What's in a number? Misconceptions and false comparisons about the GTHA’s greenfield land supply

With the window rapidly closing on changes to the Growth Plan for the Greater Golden Horseshoe through the Co-ordinated Land Use Planning Review, and with continuing frenzy in the real estate market, there is no end to the hyperbole on who and what is to blame for rising house prices in the Toronto region.

A recent commentary in the Globe and Mail used work by the planning and development consulting firm Malone Given Parsons (MGP) to support the claim that the Growth Plan is to blame for a land supply shortage and runaway house prices in the Greater Toronto Hamilton Area. Unfortunately, the commentary contains egregious errors. Among other things, a false comparison was made between the work of MGP and the Neptis Foundation to further a specious argument. Since the author is not the only person to make this kind of mistake, Neptis wants to set the record straight on this matter.

MGP performed a similar (but not identical) exercise to the Neptis Foundation in estimating the amount of designated greenfield area (DGA) set aside by municipalities to accommodate growth to 2031 under the Growth Plan for the Greater Golden Horseshoe. The analysis required a review of municipal official plans and other data sources, as did the Neptis one.

The gross estimate of the land supply from both organizations is comparable. MGP estimated the gross area of the DGA in the Greater Toronto and Hamilton Area (GTHA) at 63,000 hectares; Neptis estimates it more conservatively at 56,000 hectares.

Both estimates also acknowledge that municipal planners have already accounted for the land needed for housing, employment, infrastructure corridors, and the like up to 2031. The DGA includes "take-outs" (undevelopable areas) such as elements of the natural heritage system, open space, and parks. This accounting is part of the land budgeting that municipalities in the GTHA perform regularly as part of the growth planning process. Unfortunately, the data required to make cumulative estimates of the total amount of DGA is not readily available, which is why the time-consuming work by MGP and the Neptis Foundation is so critical to the land use debate.

While the author of the Globe and Mail commentary claims MGP's work indicates a "crisis-level shortage of land for housing," both MGP and the Neptis Foundation have concluded that municipalities have set aside enough land in the GTHA to accommodate the estimated 1.8 million people and 700,000 jobs expected to be added to the region by 2031. This does not include the unprotected countryside area lying outside the planned urban footprint, which represents even more potential for the urban area to grow without the need to urbanize land in the Greenbelt.

Where the analyses by MGP and Neptis differ is in the purpose of the information they collect, and the methods they use.

MGP's work involves tracking municipal plan information and specifically focuses on the residential areas of official plans so that the firm can advise its clients on how much land can be developed for housing. MGP needs to separate employment from residential uses and subtract from the total all areas that cannot be developed.

The Neptis Foundation's research program focuses on understanding long-term change in the city-region, which means tracking over time the growth of the total urban footprint with its many different land uses. Neptis research has shown that over the last two decades, the rate of expansion of the urban footprint has slowed in the Greater Toronto and Hamilton Area (GTHA) and in other fast-growing city-regions in Canada (whether or not they have growth management policies), even though population growth has remained the same or increased. This finding was confirmed in 2016 by Statistics Canada in research showing that population and housing densities increased in rapidly growing cities between 2001 and 2011.

Nevertheless, there are those who disingenuously compare the MPG estimate of 17,200 hectares of "vacant Community Greenfield Areas" to the Neptis Foundation's estimate of 46,000 hectares of "unbuilt" land in the GTHA alone - not to mention land outside the GTHA but still within the Greater Golden Horseshoe.

MGP's number is an estimate of the amount of land that is not in an advanced stage of planning while the Neptis number refers to land that is "unbuilt." These are not the same thing.

Additionally, while MGP focuses on residential land, the Neptis number captures land allocated for both residential and employment uses, because the greenfield density target in the Growth Plan is intended to measure both population and jobs in the DGA. MGP's and Neptis's numbers have been collected for different purposes and cannot be compared in apples-to-apples comparison, as informed observers well know.

Moreover, MGP's recent analysis of the GTHA did not focus on the question of whether the Growth Plan has constrained land supply or not. Its purpose was rather to illustrate the implications of applying the higher greenfield and intensification targets proposed in the amended Growth Plan to an area that has already been planned to accommodate growth up to 2031 under the original (lower) targets. MGP concluded that in some cases, greenfield densities would have to be substantially higher than the new target in order to achieve the overall requirements of the amended Growth Plan.[1]

MGP's work has informed the Province's deliberation on the time frame of the amendments to the Growth Plan and adds much value in getting the implementation of the amended Growth Plan right. Just as a 2013 Neptis report showed how an innovative plan came under pressure that resulted in delays in its implementation, the MGP analysis highlights potential future challenges depending on when and where the new targets are applied.

What MGP's work does not do is to substantiate the falsehood that the Growth Plan has constrained land for residential development, since the analysis clearly shows municipalities have adequately planned for growth to 2031 - as the Growth Plan requires them to do.

It is not surprising at this late stage that the rhetoric from some quarters has been amplified. If there is one thing the Growth Plan can do, despite its many weaknesses and loopholes, it is to reduce the value of certain speculative land investments by making the expansion of the urban footprint in municipalities across the region more difficult. Speculative investors would prefer relaxed rules around the expansion of the urban footprint and the days of ad-hoc municipal planning in which municipalities expanded outwards without having to complete detailed reviews to justify the need to add more land at the urban edge. The Growth Plan aims to curb this kind of planning.

Improvements are certainly required to the Plan, including the need to better align growth with transit investments and to develop a coherent regional economic and employment lands strategy. But if we have learned anything in recent years, it is that as congestion in our region increases to the point at which it has surpassed that in places like Los Angeles, the region cannot continue to grow outward at the pace it has in the past. Efforts to designate yet more land for unsustainable, low-density, car-dependent development and reject the province's plan for a more strategic approach to growth is the real threat to the region's competitiveness.

[1] The Neptis Foundation recognized the difficulty of applying new targets to already planned areas of the region when the proposed amendments to the Growth Plan were first released. After the publication of "The Province must embrace its Role of Regional Planner," a 2016 commentary on the proposed amendments, in which we assumed the targets would apply only to the unplanned time horizon of the Growth Plan (2031-2041), provincial planners contacted the Neptis Foundation to say that in fact the targets would apply to the already planned DGA up to 2031 and to acknowledge that densities would need to exceed the new target in some places.