How definitional differences led to a policy gap

The rural settlement areas in question are officially known as "undelineated built-up areas," (UBUAs). The term was coined in 2008 during the implementation process for the Growth Plan. In fact, the precise boundaries of each settlement are "delineated" in municipal official plans, but not in provincial documents, where they appear simply as dots on a map. There are more than 400 of these settlements scattered across the Greater Golden Horseshoe.

The UBUAs were identified in 2008 when the Province mapped the "Built Boundary." The Built Boundary encloses an area within each urban settlement that is defined for the purpose of measuring and implementing intensification. The intensification of existing urbanized areas is one of the key policy levers in the Growth Plan intended to curb sprawl. The policy in the 2006 Growth Plan requires that upper-and single-tier municipalities direct 40 percent of all residential development to areas inside the Built Boundary. Growth outside that boundary may occur on the contiguous Designated Greenfield Area (previously undeveloped land set aside by municipalities for future development).

Intensification is defined in the Growth Plan as "The development of a property, site or area at a higher density than currently exists through: a. redevelopment, including the reuse of brownfield sites; b. the development of vacant and/or underutilized lots within previously developed areas; c. infill development; or d. the expansion or conversion of existing buildings."[1]

The rationale for not defining a Built Boundary in rural settlements was that UBUAs "are not expected to be a focus for intensification."[2] As a result, they did not require a delineated Built Boundary for monitoring intensification.

The policy conflict emerges in the different ways in which UBUAs are defined or described in the two documents: the 2006 Growth Plan and the 2008 Built Boundary document.

The definition of the Designated Greenfield Area in the 2006 Growth Plan states, "Where a settlement area does not have a built boundary, the entire settlement area is considered designated greenfield area." Meanwhile, Section 3 of the 2008 Built Boundary document states, "The built boundary consists of delineated and undelineated built-up areas."[3] This second definition allows for any development anywhere in a rural settlement, or UBUA, to be counted as intensification, a stark contradiction of the definition in the 2006 Growth Plan.

Neptis research indicates that during the implementation of the Growth Plan, some municipalities used the wording in the 2008 Built Boundary document to justify treating development proposals in rural settlements areas as intensification.

[1] Ministry of Infrastructure, Growth Plan for the Greater Golden Horseshoe, 2006, Office Consolidation, Toronto, 2013, Section 7. Office consolidation retrieved from:

[2] Ministry of Public Infrastructure Renewal, Built Boundary for the Growth Plan for the Greater Golden Horseshoe, 2006, Toronto, 2008. Section 2, Step 4, rule i. Retrieved from

[3] Ministry of Public Infrastructure, Built Boundary for the Growth Plan for the Greater Golden Horseshoe, 2006, Toronto, 2008. Section 3.