela, Greater Toronto Homebuilders' Association).103
  • "We've got all these people coming to the region and it's arguable as to where we will put these people. I think what our industry is saying is: over time, it may not be in two years from now, it may be 50 years from now, where we're effectively going to run out of land in the areas that we know today. Let's call it south of the moraine" (Neil Rodgers, Urban Development Institute-Ontario).104
  • "The supply of greenfield land for ground-related housing in the GTA will likely be exhausted by 2017" (IBI Group).105
  • "Long-range plans must be made now to identify new areas capable of accommodating 1.6 million of [the] 3.5 million people not currently accounted for in local and regional Official Plans" (Sorensen Gravely Lowes for Bond Head Development Corporation).106
  • "The greenfield land supply in the GTA is adequate to meet needs to about 2017, even with considerable intensification of ground-related units" (Hemson Consulting).107

Each of these quotes is factually correct. What is missing is the underlying set of assumptions about land supply.

Assumptions about the designation of urban land

The developers' comments implicitly assume that no new land will be designated for urban development south of the Oak Ridges Moraine and that building will continue at prevailing densities. As noted, this is usually made clear in the fine print. For example, in a report for the Greater Toronto Homebuilders' Association, Hemson Consulting stresses that if built at prevailing densities a 14-year supply of land designated for urban use remains in the GTA.108

All data show that there is more than enough land south of the Oak Ridges Moraine to accommodate future development to 2031 and beyond. The debate should not be around whether there is land available, but whether the existing rural and agricultural uses should be changed to urban.

The Toronto-Related Region Futures Study found that at present densities, most municipalities can accommodate anticipated growth through to 2021 within land already designated as urban in official plans, and that "the region has enough additional land for many years of urban expansion ... even with most of the Oak Ridges Moraine protected from development."109 Hemson Consulting agrees, finding that the consensus population projection to 2031 for the GTA can be accommodated at current densities south of the Oak Ridges Moraine if additional lands are designated.110

The conclusion is clear: there is nothing inevitable about Simcoe County having to accommodate growth beyond that projected.

Assumptions about development densities

The argument about limited land supply assumes that development will occur at prevailing densities. If the land were developed at higher densities, however, the supply of land would last longer.

The development industry maintains that housing in southern Ontario is already built at relatively high densities and with a higher proportion of multi-unit buildings than anywhere else in North America. They believe that the market cannot absorb housing at higher densities. In addition, developer market studies indicate an overwhelming preference for ground-related housing.111

However, critics like David Donnelly, legal director of Environmental Defense Canada, claim that with mixed-type construction, the average density can be increased from 24.7 to 86.5 units per hectare, increasing the land supply horizon by many years.112 Even small amounts of infill and incremental intensification throughout already-built-out areas would have an impact on land consumption.

Assumptions about environmental protection measures

The development industry asserts that the supply of developable land is constrained by environmental protection measures. Although environmental protections may be justified, they result in higher prices and less convenient locations for homebuyers, they argue.113 Insofar as these exclude land from development or impose costs on the developer or builder, these policies and standards affect the price of new construction and where development will take place in the region.

In response to 10 years of debate over development encroaching on the Moraine, especially in York and Peel Regions, the Province enacted the Oak Ridges Moraine Conservation Plan (ORMCP) in late 2001. The Plan prohibits development on 92% of the Oak Ridges Moraine and imposes strict development restrictions on the remainder. The ORMCP focuses on protecting headwater areas, watersheds and groundwater sources and protects forests, woodlots, wetlands and agricultural land. The ORMCP sets firm urban boundaries around Settlement Areas (8% of the moraine planning area); identifies and protects Natural Core Areas (38% of the moraine) and Natural Linkage Areas (24% of the moraine); and sets aside agricultural land and other rural land uses in Countryside Areas (30% of the moraine).114

While the Greenbelt Protection Act is being prepared, a zoning order has been passed that prohibits the expansion of urban settlement boundaries south of the Oak Ridges Moraine for one year.115 While it does not apply to lands already designated as urban, the zoning order supports the development industry's argument that developable lands south of the ORM are running out. There is consensus that the land supply south of the Moraine is limited if no new lands are designated. The zoning order then, can be seen to encourage developers to look north of the GTA in Simcoe County, at least in the short term.

Developers also point to the Walkerton Inquiry Report, which focuses on the supply of clean drinking water and the protection of Ontario's groundwater. The Inquiry asserts that the proper management and protection of water resources is best achieved at the scale of the watershed.116 Provincial legislation governing implementation of watershed-based source protection plans is not yet in place. The development industry has indicated that legislation implementing watershed-based source protection plans "will play a very significant role in how the growth of this province is directed"117 and "may pose further challenges to accommodate population and employment uses in the future."118 Members of the development industry have stated that source protection measures south of the Oak Ridges Moraine will drive development north where, by virtue of Georgian Bay and Lake Simcoe, they argue that piped water and technological advancements in wastewater treatment can increase servicing capacity. Under strict watershed protection guidelines, developers and municipalities will likely be required to make costly investments in sophisticated infrastructure for drawing water and treating effluents in order to avoid impacts on ground water sources. In addition to limiting the amount of available land, then, watershed protection plans will also make it more expensive to develop.

Both the OPDI and the Bradford Bond Head Planning Area proposals rely on better wastewater treatment technology becoming available in the future. While the cost of service provision has driven them to propose large-scale, clean-slate developments, there is no guarantee that the technology required to adequately protect sensitive lands and service the developments will be available and applicable.

Environmental protection measures will have two impacts. First, it follows that whenever land previously designated for urban use is taken out of supply for reasons of environmental protection, the supply of land designated for urban use is reduced. Second, since higher standards resulting from new watershed protection measures will apply everywhere in the province, there will be no location-specific disadvantages to development.119 To the extent that new regulations impose higher standards for water provision and wastewater treatment, the developer will assume additional costs, if any, where they supply infrastructure. These costs will be factored into final house prices, which will be passed on to the consumer. It is possible that such costs may make some developments unfeasible.

In both cases, no data exist to indicate the magnitude of the impact on the supply of designated land and costs to the development industry. The Greenbelt Task Force's recommendations next year will have an affect around the margins, but now that the boundaries of the Oak Ridges Moraine and Niagara Escarpment are defined, it is highly unlikely that additional large-scale exclusions of land from development will occur.

The development industry's land supply argument is answerable with an obvious solution: more land must be designated in environmentally appropriate areas south of the Moraine. While the new provincial government's PPS review and Greenbelt Act will likely change the policies and standards governing land designation when they are complete, there is no credible evidence that the incremental designation of urban land that has occurred throughout the 1980s and 1990s will cease completely. There is nothing inevitable about higher-than-projected growth in Simcoe County.

For the moment, however, the Zoning Order has set up a perverse incentive. By fuelling the perception that land development is frozen (even as most municipalities in the GTA have designated land available to 2021), the justification for development outside the GTA is strengthened. The Province must clearly state that the orderly and environmentally responsible designation of urban land south of the Moraine will continue as soon as the review of the regulatory regime is complete.

102. Neil Rodgers. President, UDI-Ontario. Interview. October 31, 2003.
103. Quoted in S. Avery, "Growth Confronts Moraine," Globe and Mail. November 14, 2003.
104. Neil Rodgers. President, UDI-Ontario. Interview. October 31, 2003.
105. IBI Group, Town of New Tecumseth Growth Management/Residential Land Needs Assessment. May 2003. 2.
106. Sorensen Gravely Lowes Planning Associates Inc. Bradford Bond Head Planning Area: Regional Context Overview. February 2004.
107. Hemson Consulting, Growth and Urban Land Need in Central Ontario, prepared for the Greater Toronto Homebuilders' Association 2003a. Executive Summary.
108. Hemson Consulting, Growth and Urban Land Need in Central Ontario, prepared for the Greater Toronto Homebuilders' Association 2003a. 8.
109. Neptis Foundation. Toronto-Related Region Futures Study Interim Report: Implications of Business-As-Usual Development. 2002. 50.
110. Hemson Consulting, "OPDI Peer Review of the IBI Growth Management/Residential Land Needs Assessment." Prepared for the Town of New Tecumseth. January 2004a. 2.
111. Neil Rodgers. President, UDI-Ontario. Interview. October 31, 2003.
112. Avery, Simon, "Growth Confront Moraine," Globe and Mail. November 14, 2003. G1. Densities were originally cited as 10 and 35 units per acre. Note that employment densities are not as flexible as residential densities. For this reason, the Neptis Toronto-Related Region sketch models (2003) show that varying density and location assumptions for residential development do not produce substantial variation in overall land consumption.
113. Neil Rodgers. President, UDI-Ontario. Interview. October 31, 2003; Joe Valela, "Planning Reforms will hurt affordability," Toronto Star. November 29, 2003.
114. Government of Ontario. Oak Ridges Moraine Conservation Plan. 2001. 4.
115. Government of Ontario. Ministry of Municipal Affairs and Housing. "Greenbelt Protection," <>.
116. Government of Ontario, Ministry of the Attorney General, Part Two Report of the Walkerton Inquiry: A Strategy for Safe Drinking Water. 2002. 94.
117. Neil Rodgers. President, UDI-Ontario. Interview. October 31, 2003.
118. Hemson Consulting, Investing for Tomorrow: Moving Forward With Smart Growth in Central Ontario. 2003c. 26-27.
119. Individual parcels of land may of course become un-developable at reasonable cost, but on average it may be assumed that every municipality will be equally affected.