Components of the land supply in the GGH

Total Unbuilt Land Supply circa 2016 Inner and Outer in GGH

Figure 2. Unbuilt Land Supply in Inner (GTHA) and Outer Ringer of the Greater Golden Horseshoe, as of 2016.

Designated Greenfield Area

The Growth Plan defines the Designated Greenfield Area (DGA) as "the area within a settlement area that is not built-up area."[1] The DGA can accommodate up to 60 percent of residential development as well as employment and other uses. The remaining 40 percent of residential development is directed to existing built-up areas in the form of intensification.

The DGA includes lands that were approved for development before the Growth Plan was established in 2006, as well as new land added since then. The amount of land for development is calculated through a land budgeting exercise whereby municipalities (1) convert population allocations to housing units and the land needed for those units, and (2) allocate employment forecasts to the land needed for different types of employment.

There is a minimum density requirement of 50 people and jobs per hectare for development in Designated Greenfield Areas (certain Outer Ring municipalities are allowed to use lower density targets).[2] This requirement is calculated across the entire DGA of an upper-tier municipality, such as York Region. This means that lower density in one part, such as the Town of Whitchurch-Stouffville, could be compensated for by higher density in the neighbouring City of Markham, which are both part of York Region.

In 2013, the Neptis estimate of the total DGA across the Greater Golden Horseshoe was about 107,100 hectares. Since then, we have revised our estimate following Ontario Municipal Board decisions and amendments to local official plans, to arrive at our new estimate of about 103,200 hectares in total.

For example:

  • In Pentanguishene and Midland, land previously identified as DGA has been reclassified as "land not for urban uses."
  • In Peel Region, new settlement areas have been added in the Town of Caledon.
  • In Waterloo Region, a 2015 Ontario Municipal Board decision reduced the amount of DGA, reversing an earlier OMB decision that had established a larger DGA but had been opposed by the Region.[3]

Note that the DGA estimate is a gross number, and includes areas that may not be developable, such as wetlands, woodlands, and other "take-outs." However, for the DGA municipalities account for these take-outs as part of the land budgeting process that ultimately determines the DGA boundary.

Undelineated Built-Up Areas (Rural Towns, Villages, and Hamlets)

The Growth Plan makes a clear distinction between, on the one hand, urban settlements with full municipal water and wastewater systems and, on the other, rural settlements (small towns, villages, and hamlets) that depend on private or communal wells as a source of water and on septic tanks for wastewater disposal.

The distinction underpins a key goal of the Growth Plan: that of "directing major growth to settlement areas that offer municipal water and wastewater systems and limiting growth in settlement areas that are serviced by other forms of water and wastewater services."[4]

Early on during the implementation of the Growth Plan, the Province decided that these rural settlement areas would not be a focus for growth. As a result, the Province never delineated a boundary between the built-up and unbuilt areas as it had done for more urbanized areas. The Province called areas with limited or no municipal servicing undelineated built-up areas (UBUAs), although these settlements are delineated in municipal official plans. This decision meant that the Province did not know just how much unbuilt land lay within these rural settlement areas.

Neptis has included unbuilt land within the undelineated built-up area as part of the total supply for the following reasons:

(1) New Neptis analysis shows that 31,250 hectares of the 50,240 hectares that lie within the rural settlement boundaries shown on municipal official plans (about 62 percent), is unbuilt. This is a significant supply of potentially developable land.

(2) Contradictions between the Growth Plan and other Provincial documents have blurred the distinction between these settlements and urban settlements[5] such that some municipalities are counting development in UBUAs as "intensification."

(3) In Simcoe County, which has planned for almost 40 percent of its growth to be in the form of intensification, about 65 percent of the units that have been approved as intensification are being directed to UBUAs; 83 percent of these units are in the form of single detached housing units.[6]

(4) Proposed amendments to the Growth Plan could entrench the approach taken by Simcoe County and would allow other municipalities to count growth in UBUAs, even in the form of housing units on previously undeveloped land, as "intensification."[7]

(5) Finally, infrastructure planning is already taking place in municipalities such as Simcoe County to extend urban services to rural settlement areas (thereby allowing leapfrog growth instead of the contiguous outward growth of urban areas), even though the Growth Plan explicitly directs major growth to settlement areas that already offer municipal water and wastewater systems and limits growth in settlement areas that are serviced by other forms of water and wastewater systems.

Barrie Annexation and Brant County-Brantford Boundary Adjustment Lands

Municipal law in Ontario allows for the restructuring of municipal boundaries through annexations and amalgamations.

Since the Growth Plan came into existence, two significant boundary adjustments in the GGH have been allowed by the Minister of Municipal Affairs, resulting in more than 5,000 hectares of rural land being added to the land supply.

In the Barrie-Innisfil Boundary Adjustment,[8] an almost built-out Barrie was allowed to annex almost 2,300 hectares from neighbouring Innisfil in 2009. This annexation was followed in 2016 by the Municipal Boundary Agreement between rural Brant County and the City of Brantford, which resulted in 2,720 hectares of mostly prime agricultural land being brought into the urban envelope.[9]

Neptis did not initially include the Barrie annexation lands as part of the DGA supply because it was unclear whether these lands would form part of the 2031 supply. Secondary plans for a significant portion of these lands now show that development is being planned under the current Growth Plan DGA requirements of 50 people and jobs per hectare and within the 2031 planning horizon.

The planning horizon of the Brant County-Brantford boundary adjustment lands is not yet clear, as Provincial approval took effect in January 2017.[10]

Amendment 1 Lands (Simcoe County and the Cities of Barrie and Orillia)

The Province introduced Amendment 1 to the Growth Plan in October 2010. The Amendment specifically focused on Simcoe County and the cities of Barrie and Orillia, creating special policies in the Growth Plan not available to other municipalities in the Greater Golden Horseshoe.

The policies involved two key changes:

(1) The creation of two strategic settlement employment areas along Highway 400, one in Bradford West Gwillimbury and the other in Innisfil just south of Barrie, as well as the creation of two other employment districts northeast of Barrie.[11]

(2) The creation of seven primary settlement areas when previously there was only one growth node in the area, the City of Barrie. The six other primary settlement areas are Alcona, Alliston, Bradford, Collingwood, Orillia, and Penetanguishene/Midland.[12]

The Province's rationale for the Simcoe exceptions was that the sub-area was "facing intense growth and development pressures" while containing "important environmental assets for the Greater Golden Horseshoe."[13]

The creation of the primary settlement areas did not add any new land to the urban envelope, but the creation of the strategic settlement employment areas along Highway 400 and the other two employment nodes did add 1,861 hectares that were previously not eligible for development under Growth Plan rules.[14]

Strategic settlement employment areas are defined in the Growth Plan as being "planned and protected for employment uses that require large lots of land and depend upon efficient movement of goods and access to Highway 400. These are not settlement areas. Major retail and residential uses are not permitted."[15]

Neptis has included these lands in its total land supply estimates because these areas are part of the urban envelope. Municipal water and wastewater infrastructure plans link them to other settlement areas.[16] Although these lands were intended for employment uses only, pressure is building in Bradford West Gwillimbury, which has a strategic settlement employment area on Highway 400, to convert employment lands to residential uses, based on the argument that there is an oversupply of employment lands in the municipality.[17]

[1] Ministry of Infrastructure, Growth Plan for the Greater Golden Horseshoe, Office Consolidation 2013, section 7, p. 48.

[2] In the 2016 draft of the amended Growth Plan, this target has been increased to 80 people plus jobs per hectare.

[3] The larger DGA was created when developers appealed the proposed Region of Waterloo Official Plan, and the Ontario Municipal Board upheld the developers' appeals. In 2015, the Region and the developers reached an agreement that reduced the extent of the DGA. See Paige Desmond, "OMB accepts settlement of regional land dispute," Waterloo Record, June 18, 2015. Retrieved from

[4] Ministry of Public Infrastructure Renewal, Growth Plan for the Greater Golden Horseshoe, 2006, section 2.2.2j.

[5] Section 3 of the 2008 Built Boundary document states: "The built boundary consists of delineated and undelineated built-up areas." Ministry of Public Infrastructure, Built Boundary for the Growth Plan for the Greater Golden Horseshoe, 2006, Toronto, 2008.

[6] These percentages are derived from Neptis's analysis of the land budget for the County of Simcoe (the land budget was retrieved from

[7] The 2016 draft of the amended Growth Plan states that "The built boundary consists of delineated and undelineated built-up areas." Since all development within the built boundary is considered intensification, development in UBUAs would be treated as intensification. Proposed Growth Plan for the Greater Golden Horseshoe, 2016, section 7. Retrieved from

[8] Barrie-Innisfil Boundary Adjustment Act, 2009. Retrieved from; see also information on the Barrie website at

[9] City of Brantford 2017 Boundary Adjustment map. Retrieved from

[11] See Ministry of Infrastructure, Growth Plan for the Greater Golden Horseshoe, Office Consolidation 2013, section 6.4.1.

[12] See Ministry of Infrastructure, Growth Plan for the Greater Golden Horseshoe, Office Consolidation 2013, Schedule 8.

[13] Ontario Growth Secretariat, Minister of Energy and Infrastructure, Simcoe Area: A Strategic Vision for Growth, 2009, p. 1. Retrieved from

[14] See Ministry of Infrastructure, Growth Plan for the Greater Golden Horseshoe, Office Consolidation 2013, section 6.4, pp. 43-44; and County of Simcoe Official Plan, Schedule 5.1. Retrieved from

[15] See Ministry of Infrastructure, Growth Plan for the Greater Golden Horseshoe, Office Consolidation 2013, section 7, p. 55.

[16] See, for example, Town of Innisfil, Town-wide Water and Wastewater Master Servicing Plan, 2012, retrieved from, and C.C. Tatham and Associates, Water Supply and Wastewater Servicing Master Plan Update: Town of Bradford West Gwillimbury, 2011, retrieved from

[17] See, for example, letter from Keith McKinnon, KLM Planning Partners, to Ryan Windle, Office of Community Planning, Bradford West Gwillimbury, October 4, 2016, retrieved from