Hospital Re-location Analysis

Transcription

1 Hospital Re-location Analysis Background Collingwood General and Marine Hospital is in the early stages of a capital hospital facility redevelopment with the Ministry of Health and Long Term Care. The need for the redevelopment has been established as the facility is out of space and challenges CGMH s ability to sustain care for the community in the future. A growing and aging population is increasing demands on both the staff and the facility. Collingwood Town Council is looking to complete its due diligence on the site selection process leading to the identification of the approved site. Council would like to be satisfied that appropriate selection criteria were identified; information gathered to date is complete and that the process will lead to a successful redevelopment. The CGMH have confirmed they are prepared to assist the Town in achieving a level of comfort regarding the Board s preferred location. The preferred location selected by CGMH is along Poplar Sideroad in an employment area that is designated Industrial Park and zoned in an Industrial Park Exception zone. CGMH retained the services of urbanmetrics inc. to prepare a letter of professional opinion intended to provide CGMH with a third party, arms-length opinion about the impacts of relocating the hospital from its current location at 459 Hume Street to a new Greenfield site located at Poplar Sideroad, just east of Raglan Street. As part of the Town s due diligence process, Planning staff have prepared the following assessment of the applicable policies and/or legislation that would need to be considered if the hospital is to re-locate from its current location: Matters of Provincial Interest Section 2 of the Planning Act, R.S.O. 1990, c.p. 13, as amended, provides that Council in carrying out their responsibilities under the Planning Act shall have regard to matters of provincial interest. The matters of Provincial interest which should be considered in this case include the following: (h) the orderly development of safe and healthy communities; (i) the adequate provision and distribution of educational, health, social, cultural and recreational facilities; (k) the adequate provision of employment opportunities; (p) the appropriate location of growth and development; and (q) the promotion of development that is designed to be sustainable, to support public transit and to be oriented to pedestrians. These matters should be appropriately addressed in any Planning Justification Report. Section 22(7.3) of the Planning Act, R.S.O. 1990, c. P. 13, as amended, confirms that if an Official Plan contains policies dealing with the removal of land from areas of employment, decisions regarding the removal of land may not be appealed to the Ontario Municipal Board. In the hospital s case, the proposed land use is a large employer, but at the same time, as a sensitive land use, they will impact the ability of other employment uses to locate in their vicinity. The municipality will need to ensure that sufficient traditional industrial type employment lands are retained. Greater detail is provided later in this Analysis.

2 Provincial Policy Statement (PPS ) Section 3(5) of the Planning Act, R.S.O. 1990, c.p. 13, as amended, provides that the Council of a municipality, in exercising any authority that affects a planning matter, shall ensure that those powers are exercised in a manner that is consistent with the policy statements issued by the Province. Planning staff have identified the following sections of the PPS as relevant: Healthy, liveable and safe communities are sustained by: c) avoiding development and land use patterns which may cause environmental or public health and safety concerns; and on a related note: Major facilities and sensitive land uses should be planned to ensure they are appropriately designed, buffered and/or separated from each other to prevent or mitigate adverse effects from odours, noise and other contaminants, minimize risk to public health and safety, and to ensure the long term viability of major facilities. Relevant definitions: Major facilities: means facilities which may require separation from sensitive land uses including but not limited to... industries... Sensitive land uses: means buildings, amenity areas, outdoor spaces where routine or normal activities occurring at reasonably expected times would experience one or more adverse effects for contaminant discharges generated by a nearby major facility... Examples may include, but are not limited to: residences, day care centres, and educational and health facilities. Adverse effects: are as defined in the Environmental Protection Act. Comment the policy framework established in the 2014 PPS clearly indicates that health facilities (a sensitive land use) and industrial uses are to be planned so that they are separated from each other. The most appropriate method of ensuring that these land uses are separated is to permit them in distinct designations in municipal planning documents. This policy is also found in Guideline D6 entitled Compatibility Between Industrial Facilities and Sensitive Land Uses prepared by the Ministry of the Environment and Climate Change. Guideline D6 is discussed in greater detail later in this Analysis. Further comment Planning staff recommend a review of our own documents to ensure that they are consistent with section of the 2014 PPS Planning authorities shall promote economic development and competitiveness by: a) providing for an appropriate mix and range of employment and institutional uses to meet long-term needs; d) ensuring the necessary infrastructure is provided to support current and projected needs Planning authorities shall plan for, protect and preserve employment areas for current and future uses and ensure that the necessary infrastructure is provided to support current and projected needs.

3 Planning authorities may permit conversion of lands within employment areas to nonemployment uses through a comprehensive review, only where it has been demonstrated that the land is not required for employment purposes over the long term and that there is a need for the conversion. Relevant definitions: Employment areas: means those areas designated in an official plan for clusters of business and economic activities including, but not limited to, manufacturing, warehousing, offices, and associated retail and ancillary facilities. Comprehensive review: includes an official plan amendment which is initiated or adopted by a planning authority, which is based on a review of population and employment projections and which reflect projections and allocations by upper tier municipalities and provincial plans... (see Appendix for complete definition). Comment in the opinion of Planning staff, while health facilities are considered as a type of employment land use (an institutional use) in accordance with the PPS, they are not permitted in traditional industrial areas classified as employment areas. There appears to be a distinction drawn in the Provincial Planning documents between employment land uses and employment areas. An employment area is defined as the more traditional industrial area and which does not permit sensitive land uses such as health care facilities. Therefore, in order to redesignate the Poplar Sideroad industrial lands to an institutional category a comprehensive review of the employment projections is needed so that the municipality is assured that there is a sufficient long term supply of traditional Industrially designated land. It should also be noted that there is a distinction between the comprehensive review definition in the PPS and a municipal comprehensive review which is the term used in the Growth Plan. The Growth Plan requires that the review be initiated by the municipality The vitality of settlement areas is critical to the long-term economic prosperity of our communities. Development pressures and land use change will vary across Ontario. It is in the interest of all communities to use land and resources wisely, to promote efficient development patterns, protect resources, promote green spaces, ensure effective use of infrastructure and public service facilities and minimize unnecessary public expenditures. Comment as part of the due diligence process Town Council is interested in obtaining an accurate and up to date assessment of the costs the Town will be expected to absorb as part of a hospital re-development project. This assessment will be of great assistance to the municipality in whatever form this project moves forward. Growth Plan for the Greater Golden Horseshoe Section 3(5) of the Planning Act, R.S.O. 1990, c. P. 13, as amended, provides that the Council of a municipality, in exercising any authority that affects a planning matter shall conform to the provincial plans that are in effect, or shall not conflict with them, as the case may be. Planning staff have identified the following sections of the Growth Plan as relevant: 6.1 Simcoe Sub-area Context

4 The policies of Section 6 direct a significant portion of growth within the Simcoe Subarea to communities where development can be most effectively serviced, and where growth improves the range of opportunities for people to live, work, and play in their communities, with particular emphasis on primary settlement areas... By providing further direction on where growth is to occur in the Simcoe Sub-area it also establishes a foundation for municipalities to align infrastructure investments with growth management, optimize the use of existing, planned and new infrastructure, co-ordinate water and wastewater services, and promote green infrastructure and innovative technologies. A more livable, compact, complete urban structure with good design and built form will support the achievement of economic and environmental benefits Municipalities with primary settlement areas will, in their official plans and other supporting documents b) identify and plan for intensification areas within primary settlement areas c) plan to create complete communities within primary settlement areas d) ensure the development of high quality urban form and public open spaces within primary settlement areas through site design and urban design standards that create attractive and vibrant places that support walking and cycling for everyday activities and are transit-supportive Community infrastructure planning, land-use planning and community infrastructure investment will be co-ordinated to implement this Plan. Relevant definitions: Simcoe Sub-area The geographic area consisting of the County of Simcoe, the City of Barrie and the City of Orillia. Primary Settlement Areas Locations set out in Schedule 8. Primary settlement areas are the settlement areas of... the Town of Collingwood. Complete Communities meets people s needs for daily living throughout an entire lifetime by providing convenient access to an appropriate mix of jobs, local services, a full range of housing, and community infrastructure including affordable housing, schools, recreation and open space for their residents. Convenient access to public transportation and options for safe, non-motorized travel is also provided. 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, sociocultural activities, security and safety, and affordable housing. Comment in the opinion of Planning staff the Growth Plan makes it clear that the Town of Collingwood as an identified primary settlement area, is to be the focus of growth and development in north-west Simcoe County. It is to be a complete community with community infrastructure including health care. Planning staff are of the opinion that if Provincial policy is to be followed then the hospital should remain in Collingwood.

5 2.2.2 Population and employment growth will be accommodated by a) directing a significant portion of new growth to the built-up areas of the community through intensification b) focusing intensification in intensification areas c) building compact, transit-supportive communities in designated greenfield areas Planning for growth will take into account the availability and location of existing and planned community infrastructure so that community infrastructure can be provided efficiently and effectively An appropriate range of community infrastructure should be planned to meet the needs resulting from population changes and to foster complete communities Services planning, funding and delivery sectors are encouraged to develop a community infrastructure strategy to facilitate the co-ordination and planning of community infrastructure with land use, infrastructure and investment through a collaborative and consultative process. Comment Planning staff are of the opinion that the existing community infrastructure, built-up areas of the community and planned facilities need to be thoroughly considered if the preferred site is a greenfield location which would require servicing extensions. Planning staff also appreciate that for hospitals to operate efficiently they require servicing redundancies that may not currently be in place Municipalities will promote economic development and competitiveness by a) providing for an appropriate mix of employment uses including industrial, commercial and institutional uses to meet long-term needs b) providing opportunities for a diversified economic base, including maintaining a range and choice of suitable sites for employment uses which support a wide range of economic activities and ancillary uses, and take into account the needs of existing and future businesses c) planning for, protecting and preserving employment areas for current and future uses d) ensuring the necessary infrastructure is provided to support current and forecasted employment needs Municipalities may permit conversion of lands within employment areas, to nonemployment uses, only through a municipal comprehensive review where it has been demonstrated that a) there is a need for the conversion b) the municipality will meet the employment forecasts allocated to the municipality pursuant to this Plan c) the conversion will not adversely affect the overall viability of the employment area, and achievement of the intensification target, density targets and other policies of this Plan d) there is existing or planned infrastructure to accommodate the proposed conversion e) the lands are not required over the long term for employment purposes

6 Relevant definition: Municipal Comprehensive Review an official plan review, or an official plan amendment, initiated by a municipality that comprehensively applies the policies and schedules of this Plan. Comment Planning staff are of the opinion that the Town s planning documents should ensure that there is an adequate supply of land designated for industrial, commercial and institutional uses to meet the community s long term needs. In accordance with the requirements of the Growth Plan, the County of Simcoe is currently in the process of preparing a study to determine the amount of industrial land needed in each of its 16 communities. Town staff have been in contact with the consultant preparing this study to ensure that adequate information is included to provide background information for any future Town initiative such as a municipal comprehensive review. Planning staff recognize that further to c) above, sufficient information is going to need to be provided to determine that the existing businesses in the east end employment area are not going to be negatively impacted by the proposed hospital location and that there will be sufficient land available to accommodate the Town s anticipated industrial growth. Proposed Growth Plan for the Greater Golden Horseshoe, 2016 The Proposed Growth Plan, 2016 adds the term prime employment area and the current draft includes the following policies: Suitable lands within settlement areas that are adjacent to, or in the vicinity of, major goods movement facilities and corridors, including major highway interchanges, should be identified as prime employment areas Prime employment areas... will be designated in official plans and protected for appropriate employment uses over the long term by: a) prohibiting residential and other sensitive land uses, institutional uses, and retail, commercial and office uses that are not ancillary to the primary employment use; With the exception of prime employment areas, employment areas within settlement areas will be designated and planned to: b) prohibit residential land uses and limit other sensitive land uses to preserve the longterm integrity of the employment areas for uses that require those locations; The conversion of lands within prime employment areas to employment areas, or lands within employment areas to non-employment uses may be permitted only through a municipal comprehensive review... Relevant definition: Prime employment area Areas of employment within settlement areas that are designated in an official plan and protected over the long term for uses that are land extensive or have low employment densities and require these locations, including manufacturing warehousing and logistics and appropriate associated uses and ancillary facilities.

7 Comment Planning staff recognize that at this time the Growth Plan, 2016 is not in effect. If it comes into effect in the short term it does provide additional clarity which respect to sensitive land uses in employment areas. It should also be noted that the Poplar Sideroad lands would likely fit the definition of a prime employment area where institutional uses are prohibited. County of Simcoe Official Plan The relevant policy sections of the County of Simcoe Official Plan follow: Emissions Where a land use change is proposed that is likely to adversely affect existing uses or be adversely affected by existing uses, a feasibility study that assesses the impacts of odour, noise, vibration, particulates, or other emissions may be required in accordance with appropriate provincial guidelines... (full text see Appendix) Major facilities, such as utility and transportation facilities and corridors, airports, sewage treatment facilities, waste disposal sites, industrial installations, and mineral aggregate operations, and sensitive land uses shall be appropriately designed, buffered and/or separated from each other in accordance with Provincial standards and guidelines to prevent unacceptable adverse effects from odour, noise, vibration, and other contaminants. Comment the Emissions section of the Simcoe County Official Plan is the upper tier s approach to addressing Ministry of Environment Guideline D6 and policy of the PPS. Additional comments regarding Guideline D6 are found later in this Analysis. Community Facilities and Services Before consideration is given to developing new infrastructure and public service facilities, opportunities for adaptive re-use should be considered, wherever feasible and subject to local municipal official plans Community facilities and public service facilities should be co-located in community hubs, where appropriate, to promote cost-effectiveness and facilitate service integration, access to transit and active transportation. Comment the Simcoe County Official Plan does encourage the creation of community hubs for public uses. The location of CGMH is close proximity to Georgian College would contribute to the creation of a community hub, however the appropriateness of this location would require greater investigation than has occurred to date. Town of Collingwood Official Plan There are a number of policy sections of the Town s Official Plan that are relevant during any assessment of a potential hospital re-location. It should be noted that the Town s Official Plan does not presently include an institutional designation. As opposed to specifically limiting the location of institutional uses to particular areas, the Town Plan includes a chart (Figure 3, see Appendix), which indicates in which

8 designations public uses and community services are permitted. Hospitals, nursing homes, senior citizen/retirement homes, group homes and emergency housing are permitted in all areas designated Residential and Commercial. Comment hospitals and nursing homes are not permitted in areas designated Industrial because these uses are considered sensitive land uses. Staff believe that these uses were initially identified as sensitive land uses in the Ministry of the Environment and Climate Change Guideline D6. The Ministry Guideline establishes separation distances between sensitive land uses (section 1.2.1, example given includes hospitals) and industrial uses. Although the Guidelines were issued many years ago, they are still used by the Ministry and planning authorities to establish appropriate setbacks between land uses. The Guideline recommends potential influence areas of between 70 and 1,000 metres and minimum separation distances of between 20 and 300 metres. The size of the setback is dependent on the type of industrial use permitted proposed in the area. The Town of Collingwood has a long history of receiving complaints from home owners about industries causing odour and noise, and disrupting the owner s enjoyment of their residential property. The Ministry of Environment and Climate Change has been involved on numerous occasions, and received many calls and complaints. Local industries have been charged and fined. As a result, Town staff are particularly attuned to potential land use conflicts between industries and sensitive land uses and want to be assured that future problems will not develop. Planning staff would recommend that Figure 3 should be amended to remove from the Industrial category the following uses: - schools - nursery schools - day care centres. This proposed amendment is necessary to ensure that the Town s Official Plan is consistent with the 2014 Provincial Policy Statement. Section 3.13 Attenuation of Noise, Vibration, Odour and Noxious Emissions (full text see Appendix) Comment Section is the Town s approach to addressing Ministry of Environment Guideline D6. Studies are required when development is proposed which may adversely affect existing uses or be adversely affected by existing uses. In the case of the proposed hospital relocation, the hospital as a sensitive land use could be adversely affected by industries existing in the area. The closest traditional industries to the proposed site include a grain terminal and a brewery. As noted, in addition to determining whether or not the existing industries are far enough away so that there would be no negative impact on the proposed sensitive land use, studies would be needed to determine that there is no impact on the industry s ability to continue to operate. Also, studies would be needed to determine the size of the buffer around any proposed sensitive land use and what uses would be appropriate within the buffer to ensure that there are no impacts on either the hospital or the existing industries. Section 3.17 Redesignation of Industrial Lands (full text see Appendix) Comment Industrial lands are only to be redesignated if the studies completed in 2007 would have supported the conversion, or if required, a further Municipal Comprehensive Review recommending the conversion was completed. As noted previously, the County of Simcoe is

9 currently preparing an employment lands land budget which has the potential to form a basis for an updated municipal comprehensive review. Planning staff are of the opinion that up to date information reflecting current circumstances is necessary in order to appropriately assess the merits of any potential review/ conversion initiated by the municipality. Section Special Policy Health Services (full text see Appendix) Comment The urbanmetrics opinion concludes that: In the case of Collingwood, current land use policies dictate that healthcare providers should only locate within the SPA-Health Area. Planning policies, in our opinion should not hold users captive, particularly if other, better lands are available that could help advance the public interest. The text of Section says It is a policy of this Official Plan to encourage a broader range of health services to be located on lands that are close to the hospital. In the opinion of Planning staff this policy permits and supports the location of health services near the hospital. It is an encouragement policy as opposed to a policy that restricts health care uses to only being located close to the hospital. The policy was put in place in 2008 to encourage the creation of a campus of health related uses to locate around the hospital and, public and private investments have been made as a result of this policy. The Town s Official Plan and Zoning By-law permit medical clinics, pharmacies and professional offices in a number of commercial locations. Nursing homes and retirement homes are permitted in a variety of residential and commercial locations. As noted previously, hospitals are permitted on any lands that are designated either Residential or Commercial (Figure 3). Therefore, Planning staff and urbanmetrics opinions differ with respect to the interpretation of the effect of the Health Services overlay. The additional comment that staff would like to make is that the Health Services is an overlay as opposed to a distinct designation. It was put in place to facilitate comprehensive planning of medical related uses in the vicinity of the hospital. That being said, all of the land owners in the area have the ability at the present time to propose either residential or commercial developments that are not health oriented on their property. Admittedly, since the later part of the last decade the pace of commercial development has slowed down quite considerably in Town. Staff are not sure how the removal of the health overlay on its own, would provide more flexibility for the Hume Street land owners. Section Industrial Objectives To preserve the industrial integrity of the Town s industrial parks and in particular the east end industrial area by discouraging the intrusion of non-industrial uses. Comment this policy was added to the Official Plan after the Town accepted the findings of the 2008 Industrial Land Strategy prepared by urbanmetrics. Recommendation 1.6 of this report says: To ease the pressure for conversion the Town should develop a policy position that makes it clear that redesignation is not an option in specific areas of the community, with more restrictions on conversion in the eastern portion of Collingwood than in the west where significant conversion of employment to commercial uses has already taken

10 place. This will give a clear message as to the rules of the game for the development industry in Collingwood. And in 2016 urbanmetrics are recommending to the hospital the following: Having reviewed the available expansion options for CGMH, we strongly believe relocating the hospital to Poplar Sideroad represents a better, more efficient option from an economic/business case perspective. These seemingly divergent positions clearly leave the municipality with a number of challenges. Summary If CGMH is going to re-locate from its current location, the initial step would be for Council to authorize staff to undertake a Municipal Comprehensive Review of the Town s employment areas. The studies and background work that would be needed to support the review/ conversion of a portion of the Town s east end industrial park to an institutional designation would include at a minimum demonstration of the following: - there is a need for the conversion; - the land is not required for employment purposes over the long term; - that the Town will be able to meet the employment forecasts allocated to the municipality by the Growth Plan. The County s Employment Lands Land Budget study will provide a good indication of the current land supply; - the re-designation will not adversely affect the overall viability of the employment area, and achievement of the intensification target, density targets and other policies of the Growth Plan; - there is existing or planned infrastructure to accommodate the proposed conversion; - the re-designation respects natural features, buffers and open space corridors which may define land use categories; and, - cross-jurisdictional issues have been considered. In addition, the application for re-designation and/or Comprehensive Review shall determine whether the proposed land use conversion will impact any of the following Town services: - allocation of sewer and water capacity for the subject area; - transportation and transit infrastructure; - stormwater management; - the demand for parkland and recreational facilities including trails and walkways. (Section 3.17 Official Plan) The Town planning documents would need to be amended to set out a policy framework for a new land use classification likely to be titled Major Institutional. The size of the buffer area that would be required around the institutional use would need to be determined and identification of the type of uses which would be permitted within the buffer area. In conjunction with this exercise the Town would need to review the Industrial land use policies and the Industrial schedule of the Official Plan. New areas for some of the heavier industrial

11 uses would need to be identified, as the current planning documents permit heavier manufacturing activities on the interior potions of the Di Poce industrial lands. References to the 2007 review of the Industrial land supply and the policies recommended by that document would need to be deleted from the Official Plan. Update Figure 3 of the Official Plan to delete several sensitive land uses from the Industrial column. The Health Services Overlay on Schedule A of the Official Plan would need to be deleted along with the policies of section The Zoning By-law allowing additional permitted uses on the properties in the area would also require amendment.

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