PLANNING AND BUILDING SERVICES Planning (Report # 06-14)

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1 PLANNING AND BUILDING SERVICES Planning (Report # 06-14) Report: TO: Planning, Environment & Transportation Committee DATE: 2006/01/16 SUBJECT: CITY OF GUELPH RESPONSE TO PLACES TO GROW, BETTER CHOICES, BRIGHTER FUTURE PROPOSED GROWTH PLAN RECOMMENDATION: That PET Report and its appendices titled City of Guelph Response to Places to Grow, Better Choices, Brighter Future Proposed Growth Plan be forwarded to the Honourable David Caplan, Minister of Public Infrastructure Renewal as the City s comments on Places to Grow; and That this report be circulated to: Association of Municipalities of Ontario; the City of Brantford, the County of Brant, the County of Dufferin, the County of Wellington and the Region of Waterloo; the Grand River Conservation Authority; and Liz Sandals, M.P.P. Guelph-Wellington, as the City of Guelph Response to the Provincial Proposed Growth Plan. SUMMARY: The Province has released Places to Grow, Better Choices, Brighter Future Proposed Growth Plan for public review. The Plan presents a thirty year growth strategy for the Greater Golden Horseshoe Area to manage growth, guide infrastructure and protect cultural and natural resources. The Plan follows the release of an earlier Discussion Paper and Draft Plan for the Greater Golden Horseshoe Area (GGHA). The Proposed Growth Plan is enabled by Provincial legislation which came into affect on June 13, Comments on the Proposed Growth Plan are requested by January 27, The City of Guelph has provided responses to the Province throughout the Places to Grow process through PET Reports 04-79, 04-94, 05-16, and most recently in Report relating to the Draft Plan (March 2005) attached as Appendix 2. Major issues raised by the City included: A Great Place to Call Home Page 1

2 impact on local autonomy the process to be used to conduct sub-area studies the appropriateness of intensification and density targets the need to coordinate local and Provincial infrastructure improvements including transportation matters financial impacts to the City and the lack of implementation details and tools. REPORT: Provincial Growth Concept Overview The Province s proposed Growth Plan includes the following components: Population, household and employment forecasts prepared by the Province are required to form targets as the basis for planning and managing growth both at the Provincial level and within local municipal Official Plans in order to ensure consistency. The projections targets indicate both higher absolute population growth and population growth rates higher than past trends and projections. Previously the City expressed concerns about the projection targets. It is clear however, that the Province intends that these will be the basis for planning until the Growth Plan is reviewed in 5 years. Directing growth to 25 urban growth centres in the GGHA including the City of Guelph. The Growth Plan indicates that the Province will delineate the area where 40% intensification will occur ( the built boundary ) as well as the greenfield land supply needs in consultation with municipalities. Policies and targets to promote more compact and intensified growth within the built boundary which includes urban growth centres, intensification corridors, major transit station areas, and other major opportunities that may include infill, redevelopment, brownfield sites, the expansion or conversion of existing buildings and greyfields. Targets are also set to promote the more efficient use of greenfield lands. A conceptual transportation network consisting of future goods movement corridors and improved inter-regional transit. Policies for infrastructure including the provision of community infrastructure such as schools, hospitals and similar facilities. Policies relating to the protection of natural areas, agricultural lands and mineral aggregate resources and the creation of a culture of conservation as it relates to energy, air quality, waste management and cultural resources. The requirement for the Province to undertake sub-area assessments to refine the Growth Plan at a regional scale as it relates to employment, transportation, the coordination of major infrastructure and the protection of natural areas and agricultural lands. Both the Local Growth Strategy and the Employment Land Strategy the City has initiated will be essential to having informed consultations with the Province, neighbouring municipalities and stakeholders, during the development of the sub-area assessments and other components of the Provincial growth plan. A Great Place to Call Home Page 2

3 The requirement that the Province will develop performance indicators to measure the implementation of the Growth Plan with the requirement that municipalities will undertake monitoring and reporting. The proposed Growth Plan does not differ significantly from the previous draft. Attachments 1 through 5 show the proposed Places to Grow concept. The major changes include: A reduction of issues being dealt with through a sub-area assessment and the removal of a Schedule geographically illustrating sub-areas; A reduced minimum density for Guelph s urban centre from 200 residents and jobs per hectare to 150 residents and jobs per hectare; An increased greenfield density from 40 residents and jobs per hectare to 50 residents and jobs per hectare; A requirement to ensure 40% of new residential development occurs within a defined built-up area by 2015, however, the document gives the Province flexibility to permit an alternative minimum intensification target for an outer ring municipality such as Guelph (previous flexibility was provided through a sub-area growth strategy). The Province will define what the built boundary area will be. The introduction of the concept and the objective of creating complete communities defined as areas that meet a person s needs for living through their whole lifetime by providing employment, shopping, housing and community facilities in close proximity. The requirement to update the Official Plan to conform with the Growth Plan within 3 years of its approval; and An enhanced definition of terms. The final growth plan is anticipated in the Spring of 2006 with implementation measures to be defined within the next 8 18 months thereafter. Response Highlights Some of the issues and implications the Growth Strategy raises for the City include: Reinforcing the need to complete the preparation of a local growth strategy in order to update the City s Official Plan in the context of the Places to Grow Growth Plan. The Provincial growth projections for Guelph and area are higher than the current forecasts that underpin the Official Plan and Development Charges By-law. As growth levels and rates can have significant implications in terms of servicing capacity, land supply and the ability to finance infrastructure the establishment of growth targets should fall out of the Local Growth Strategy as opposed to being imposed through the Places to Grow Plan. Guelph s community vision should help drive growth management. Include waste management infrastructure as part of a sub-area assessment and that the Province commit to providing financial resources and appropriate approval procedures to ensure waste management disposal capacity is available to support the projected growth for the GGHA through conventional and alternative means. A Great Place to Call Home Page 3

4 That sub-area analysis allow flexibility to include other regionally important matters; Continued concerns regarding the proposed intensification targets for the established area and potential impacts on the existing urban form of the downtown area and surrounding neighbourhoods. Concerns regarding the lack of clarity regarding how the enforcement of intensification targets will occur; The Province should give priority to implementing the provincial transportation improvements identified in the 2005 Guelph-Wellington Transportation Study including the expansion of inter-regional transit and the upgrading of the Hanlon Expressway and the Highway 7 and Wellington Road 124 (former Highway 24) improvements; The need to review and likely revise the existing policy framework relating to development in the downtown core and existing height limits / view sheds to meet Provincial density targets; The implications to the City of funding water, wastewater, transportation and solid waste infrastructure improvements to meet expected growth levels and intensification requirements of the Province. Implementation concerns relating to: o The need to amend Development Charges Act, o The need for a new legislative tool needed to prohibit development sprawl o along new major corridors, The suggestion that the Province limit OMB appeals of municipal planning matters related to intensification in conformity with the Provincial Growth Plan. o Lack of transition provisions, plan terminology, and the need for consistent monitoring mechanisms. The Province should ensure that any funding arrangements to implement the proposed growth strategy be sustainable over time and represent a net increase in overall funding to municipalities. A full analysis of the impact of growth must be undertaken to define costs and benefits. New development must bear its share of the costs of growth and the Province must be responsible for fully funding its plan. Appendix I presents a proposed detailed response to the Proposed Provincial Growth Plan. CORPORATE STRATEGIC PLAN: The response to the Proposed Growth Plan addresses a number of Strategic Plan directions. In particular, the response is meant to ensure that the City can manage growth in a balanced, sustainable manner that enhances the social, economic, cultural and environmental values of the community. A strengthened economic base is given increased importance in the Proposed Provincial Plan. In addition, natural, cultural and architectural heritage is supported and community wellness enhanced. A Great Place to Call Home Page 4

5 FINANCIAL IMPLICATIONS: The anticipated growth levels will require infrastructure beyond that current anticipated by the City s Development Charge Study and higher growth rates may require certain facilities faster than is currently anticipated. The municipal cost to implement the Growth Plan will need to be defined through the City s Local Growth Strategy. In addition, Provincial financial commitments to implement the Growth Plan are yet to be identified or committed to. DEPARTMENTAL CONSULTATION/CONCURRENCE: The proposed draft plan has been circulated to various Departments including the Environment and Transportation Group and Economic Development Department which have provided their input in the City's response. COMMUNICATIONS: A public information meeting was held January 10, 2006 to allow the Province to present its Proposed Growth Plan to the residents of Guelph. The meeting was advertised and the public informed that any input received by Jan. 13th on the Plan would be summarized in the City's response to the document. Written comments are attached in Appendix 3. Summary of Public Comments January 10 th, 2006 Growth Plan Presentation: At the January 10 th, 2006 presentation of the proposed Growth Plan by the Province the majority of questions involved clarifications from participants. Overall, with the exception of reservations expressed by development industry representatives, participants attending the session supported the Growth Plan directions. The following summarizes the key points raised: Clarification that the urban growth centre and built boundary geographic areas still need to be defined. Questioning how the Provincial intensification targets will be enforced and confirming that an alternative overall target could be established following the preparation of an intensification strategy. Concerns about whether the Province will provide adequate financial resources in support of its Plan particularly in light of the lack of details in terms of the resources required and where the money is to be spent. The uncertainty of the potential cost to municipalities to implement the proposed Growth Plan was raised. The need to reform the Ontario Municipal Board was raised. That solid waste management should be a matter to be included in the sub-area analysis to be conducted subsequent to the approval of the Growth Plan. The need to provide examples of urban design and forms that achieve the density targets so people can visualize what the results of the targets are. Confirming that the population and employment forecasts prepared by the Province are growth allocation targets to be used but will be reviewed periodically by the Province. Confirming that municipal Official Plans must conform to the Growth Plan within 3 years and inquiring how this requirement will be enforced. The need to ensure the Growth Plan applies to all Provincial Ministries to ensure alignment with the Plan directions. A Great Place to Call Home Page 5

6 The policies relating to cultural heritage resources need to be strengthened. Concerns about the proposed Growth Plan that were raised by representatives of the development industry included: The difficulty in achieving infill projects and the need to ensure infrastructure and tools are available to facilitate it Questioning whether the market will support the proportion of the multiple unit housing types necessary to achieve the Provincial targets. The suggestion that downtown housing represents only a small proportion of the demand for housing which is inconsistent with the attempt to direct significantly more residential development to the urban growth centres. Concerns on the impact of the Growth Plan on the cost and affordability of housing. All of these matters are touched upon in the Appendix 1 the response from the City of Guelph to the Province regarding the proposed Growth Plan. ATTACHMENTS: Attachment 1: Places to Grow Concept Attachment 2: Urban Growth Centres Attachment 3: Moving People Attachment 4: Moving Goods Attachment 5: Growth Plan Land-Use Terminology Appendix 1: City of Guelph Response to Places to Grow, Better Choices, Brighter Future, Proposed Growth Plan, 2005 Appendix 2: April 2005 City Council Resolution and Staff Report March 2005 Appendix 3 Public Comments to the Proposed Growth Plan Prepared By: Joan Jylanne Craig A. Manley MCIP, RPP Senior Policy Planner Manager of Policy Planning ext ext joan.jylanne@guelph.ca craig.manley@guelph.ca Recommended By: James N. Riddell Director of Planning & Building Services ext jim.riddell@guelph.ca Approved for Presentation: Larry Kotseff Chief Administrative Officer P:\PET Reports\PET Reports 2006\(06-14)(01-16) City of Guelph Response to Places to Grow, Proposed Growth Plan (Craig).doc A Great Place to Call Home Page 6

7 Attachment 1: Places to Grow Concept A Great Place to Call Home Page 7

8 Attachment 2: Urban Growth Centres A Great Place to Call Home Page 8

9 Attachment 3: Moving People A Great Place to Call Home Page 9

10 Attachment 4: Moving Goods A Great Place to Call Home Page 10

11 Attachment 5: Growth Plan Land-Use Terminology A Great Place to Call Home Page 11

12 Appendix I City of Guelph Response to Places to Grow, Better Choices, Brighter Future, Draft Growth Plan, 2005 The following represents the City of Guelph s response to the Provincial government s request for comments on the Proposed Growth Plan for the Greater Golden Horseshoe Area (GGHA). The Proposed Provincial Growth Plan provides a framework to manage growth within the GGHA within which the City of Guelph is to plan its own growth and to coordinate its planning with neighbouring municipalities. The key policy directions of the Provincial Growth Plan are: To direct growth to built-up areas where the capacity exists to best accommodate the expected population, household and employment growth while providing strict criteria for settlement area boundary expansions; To promote transit supportive densities and a healthy mix of residential and employment land uses; To preserve employment lands for future economic opportunities; To identify and support a transportation network that links urban growth centres through an extensive multi-modal system anchored by efficient public transit and highway systems for moving people and goods; To plan for community infrastructure to support growth; To ensure sustainable water and wastewater services are available to support future growth; To identify a natural system and prime agricultural areas, and enhance the conservation of these valuable resources. In general there is an alignment between the Provincial Growth Plan vision/objectives and the City s Strategic Plan, SmartGuelph principles and Official Plan. The Proposed Growth Plan represents a significant Provincial planning initiative and it will strongly influence growth and how local planning is conducted for the foreseeable future WHERE AND HOW TO GROW 1.1 Population, Household and Employment Targets Overview: The Growth Plan incorporates growth projection targets which are to be used as the basis for planning and managing growth. The Growth Plan specifically requires that municipalities implement official plan policies based upon the forecasts. The forecasts currently have been prepared for Guelph and the County of Wellington combined, however, the Province has indicated that it will determine separate forecasts for the City. At current growth distribution patterns between Wellington County and the City of Guelph, by 2031 the estimated population for the City would be approximately 200,000 people. If Guelph, due to having full services, ends up taking a greater proportion of growth allocated to Wellington/Guelph area this population threshold would increase. The Provincial growth projection targets are higher than current City/County projections and anticipate continued high rates of growth throughout the time period. The following chart compares the Provincial projection targets to existing projections underpinning the City/County Official Plans and Development Charge Studies. A Great Place to Call Home Page 12

13 City of Guelph - Population Projections and Comparisons population City-County Proj Finance Ministry , ,000 Places to Grow year Comment: The City has previously indicated to the Province concerns about the Provincial growth projections and their underlying assumptions. While the Province has indicated that the projections will be reviewed during the 5 year update to the Growth Plan it is clear that under the proposed plan the projections need to be incorporated into municipal Official Plans. This mandatory requirement is of considerable concern since it is unclear what the implications and ramifications of this higher level of growth are in terms of the City s servicing capacities, land supply and infrastructure financing capabilities. If after completing a comprehensive analysis such as the City s Local Growth Strategy, a municipality can demonstrate that the growth projection targets cannot be met, the Province should commit to revising the projections to reflect that situation. Response to Provincial Growth Targets: 1.0 The City has initiated a long term local growth strategy and community consultation process. The population target for the City should result from that process as opposed to being imposed upon the City. Guelph s community vision should help drive growth management, in conjunction with the Province s Growth Plan. A Great Place to Call Home Page 13

14 2.0 At this point, it is unclear how the City could sustain the rate of population growth projected by the Province from a financial perspective. Without significant Provincial funding the physical and social services infrastructure required by such population increase are unknown at this time. 1.2 Intensification Targets and Development Densities Overview: The Provincial Growth Plan places considerable emphasis on promoting new development through intensification. The Growth Plan incorporates the following measures in this regard: An overall intensification requirement of 40% of new residential growth by 2015 Intensification targets for the downtown area; A requirement to designate intensification corridors and transit nodes A requirement to develop and include in the Official Plan an intensification strategy in keeping with the Growth Plan % Intensification By 2015, the Growth Plan requires that 40% of new residential development occur within a built boundary area defined by the Province as the current edge of the developed urban area. Discussions with Provincial officials indicate that the built boundary will be defined through a consistent methodology for each municipality within the GGHA to allow for monitoring. Draft and Registered Plans that have not been constructed will not be included within the built boundary. For Guelph the built boundary area will be defined by the Province in 2006 in consultation with the City but will likely represent the state of development on the ground at the time the Growth Plan comes into effect (i.e. spring 2006). The Growth Plan recognizes that the 40% requirement may be onerous for municipalities like Guelph in the outer ring of the GGHA and provides that an alternative target can be established given the location and capacity for intensification. Comment: At present, the City is only achieving between 5-10% of development through intensification. In Guelph, intensification has been balanced with other municipal objectives including the appropriate protection of heritage structures and downtown character, maintaining stable neighbourhoods and protecting environmental features. It also should be noted that it is not clear whether or not inner-city locations can support this level of intensification without incurring significant hard and soft infrastructure costs. It is also not clear what the ramifications will be if, despite incorporating policies for intensification consistent with the Provincial target, that actual development in a municipality does not meet these targets. A Great Place to Call Home Page 14

15 1.2.2 Downtown Densities: The Growth Plan requires the City to plan to achieve minimum gross density targets established by the Province for inner-city (downtown) areas by The boundary of these urban growth centres will be defined by the Province in consultation with the municipality. The minimum urban centre density for Guelph has been reduced from 200 jobs and residents per hectare in the previous draft of the Growth Plan to 150. Comment: The delineation of the boundaries of the urban growth centre will be critical in terms of being able to achieve the target. Currently, the City s CBD as defined in the Official Plan meets the target however, the surrounding inner-city neighbourhoods are currently developed at approximately 30 residents and jobs per hectare. If these surrounding areas are included as part of the defined urban growth centre the nature, density and height of the development required to achieve the Provincial target would be substantively larger than existing development. This may also require the City to reevaluate existing policies relating to height and view shed limits in the innercity area. The City s current approach to intensification is to try to balance the introduction of new development into existing neighbourhoods without compromising their character Intensification Corridors and Major Transit Station Areas The Growth Plan requires the City to designate intensification corridors in the Official Plan. These areas are defined as lands along major roads that are to provide a focus for higher density mixed-use development in keeping with transit service levels. In addition the City is to incorporate major transit station areas in the Official Plan. Comment: Many of the roads where intensification corridors could occur are constrained by existing built form to 2 lanes. In fact the Official Plan designates a number of roads as two-lane arterials (i.e. Woolwich, portions of Edinburgh and portions of Gordon Street) so as to not impact adjacent existing inner-city neighbourhoods. Intensification in such areas while maintaining the two lane status could create transportation issues if transit service investments are not increased and financially supported by the Province. The City s Transportation Plan identifies potential transit nodes and the eventuality of linking these nodes through a ring routing system Intensification Strategy: Municipalities are required to develop an intensification strategy to be incorporated into the Official Plan consistent with the Provincially mandated intensification target (i.e. 40%). The strategy is to incorporate urban growth centres, corridors, major transit stations areas, infill and redevelopment sites, A Great Place to Call Home Page 15

16 brownfields and other under-utilized properties. Comment: The requirement to achieve 40% intensification should include new transit supportive mixed use nodes located outside of the existing developed urban area. If greater intensification is to occur financial incentives and the further removal of liability constraints for brownfield development are necessary as is sustainable funding for affordable housing. The remaining brownfield sites are becoming more difficult to develop and funding for affordable housing is very limited despite growing demand. Response to Intensification Targets and Development Densities: 3.0 That the Province work with the City of Guelph to determine if an alternative overall intensification target is warranted for the City that respects cultural heritage and neighbourhood character concerns and represents an appropriate built form for a mid-sized city and that recognition be given to changing the target over time. 4.0 That the City expresses concerns regarding the proposed intensification target for the urban growth centre area as a result of the potential impacts on the existing urban form of the downtown area and surrounding neighbourhoods and that the Province work with the City to define the appropriate area. 5.0 That the Province explicitly state that intensification areas may include nodes and corridors within either a built-up area or greenfield area. 6.0 That the Province provides funding incentives to assist with the production of affordable housing, brownfield remediation and infrastructure improvements. Further, that clear criteria and processes be set for accessing Provincial funds. 1.3 Employment Lands Overview: The proposed Growth Plan places considerable emphasis on maintaining an adequate supply of employment lands to support economic competitiveness. Employment lands are defined as clusters of business and economic activities that include manufacturing, warehousing, and ancillary uses. Major office and retail uses are not included in this definition. Municipalities are required to ensure the availability of sufficient land designated for employment uses to accommodate forecasted employment growth. Lands in the immediate vicinity of existing major infrastructure such as highways and rail yards are encouraged to be designated and preserved for employment purposes. The Growth Plan would only permit the conversion of employment uses to non- A Great Place to Call Home Page 16

17 employment uses or major retail uses only after a municipally initiated comprehensive review of the employment land policies and availability of such lands. The Province has also recently introduced complementary legislative changes limiting appeals in this regard. The Province has indicated that through sub-area analysis it would conduct a regional economic assessment to guide planning for employment. Comment: Limited mention is made of economic development initiatives outside of the protection of key sites, intensification of use and supporting infrastructure. While mention is made of completing a sub-area assessment to conduct a regional economic analysis, it is unclear how this information is to be utilized. Provincial implementation strategies are needed to aid municipal economic development which could include reviewing fiscal tools such as tax increment financing for business development, development charges and land transfer tax. Business cluster development support and exploration of the potential for development corporations to attract private sector investment, are other strategies to investigate. Municipalities need a wide range of tools to support economic development both to attract new investment but also to retain existing investment. Response to Employment Lands Policies: 7.0 That City of Guelph supports the protection of employment lands and the intensification of these lands, where appropriate. 8.0 That the Province clarify the components of a regional economic analysis and its expectation as to how this information is to be used to plan for employment uses before the Growth Plan is finalized. 9.0 That the Province provides a wide range of tools including incentives and legislative reform given the competitive nature of attracting business/private sector investment to support economic development. 1.4 Greenfield Development Overview: Under the proposed Growth Plan minimum greenfield development densities have been increased from 40 residents and jobs per hectare to 50 residents and jobs per hectare. This standard is intended to promote transit supportive density development. Municipalities will be required to monitor and report on performance measures associated with this standard. In addition, the proposed Growth Plan establishes criteria to ensure that new development creates street configurations, densities and an urban form that supports the provision of transit and which creates communities with a mixture of A Great Place to Call Home Page 17

18 housing, shopping, community uses, non-motorized transportation opportunities and allows people to work close to where they live. Essentially, the Growth Plan provides that people are to live in complete communities with these amenities and it establishes criteria to ensure that these areas are pedestrian, cycling and transit oriented. Recent proposals to change the Planning Act to provide greater urban design and subdivision design controls will assist in this regard. Comment: Within the City only two areas currently meet the proposed 50 residents and jobs standard. The two areas are the Willow West and the Stone Road/Scottsdale areas. These areas have approximately 52% multiple unit development (high rise and low rise apartments and townhouses) as compared to the 40% multiple unit development currently being planned for in newly developing areas. An analysis of the newly developing areas at full build out suggests that these areas would achieve approximately 30 to 35 residents and jobs per hectare. The application of the proposed target will require a different development form in newly developing areas in the future. An analysis of new urbanist communities (i.e. Cornell) suggests that the proposed target can be achieved while providing good overall community design. It is noted however, that these communities incorporate a higher proportion of multiple unit development and permit the use of rear yard lanes to access garages. The proposed target would apply to the whole of the greenfield area thus allowing some individual variation of specific developments. Response: 10.0 That City of Guelph supports the intensification target for greenfield lands and the policies associated with the creation of complete communities in newly developing areas. 1.5 Settlement Area Boundary Expansions Overview: The proposed Growth Plan makes it clear that the Province, in consultation with municipalities, will determine the need for and the maximum amount of additional greenfield land for each municipality to accommodate the Provincial growth forecasts. The Growth Plan also establishes that any settlement boundary expansion may only occur through a comprehensive review process initiated by the municipality. This review must address a series of criteria to be met including that any expansion cannot exceed the land supply needs defined by the Province and cannot adversely affect the intensification objectives and targets of the Growth Plan. The completion of the City s local growth strategy will be integral to defining land supply needs. Comments: The Growth Plan appears to be an attempt to significantly change current development patterns and demographic and market preferences primarily by affecting the supply of low density land. The premise appears to be that the A Great Place to Call Home Page 18

19 demand for higher density forms of development will be created through the reduction of low density land. It is not likely that the impacts or success of such an initiative will be fully understood for a number of years. Some concerns have been raised that it will increase housing costs and further commuting times as people continue to seek lower density forms of housing outside of the GTA and other high density communities. Even if the City is capable of meeting the 40% intensification requirement within its built boundary a significant amount of growth will still take place in greenfield locations. If the Province expects its growth projection targets to be accommodated, it will be critical to ensure that single-tier municipalities have the appropriate land capacity within their boundaries and that any necessary settlement expansions are facilitated in this regard by the Province. While the City supports the concept of ensuring that long term land supplies are tied to defined needs, the City s long term growth and the associated land supply should result from the Local Growth Strategy process. Response: 11.0 That the land supply requirements for future growth of the City be defined through the Local Growth Strategy process having regard to locally defined intensification objectives, servicing and financial matters. 2.0 POLICIES FOR INFRASTRUCTURE TO SUPPORT GROWTH 2.1 Provincial Infrastructure Planning Overview: The Plan is meant to guide strategic investment decisions to support population and employment particularly in the areas of transportation, water and wastewater systems, and community infrastructure. A sub-area assessment of regional transit and transportation, and water and wastewater system needs will be undertaken by the Province. The Plan will be supported by long-term multiyear provincial infrastructure investment strategies, such as ReNew Ontario, and by sustainable financing models and sound infrastructure asset management practices. On November 7, 2005 the Province established the Ontario Infrastructure Projects Corporation (Infrastructure Ontario) as a crown agency to oversee major infrastructure projects. Comments: The need to understand and coordinate land use planning systems to make good infrastructure investments and coordinate improvements amongst municipalities is prudent. However, the legal framework provides that the Province could approve a plan predicated on certain infrastructure that may not be supported by all affected municipalities. No option is provided for municipalities to opt out, which in turn could require everyone to finance the infrastructure improvement. A Great Place to Call Home Page 19

20 In addition, although the Growth Plan indicates that infrastructure planning, land use planning and infrastructure investment should be coordinated to implement the plan, there are no Provincial commitments to address waste management system issues or to coordinate waste management matters at a regional level. Rather the Province requires municipalities to establish integrated waste management policies and strategies. To address the waste management capacity requirements of the GGHA related to the expected levels of growth, the Province needs to provide greater commitment to ensuring that financial resources and approval procedures are in place to provide waste management capacity through conventional and alternative means. Response: 12.0 That Provincial Growth Plan should be a means of planning provincial infrastructure and promoting shared infrastructure opportunities where the affected municipalities concur. Municipalities should not be required to establish or help fund infrastructure to facilitate growth unless they agree with the amount of growth and are financially supported by the Province That the Province provides full funding for innovative research dedicated to alternative waste management and infrastructure services/treatment That integrated waste management planning be included in a subarea assessment and coordinated on a regional basis and that the Province commit to providing financial resources and appropriate approval procedures to ensure waste management disposal capacity is available to support the projected growth for the GGHA through conventional and alternative means. 2.2 Moving People and Goods Overview: The Proposed Provincial Plan promotes an integrated transportation system. Figure One presents proposed higher order transit links and future goods movement corridors. A sub-area assessment will further refine and address phasing and the coordination of transportation infrastructure planning and investment at a regional level. Municipalities are to develop transportation demand management official plan policies that reduce trip distance and time, and support multi-modal use with a shift from automobile use to other modes. In moving people, transit is the first Provincial priority for investment. A higherorder transit system and inter-regional transit links between urban growth centres are proposed. Clear links between Guelph and Waterloo Region, and Guelph and the Greater Toronto Area (GTA) continue to be shown in the proposed Growth Plan. Moving goods is about investing in infrastructure that is supportive of Economic Corridors. A future economic/transportation corridor continues to be shown at the A Great Place to Call Home Page 20

21 North end of Guelph linking it with the GTA and Waterloo Region. In moving goods, an inter-modal transportation system that better integrates road, rail, marine and air modes is supported. Municipalities will be required to establish policies that ensure land-use activities around inter-modal facilities, truck routes, rail corridors, highways and major interchanges are compatible with the primary goods movement function of these facilities. New to the Provincial Plan is the clear recognition that development in and adjacent to highway corridors outside of settlement areas is to be discouraged. Comments: The objectives and provisions of the Places to Grow Plan are consistent with the directions of the City s Transportation Strategy, the Guelph-Wellington Transportation Study (GWTS, 2005) and the Official Plan. Specific GWTS recommendations and ongoing future initiatives include: Identifying and implementing TDM measures including transit ridership expansion programs within Guelph; Promoting inter-regional transit usage through (a) the development of an inter-regional, inter-modal Transportation Terminal in Guelph; (b) inter-city bus service including potential service co-ordination between Guelph Transit and Grand River Transit; (c) expansion of passenger rail service on the North Mainline through Guelph; Upgrading of the Hanlon Expressway and Wellington Road 124 (the former Highway 24); The construction of Highway 6 South realignment and the new Highway 7 between Kitchener and Guelph. While the Hanlon Expressway, Highway 6 South and Highway 7 are Provincial undertakings their implementation should be given high priority by the Province in the context of the proposed Growth Plan. Wellington Road 124 was formerly Highway 24 and was downloaded to Wellington County by the Province in It is currently an undivided 2-lane roadway although it is a vital truck route between the US and southwestern Ontario. Provincial support is necessary to upgrade WR 124 as a 4-lane expressway to facilitate transit, goods movement and commuter traffic. Provincial support is also necessary to implement inter-regional transit initiatives including the proposed Transportation Terminal in Guelph. While the document includes discussion on the need to ensure that development along highways and near interchanges is consistent with the Growth Plan, experience shows such areas are very attractive for retail, office and low density employment uses. Clarifying the need to discourage development along corridors outside of settlement areas is a welcome start, however a new legislative tool is needed to ensure that this does not happen. A Great Place to Call Home Page 21

22 Response: 15.0 That the Province support the expansion of inter-regional transit usage by (a) giving funding support to the development of an interregional and inter-modal Transportation Terminal; (b) facilitating expansion of inter-city bus service; and (c) implementing increased passenger rail service on the North Mainline That the Province give priority to (a) the upgrading of the Hanlon Expressway and (b) the construction of the Highway 6 South realignment and the new Highway 7 and the upgrading of Wellington Road That the Province involve the City of Guelph and the County of Wellington at all stages of the planning and development of the proposed GTA West Corridor That the Province establishes legislative and other mechanisms to prevent sprawl along economic corridors and clearly define these mechanisms in the Places to Grow Plan. 2.3 Sustainable Water and Wastewater Services Overview: The capacity of water and wastewater services plays a key role in determining where growth can happen. The Plan anticipates greater coordination amongst municipalities and has added the clear recognition that planning should be done on a watershed basis. Municipalities are encouraged to plan water and wastewater systems that return water to its originating watershed. Specific requirements are noted in considering expansions to municipal systems including water demand management (e.g. conservation), support for intensification and density targets, and consideration of Great Lakes Basin agreements. Through a sub-area assessment the Province in consultation with municipalities will undertake an analysis of water and wastewater capacity and requirements to service the growth forecasts set out in this Plan. The intent of the Sustainable Water and Sewage Systems Act is to ensure that full cost recovery systems are in place for both operating and capital costs, as well as source water protection costs. Aging water and wastewater infrastructure, inadequate revenues to fund repairs and service extensions, and the large capital investment needed to support population and employment growth, are challenges facing most municipalities. Some funding is available through a government cost shared program that municipalities must apply for to access. On December 5, 2005 the proposed Clean Water Act was introduced to the legislature. The Act is meant to protect existing and future drinking water sources through the identification and assessment of water threats. In addition, the Act calls for the development of a source water protection plan to address identified threats. A Great Place to Call Home Page 22

23 Comments: The City of Guelph is currently fully reliant on groundwater resources and rivers to supply water and handle treated wastewater flows. The City has nearly completed a Water Supply Master Plan to determine long term water supplies. The options being considered include continued conservation strategies, tapping additional groundwater supplies, investigating surface water options and investigating a Great Lakes based scenario. The intent of the Water Supply Master Plan is for the City to determine the directions or options it wishes to take. A Wastewater Master Plan process is also being initiated. It is unclear whether the Provincial sub-area assessment could lead to Provincial pressure for a municipality to adopt a particular water and/or wastewater approach. Hopefully the recognition of watershed based planning leads to the sub-area assessment adopting a watershed geography. Response: 19.0 That the Province provide full funding for local municipalities to investigate infrastructure sustainability and capacity analysis which would include inter-regional coordination That a municipality should be able to decide itself if the management of its growth is to be tied to the capacity of its local natural systems, water supply and wastewater disposal or part of a larger inter-regional infrastructure network That the Province conducts its water and wastewater sub-area assessment on a watershed basis. 2.4 Community Infrastructure Overview: A new section on community infrastructure has been added to the proposed Provincial Plan. Community infrastructure refers to lands, buildings, and structures that support the quality of life for people and communities by providing public services for health, education, recreation, socio-cultural activities, security and safety, and affordable housing. The Plan recognizes the importance of providing a range of appropriate community infrastructure to meet population/demographic changes and to foster complete communities. A housing strategy is to be developed by each municipality that includes a range of housing types and densities to support the Province s intensification and density targets. In addition, minimum affordable housing targets are to be established and implemented by municipalities. Comments: It is important that the Province recognize the importance of soft infrastructure along with traditional hard infrastructure (e.g. transportation systems), when planning for growth. However, unlike most hard infrastructure community infrastructure is not subject to a sub-area assessment. The Plan does however A Great Place to Call Home Page 23

24 encourage the services planning, funding and delivery sectors to develop a community infrastructure analysis. Another noted weakness in the Plan is the use of a should statement when looking at community infrastructure to support population/demographic changes, including those related to intensification. Since the Province is a major stakeholder in the provision of soft infrastructure such as hospitals, education and other health facilities, the Growth Plan should indicate that these needs will be supported by long-term multi-year provincial infrastructure investment strategies similar to those committed to for hard infrastructure. Response: 22.0 That the Province commit to creating long term multi-year provincial infrastructure investment strategies for community infrastructure to support the growth needs in this regard in the Growth Plan. 3.0 PROTECTING WHAT IS VALUABLE Overview: The Proposed Provincial Growth Plan recognizes the need to protect and enhance our valuable natural and cultural resources as part of managing growth. Through sub-area assessment the Province will identify the natural system and, where appropriate, policies for its protection. Prime agricultural areas will also be subject to a sub-area assessment. Municipal official plan policies are called to support of a culture of conservation that addresses water conservation, energy conservation, air quality, integrated waste management and cultural heritage conservation. The Plan s definitions section includes an extensive definition of natural heritage features and areas but no definition of cultural heritage is provided. Comments: This section of the Provincial Plan concentrates heavily on natural systems. It is unclear whether significant regional systems such as the Paris-Galt moraine will be given protection similar to the Greenbelt legislation. Cultural heritage appears to be an after-though with only one statement addressing cultural heritage conservation as it relates to the intensification of built-up areas. The importance of a broader municipal cultural heritage plan has been removed from the previous draft plan. It is recognized, however, that increased protection has been provided to heritage resources recently via amendments to the Ontario Heritage Act. Response: 23.0 That the Province clarify how significant regional natural systems will be protected That cultural heritage resources be addressed beyond intensification concerns and that a definition of cultural heritage be included in the Provincial Plan. A Great Place to Call Home Page 24

25 25.0 That appropriate financial incentives and other tools be developed to assist in the protection of cultural heritage resources. 4.0 IMPLEMENTATION AND INTERPRETATION Overview: The document indicates that the key mechanisms to implement the Provincial Growth Strategy include: Providing the legislative framework for the Growth Plan via the Places to Grow Act Establishing a wide range of planning and fiscal tools including instruments found in the Planning Act and Municipal Act Ensuring ongoing monitoring by municipalities in respect of defined performance measures The requirement to update local Official Plans to conform with the Provincial Growth Plan; and Undertaking sub-area analysis to recognize that different regions of the Province have different issues. The Growth Plan also contains a section to assist in interpreting the Plan and a very comprehensive definition section is included. The Growth Plan indicates that the Province will establish a set of performance indicators to measure the implementation of the Plan and will monitor it by requiring municipalities to report on the implementation of the Growth Plan locally as set out in guidelines to be established in the future. Comments: 4.1 Implementation Tools Implementation tools continue to be broad statements. While the plan indicates that Implementation approaches will involve both regulatory and fiscal tools to assist municipalities and other stakeholders in implementing plan objectives, the nature of these tools remain unclear. A large part of the burden of implementation appears to remain with local municipalities without a clear understanding of what tools will be available. Implementing the Growth Plan will require the coordination and support from all levels of government, the private sector, non-government organizations and residents. A clear understanding of the anticipated range of tools to be provided and their timing would be very helpful. The Province has recently introduced a number of proposed changes to the Ontario Planning Act which are intended to complement and help implement the Growth Plan. These changes will be outlined in detail in a separate Staff Report. A Great Place to Call Home Page 25

26 While the Growth Plan indicates that a coordinated approach will be taken within the Government of Ontario to implement this Plan, experience has shown that at times different Ministries of the Province can work at crosspurposes. To be effective the Growth Plan should require that all Provincial policies, programs and actions should be brought into alignment with the Plan. Sustainable funding arrangements to implement the Growth Plan are critical to success. The Province must provide full funding and not transfer an additional burden onto municipalities already struggling financially. One particular regulatory tool that would be of significance in the implementation of the growth plan is the Environmental Assessment process. Currently, increasing water, wastewater and solid waste handling capacity as well as undertaking major transportation initiatives are difficult tasks especially in multijurisdictional situations. In 2004, the Ministry of the Environment began the Improvements to Ontario s Environmental Assessment Process, which is still under way. It is essential that reforms to the EA process should take into account their implications for implementing the Growth Plan including both land use and infrastructure components. The EA reform and the Growth Plan development should be coordinated before they are finalized. Additional legislative tools are needed to prohibit development along new major corridors (outside of settlement areas), and the Province should consider limiting OMB appeals of intensification proposals that are in keeping with the Provincial Growth Plan. While the Growth Plan cannot be appealed, local policies and decisions on proposals implementing it continue to be subject to appeal and will continue to delay the achievement of the Growth Plan and require considerable local resources. 4.2 Official Plan Policies: Overview: The Proposed Provincial Growth Plan places specific requirements on municipal Official Plans. Urban growth centre boundaries are to be defined in municipal Official Plans along with major transit station areas and intensification corridors. Phasing policies and other strategies to achieve intensification and density targets are also to be included in local Official Plans for both built-up and greenfield areas. Official Plan housing policies are to address the needs of all residents including affordable housing. Municipalities are to develop and implement official plan policies in support of conservation objectives specified in the Provincial Plan for water, energy, air quality, waste management and cultural heritage. Transportation demand management policies are also to be included in official plans or other planning documents. Under the Plan, a municipality has three years to amend its Official Plan to bring it into conformity with the Provincial growth plan. Comments: While the City of Guelph Official Plan currently includes many of the Provincial Growth Plan s objectives and policies, during the next major update in 2007 A Great Place to Call Home Page 26

27 the plan will require a careful assessment of current policies to ensure they are compatible in scope, detail and terminology between provincial and local policies. New policies will also likely required. There remains a lack of transition provisions, in particular timing concerning when the conform with provisions are required. 4.3 Sub-Area Assessments: Overview: Both the draft and proposed Provincial Growth Plan recognize that different regions of the Province have different issues. In the proposed Growth Plan, sub-area assessments continue to be required but for a limited number of policy issues. The issues to be addressed at a sub-area level include employment, transportation, natural systems, agriculture, and water and wastewater. Housing, solid waste management and the distribution of population, household and employment forecasts have been removed. In addition, the proposed growth plan no longer geographically defines sub-areas in a Schedule. Instead an accompanying guideline outlines the sub-areas and the items to be covered in the analysis. Comments: It is difficult to determine the impact of the sub-area assessments on the City of Guelph since they have yet to be developed. It is also difficult to know if different geographies are to be used for different sub-area issues. The Plan indicates that the Province will prepare these assessments with municipalities but does not address how potential disagreements between affected municipalities or between the Province and municipalities will be addressed. It is also unclear if the sub-area assessment will serve as background information or be formally incorporated into the Provincial Growth Plan via an amendment. While a number of issues have been removed from the sub-area assessments these studies should be flexible enough to include other locally important matters and it is imperative that solid waste management be incorporated as a required matter. The success of the sub-area strategy will be in its development and implementation. The proof is yet to be found in the details. Flexibility and cooperation is definitely needed as is a common understanding of the terminology used in the document. Response: 26.0 That the Province provide greater flexibility with respect to the matters to be included in sub-area analysis and further that it define the status of these analysis in the Growth Plan That the Province releases a technical support document outlining A Great Place to Call Home Page 27

28 the anticipated legislative, fiscal and other tools available for the implementation of the Places to Grow Plan. Specifically, the Places to Grow Plan should be coordinated with the Ministry of the Environment s EA reform process. Development Charges Act improvements, OMB referral limitations and legislative mechanisms to prevent major development along corridors outside of settlement areas should also be implemented That the Province ensures that any funding arrangements to implement the proposed growth strategy be sustainable over time and represent a net increase in overall funding to municipalities. A full analysis of the impact of growth must be undertaken to define costs and benefits. New development must bear its share of the costs of growth and the Province must be responsible for fully funding its plan That the release of the Final Growth Plan be accompanied by a transition regulation including the timing of the conform with provisions and corresponding policies in the Plan to clarify recognition of growth management and servicing studies that may be ongoing at the time that the Plan comes into effect That the Growth Plan require that all Provincial policies, programs and actions be brought into alignment with the Plan. 5.0 EFFECTIVE MUNICIPAL CONSULTATION Overview: The Growth Plan document indicates a number of key implementation matters to be defined by the Province after the Plan is approved including the following: Verification and delineation of the built boundary; Developing a detailed assessment of need for future designated greenfield areas; Determining the scope and scale of urban growth centres; Undertaking sub-area assessments for key policy areas; Defining implementation tools and performance measures. The Plan indicates that the Province will consult individually with municipalities on the built boundary, designated greenfield areas and urban growth centres and for the preparation of sub-area assessments. There is no commitment to consult on the development of performance measures. A Great Place to Call Home Page 28

29 Comments: Effective consultation and the involvement of municipalities in all of these matters will be critical to the successful implementation of the Growth Plan. The Province should establish implementation working groups with local municipalities to ensure effective communication and the appropriate definition of implementation details. Response: 31.0 That the Province commit to effective local input for the implementation of the Growth Plan by establishing working groups with local municipalities to ensure effective communication and the appropriate definition of implementation details 32.0 That for the sub-area analysis, the Province establish sub-area working groups to discuss elements of sub-area assessments, timing of the sub-area assessments, timing and the results of various local planning initiatives, potential monitoring indicators and other implementation options. A Great Place to Call Home Page 29

30 Appendix 2 April 2005 City Council Resolution and Staff Report March 2005 A Great Place to Call Home Page 30

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32 Appendix 2 April 8, 2005 Resolution and Staff Report of March 2005 A Great Place to Call Home Page 32

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