Neptis commissioned a policy gap analysis,[1] which looked at the original Growth Plan, the proposed amendments to the Growth Plan, the original Greenbelt Plan and proposed amendments, and the Provincial Policy Statement (PPS). The analysis concluded that although it is clearly the intent of these documents to limit subdivision-style development on unserviced or partially serviced land, there is nothing that explicitly prohibits such development. Likewise, the Greenbelt Plan, although it prohibits subdivision-style development in rural areas, does not expressly prohibit development within UBUAs.
The analysis also notes that the decision by the Province to distinguish between delineated and undelineated settlement areas was made on the premise that areas within the UBUA were not intended to be a focus for intensification. Yet the amendments as currently proposed would allow growth anywhere in any UBUA to count as intensification.
[1] Undelineated Built-Up Areas: A Gap that could undermine the Growth Plan. Demarco Allan, 2017.