The 10-year-review of the Growth Plan and the proposed amendments together represent an opportunity to correct a decision made during the implementation of the Growth Plan to allow greenfield development within rural settlements (undelineated built-up areas or UBUAs) to be counted as intensification. If the Growth Plan is to work as intended, the important distinction between intensification and greenfield development needs to be maintained. The distinction is important because of the unsustainable costs of servicing small, scattered developments across the Greater Golden Horseshoe. The need to control these costs was one of the main reasons the Growth Plan was established in the first place.

The fact that this significant policy gap has allowed for interpretations of the Growth Plan that are directly contrary to the stated goals of the Growth Plan is an important reminder of the need to monitor growth in the Greater Golden Horseshoe, including the extension of water and wastewater infrastructure to rural areas. Unless growth is monitored, it will be impossible to tell whether the Growth Plan is working as it was intended to do.

There is a choice to be made: do we direct growth to settlements in which it contributes to cost-effective infrastructure investments or do we continue to allow growth in rural settlements in ways that increase infrastructure demands and costs?