HomeMy WebLinkAboutCSD-16-069 - Provincial Plan Review - Propsed Growth Plan for the Greater Golden Horseshoe
REPORT TO: Planning & Strategic Initiatives Committee
DATE OF MEETING: October 3, 2016
SUBMITTED BY: Alain Pinard, Director of Planning, 519-741-2200 ext. 7319
PREPARED BY: Brandon Sloan, Manager, Long Range & Policy Planning,
519-741-2200 ext. 7648
WARD(S) INVOLVED: All Wards
DATE OF REPORT: September 19, 2016
REPORT NO.: CSD-16-069
SUBJECT:Provincial Plan Review
Proposed Growth Plan for the Greater Golden Horseshoe, 2016
RECOMMENDATION:
That report CSD-16-069 regarding comments on the proposed Growth Plan for the
Greater Golden Horseshoe, 2016 be endorsed and submitted to the province as
the City of Kitchener comments.
BACKGROUND:
Pursuant to the Places to Grow Act, the Growth Plan for the Greater Golden Horseshoe
(Growth Plan) took effect in June 2006. Waterloo Region and the City of Kitchener were
included in the geographical extent of the plan and thus had new provincial policies and
targets to plan for regarding how we manage our growth. This not only charted a new
course for planning and housing, but also created new directions for transportation,
engineering infrastructure, the environment, social infrastructure and other matters
related to a complete and healthy community.
The Region’s Official Plan and the new Kitchener Official Plan conform to the current
Growth Plan. Portions of the Growth Plan also influence the Planning Around Rapid
Transit Stations (PARTS) project, specific trunk sanitary sewer studies, the City’s
Transportation Master Plan and even some components of the Comprehensive Review
of the Zoning By-law (CRoZBy).
The province initiated a coordinated review of four plans in 2015. Of the four plans, only
the Growth Plan currently has effect in Kitchener. In response to the first phase of public
consultation on a provincial discussion document, Kitchener provided initial high-level
comments via report CSD-15-043. A Proposed Growth Plan for the Greater Golden
Horseshoe, 2016 was released this year for comment with the review deadline being
the end of October. This report provides an overview of some of the key proposed
changes and forms the staff comments.
*** This information is available in accessible formats upon request. ***
Please call 519-741-2345 or TTY 1-866-969-9994 for assistance.
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REPORT:
Overview
The Province of Ontario issued “Shaping Land Use in the Greater Golden Horseshoe” in
May 2016 which provides a guide to the proposed changes to four provincial plans: The
Growth Plan for the Greater Golden Horseshoe, The Greenbelt Plan, The Oak Ridges
Moraine Conservation Plan and the Niagara Escarpment Plan. The four plans are all in
the process of being updated and the intent is that they work together to help manage
growth, conserve the natural environment, build complete communities and support
economic development within a fast growing area. The primary themes from this
coordinated land use planning review are:
Building Complete Communities
Supporting Agriculture
Protecting Natural Heritage and Water
Growing the Greenbelt
Addressing Climate Change
Integrating Infrastructure
Improving Plan Implementation
To date, the Growth Plan is the only one of these provincial plans that is relevant to
Kitchener and is the primary focus of the content of this report.
Provincial Plan Review Link: http://www.mah.gov.on.ca/Page14809.aspx#Introduction
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Proposed Growth Plan for the Greater Golden Horseshoe, 2016
While the principles contained with the proposed Growth Plan update remain strong and
true to key growth management principles, there are significant changes proposed
within the policies, definitions and time horizons. The current understanding is that
some changes may take effect immediately upon approval of the updated plan and
other policies will be implemented through a municipal comprehensive review, such as
the next Regional Official Plan update and subsequent conformity update for
Kitchener’s Official Plan. Given the fairly significant scope of the material and proposed
changes, combined with so much planning work currently occurring at the local level,
the potential implications of the proposed Growth Plan require some time to fully
understand and determine the likely impacts. Notwithstanding, this report highlights
some of the positive aspects of the new plan along with a few of the likely challenges
and potential implications specifically for Kitchener. Additional commentary on the
individual sections of the proposed Growth Plan is attached to this report as Appendix
A.
Although the Greenbelt Plan does not currently include lands within Kitchener, there is a
portion within part of Waterloo Region and the province is reviewing that plan as well.
We will monitor to see if there are any major changes proposed that could affect us.
There is new terminology being introduced in the Greenbelt Plan that is being aligned
and included in the Growth Plan and those implications will need to be further
confirmed. Some of the key terms and proposed policies are touched on within this
report and we understand the Grand River Conservation Authority and Region of
Waterloo are further reviewing.
Positive Highlights
Much of the policy direction within the proposed Growth Plan, including many of the
newer changes, are aligned with the direction that our municipal master plans, policies
and implementation plans are heading (i.e. low impact development and minimum
density for major transit station areas). A major highlight is that this provincial plan
includes a schedule regarding “Moving People – Transit” that shows a future high-speed
rail corridor linking Kitchener with Toronto (and conceptually Pearson Airport) and
continuing southwesterly from Waterloo Region. After significant local and broader
efforts to demonstrate the importance of the improving the movement of people in the
Waterloo Region-Toronto Innovation Corridor, it is great to see this need reflected within
a provincial plan. We are excited to see this infrastructure move forward, along with
enhancements to the existing higher order transit (i.e. 2-way GO rail) and the priority
transit corridor (the ION LRT route).
The proposed Growth Plan continues to emphasise the importance of complete
communities (which is aligned and reflected with our new Official Plan “A Complete and
Healthy Kitchener”). The plan also continues to highlight the importance of protecting
and conserving natural heritage features and adds new emphasis on water resource
systems, key hydrologic features and watershed planning. Policies regarding integrated
infrastructure planning and enhancing the linkage between transportation/transit
planning and land use planning are critical elements of managing growth. If practiced
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fully to the implementation and development process stage, our communities could be
transformed to be much more sustainable and healthy.
The proposed Growth Plan also brings climate change more into the foreground of
growth planning. This also includes direction for stormwater management principles,
such as low impact development, along with green and resilient infrastructure. From a
municipal perspective, the inclusion of policies that require more consideration and
emphasis of the financial implications of growth such as the full life cycle costs for
infrastructure and public service facilities are quite important. Overall, many of the
principles and high-level policies of the proposed Growth Plan provide positive direction
to ensure that growth can positively contribute to our communities.
Challenges and Potential Implications for Kitchener
The proposed changes to the Growth Plan are significant. We are in the process of
major overhauls of our local level planning framework, primarily to conform to previous
shifts in provincial and regional policy. We will need time to further analyze what the full
implications may be of further significant changes to policies, targets, infrastructure
planning and needs, alignment of terminology, etc. This may require dedicating
resources to revisit some of the planning and related initiatives that were recently
undertaken.
Some of the challenges from the proposed Growth Plan relate to matters such as the
population and employment forecasts, the extended time horizon, infrastructure
planning beyond the horizon, proposed changes and implementation of the numerical
targets regarding the intensification level and the greenfield density requirement, and
the continued uncertainty and lack of clarity with respect to employment lands. While
important, the further emphasis on intensification within the Built-up Area will put added
pressure on ensuring that growth is directed to the most appropriate locations and that
redevelopment is designed sensitively in order to integrate better into the existing urban
fabric. Intensification in established neighbourhoods remains an important topic in
Kitchener (as with most growing municipalities) and there is the potential for future
added pressures.
Two of the major changes in the proposed Growth Plan include the potential increase in
the Intensification Level target from a region-wide 40% to 60% and in the minimum
greenfield density target from a region-wide 50 resident and jobs combined per hectare
to 80. Since Kitchener has a large proportion of both greenfield land and intensification
opportunities, both of the targets have potential implications for us. Several years ago,
these numerical targets required significant resources to study the implications to our
region and city. Discussion about the distribution and implementation of these targets at
the local level remains ongoing. Significant changes to the targets will no doubt require
continued attention and resources.
With some of these proposed changes to the framework, intensification level and
density targets, we may have to revisit our sanitary sewer capacity analysis for some
areas of the city to confirm (the Urban Growth Centre and PARTS areas are aligned but
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other areas may need to be re-investigated). The City’s positive step of improving the
sanitary and other infrastructure systems through the accelerated infrastructure renewal
program is assisting with accommodating the intensification that was planned; however,
there may be instances where infrastructure costs could influence where the more
appropriate areas are to intensify.
The implementation of climate change plans, asset management plans, stormwater
management plans, etc. are going to require substantial resources, shifts in practice
and long-term financial requirements. Also, there are further policies about new and
reconstructed streets to utilize a ‘complete streets’ approach and the potential cost
implications of ensuring that infrastructure has the capacity to accommodate growth in
certain areas.
When reading the policies in their totality, there appears to be somewhat of a
diminished role for the local municipality. This should not be the case and be revisited
as local municipalities play a major role in how growth is managed, including the
comprehensive integration of infrastructure, transportation, environmental, financial,
public service facility and other considerations with land use planning.
In the future, we are going to have to amend our new Official Plan (and possibly other
related plans and supporting tools) to further conform to the proposed Growth Plan
changes. This is expected to most likely occur after the next Regional Official Plan
review as there are many policies directed at the upper-tier that would need to be
coordinated for lower-tier implementation thereafter.
ALIGNMENT WITH CITY OF KITCHENER STRATEGIC PLAN:
Strategic Priorities: Strong and Resilient Economy
Safe and Thriving Neighbourhoods
Sustainable Environment and Infrastructure
FINANCIAL IMPLICATIONS:
Provincial policy regarding growth planning increasingly has more emphasis on
ensuring that growth is financially viable and supportable for municipalities. The
proposed changes to the Growth Plan include several policies that deal with appropriate
locations for growth needing to ensure that infrastructure and public service facilities
have to be financially viable over the full life cycle of the asset. Depending upon the final
wording of the Growth Plan and the implementation thereof, there could be several
aspects that could have implications to future capital projects. This includes the
direction to use a ‘complete streets’ approach to the design or reconstruction of the
existing and planned street network.
Additional work, projects or master plan updates may be required in the future to fully
implement the proposed Growth Plan and subsequent Regional and Local Official Plan
updates. This may require significant allocation of staff time in the coming years.
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COMMUNITY ENGAGEMENT:
INFORM – This report has been posted to the City’s website with the agenda in
advance of the council / committee meeting.
City Planning staff met with representatives of the local municipalities, the Region of
Waterloo and the Grand River Conservation Authority to discuss the proposed changes
in advance of preparing reports and providing comments to the province. Planning staff
also provided an update to the Waterloo Region Homebuilders Association Liaison
Committee meeting in July. It is expected that the development industry and other
stakeholders will identify significant issues with the proposed Growth Plan and will
comment directly to the province.
CONCLUSION:
The principles and general policies of the proposed changes to the Growth Plan
continue to provide positive direction for managing growth and shaping more healthy
communities. More consideration is required regarding the details of what the amended
policies and definitions mean at the municipal level. There will be some resource
impacts.
Municipalities do have some struggles though with implementing these provincial
policies and we constantly deal with the “on-the-ground” implications. Will the province
support municipalities to overcome obstacles and provide more tools and resources to
move forward through implementation? Also, without Ontario Municipal Board reform
and provincial support in defending provincial policies at the Board, municipalities may
have some constraints as to the extent and timeframe that they can implement
provincial plans.
REVIEWED BY:
Tina Malone-Wright, Senior Planner
Natalie Goss, Senior Planner
Richard Kelly-Ruetz, Student Planner
ACKNOWLEDGED BY:
Michael May, Deputy CAO (Community Services)
Attachments:
Appendix A – Additional Comments on Proposed Growth Plan Changes
Appendix B – Link to Proposed Growth Plan (.pdf or track changes version):
(https://www.placestogrow.ca/index.php?option=com_content&task=view
&id=420&Itemid=12)
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Appendix A
Additional Comments on Proposed Growth Plan Changes
Section 1 - Introduction
1.2.1 Guiding Principles
These provide a strong indication of the vision and direction for our communities.
The emphasis on ‘complete communities’ is important to carry forward and strengthen.
Any further strengthening of the importance (economically, environmentally, socially,
culturally) of prioritizing intensification and a compact, urban form for a healthy
community is appreciated.
The identification of enhancing the linkage between land use planning and investment in
infrastructure and public service facilities is quite important and increased attention
needs to be given to this for all levels of government.
The continued emphasis on our natural heritage system, along with the need to
conserve our cultural heritage resources is what will help make our communities more
livable and enjoyable.
The integration of climate change considerations and resilient infrastructure is noted last
in the guiding principles and perhaps should play a more prominent role with stronger
language (throughout the document).
1.2.3 Horizon
Extending the time horizon of the plan could be problematic for municipalities that are
still dealing with the implications of implementing the current Growth Plan and
considering that (in our case), the population forecasts are high.
The first two statements in the second paragraph of this subsection are quite important
and can often be utilized to pose significant growth management challenges at the
ground level. Planning certain infrastructure (and that it can be planned beyond a 2041
horizon) will have some predetermination of form, pattern and extent of future
settlement areas and pressures. These statements need to be further considered and
how that would be ensured.
Planning for the long term protection of employment areas beyond the horizon of the
plan without designating them will be interesting as to how that is best accomplished
Section 2- Where and How to Grow
2.1 Context
The introduction of “net zero communities” is a step in the right direction to prepare
ourselves for the bigger and broader shift that we need to make in our communities.
Changing terminology, such as “strategic growth areas” instead of ‘intensification areas’,
may be a bit problematic for alignment and consistency (although we can see the intent
to change the view or connotation of what the word ‘intensification’ conveys to some).
“Transit as a first priority” is a very important principle.
2.2.1 Managing Growth
These remain good principles and policies. (see comments above re: population growth,
complete communities and climate change/net zero communities). These policies are
generally aligned with how Kitchener manages growth.
Perhaps 2.2.1.2 should include a statement about accommodating growth in a fiscally
responsible way (mentioned elsewhere but should also be stated here).
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2.2.1.3 f) green infrastructure and low impact development as part of complete
communities is helpful policy direction that aligns with Kitchener’s policies and new
stormwater management approach.
2.2.1.3 g) high quality built form and site design standards that create an attractive and
vibrant public realm cannot be stated enough as it is a critical aspect of growth and
intensification but also at the local level is often a significant and ongoing challenge and
struggle.
2.2.1.3 – suggest adding a statement to this section, the Built-up Area or other
applicable section about intensification that supports subwatershed objectives and
restoration of watercourses.
2.2.1.4 – additional information on the policy would help. We presume this intends that
an upper and single tier municipality should have a growth management strategy based
on the listed items and is to be embedded in their Official Plan. Considering the “full life
cycle costs” of infrastructure and public service facilities is quite important for good
growth management. The “direction to lower-tier municipalities on how to implement the
approach” may be of some concern.
2.2.1.5 – most high-level pressures on adhering to good growth management principles
stems from land needs. Any further information on the expected process, timing and
content of the Minister’s land needs methodology would be appreciated.
2.2.1.6 - what is the intent behind why there would be an identification of ‘excess lands’
in an Official Plan and prohibit development to the horizon.
2.2.2 Built-up Areas
We need to further consider the implications of the proposed policies related to the
timing and increase of the intensification level to a minimum of 60 %. We are currently
dealing with local level implementation of the previous target. Our understanding is that
the new approach would not occur until after the next Regional comprehensive
review/Official Plan update.
2.2.2.5 Intensification – the clauses identified in this policy about the type and scale of
development in growth areas, transition of built form, high quality urban form and public
spaces are quite critical to successful integration of new development in existing areas.
Residents of many municipalities, including Kitchener, continue to have some challenges
regarding intensification in existing built-up areas.
2.2.3 Urban Growth Centre
There does not appear to be many changes in this section. Kitchener has established a
minimum target of 225 residents and jobs per hectare in our new Official Plan (which
would be our target as per 2.2.3.4).
2.2.4 Transit Corridors and Station Areas
Showing priority transit corridors in Official Plans is important. It is not clear if this is for
both upper and lower tier plans. In Kitchener, we have used this as one of the key
elements of our urban structure. One minor issue is that there is slightly different
terminology.
2.2.4.3 – we may have some issues with the intent and how this proposed policy is
worded. In Waterloo Region, the local level municipalities are conducting planning in
major transit station areas and we are delineating them in our Official Plans/creating
Secondary Plans. It should not be ‘in consultation with lower-tier municipalities’. The
wording should allow local municipalities to do this.
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2.2.5 – the targets within the policy are generally aligned with the minimum targets we
have been using for station area planning in Kitchener (and it based in other transit
supportive density work). What could be problematic is the stipulation about 2041 or
earlier. How can a municipality fully make all the development happen within multiple
areas by a specified time frame? There are so many factors and some can be
influenced, but not all. The plan can be done for the horizon; however, at some locations
it may be long-term before full redevelopment/build-out is realized. Also, certain portions
of station areas should be excluded from the calculation such as stable neighbourhoods,
floodplains, etc.)
2.2.7 – most of the items in this proposed policy are reaching into the local level. It is
unclear what “planning in a timely manner” means.
2.2.9 – establishing minimum density targets for lands in strategic growth areas so that
they are transit-supportive is good planning. We will need to revisit recent growth
management, the Official Plan and other work to determine what aspects of our
approach will need to be updated beyond what we recently prepared.
2.2.10 – the province may identify priority transit corridors and hubs? It would be helpful
to know a potential example of this, the involvement of municipalities and the
implications. We would assume it would be a fairly major location of provincial interest.
2.2.5 Employment
There is now a distinction between “employment areas” and “prime employment
areas”. The direction is that prime employment areas should be planned around
vicinity of, major goods movement facilities and corridors (freight-supportive patterns,
major highway interchanges).
We will need to further investigate and confirm what land in Kitchener meets the new
definition for “prime employment area”.
Through the creation of the two categories, it would appear as though the intent is to
‘tighten up’ what was believed to be intended by the PPS definition for employment
area. There still remains some uncertainty with the proposed Growth Plan definition
for “employment area” and the associated policies. Perhaps the PPS definition will
need to be revisited?
The wording of 2.2.5.6 for “employment areas” is definitely not as strong as 2.2.5.5
for “prime employment areas” and could have significant implications. These
locations need to be protected for the long term and commercial, institutional and in
some instances office uses need to be directed elsewhere or in locations in the
vicinity that are complementary to but do not take away from, industrial/employment
uses.
We also note that a policy may have been removed regarding major retail uses being
considered a non-employment use. The assumption is that this is due to other
definition and policy changes; however, this topic is still unclear.
Prime Employment areas are prohibited from conversion to non-employment uses.
Employment areas can convert to non-employment uses with a municipal
comprehensive review. It is important to maintain in the Growth Plan that a local
municipality can conduct a municipal comprehensive review – which would be
appropriate in the case of considering employment land use designations for an
Official Plan.
The changes proposed to “major office” also have significant implications. The
appropriate location for office and “major office” was an important consideration in
our recent Official Plan that balances where industrial employment or other uses
should be maintained. Significantly reducing the size of “major office” will have
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impacts, and although important to direct to the locations identified in policy 2.2.5.9,
there may be some other appropriate locations or strategic places along transit
corridors within an employment area to integrate the use (without it being a complete
“office park” which is also a new added element to the plan).
We will need to further consider the proposed policy changes with respect to our
local policy direction.
Overall, there are significant issues with the policies and definitions of this section.
2.2.6 Housing
This section includes the direction regarding an upper-tier housing strategy and policies
in official plans for affordable housing targets. Confirmation of how 2.2.6.1.b) relates to
the changes proposed via Bill 2014 (Promoting Affordable Housing Act) would be
helpful.
2.2.6.2 – there may be significant implications regarding this notwithstanding the PPS
policy and it could potentially be contradictory to other policy direction in the plan.
Planning to accommodate a forecasted growth that is likely high for our area and into a
horizon that is beyond the PPS requirements could put some pressure on our
municipality.
2.2.7 Designated Greenfield Areas
2.2.7.2 (minimum density target)
Although we have some assumptions, we would like clarification as to why
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“within the horizon of this Plan” is added to the policy. It may further add to some
challenges in the implementation process.
The timing of actual development is influenced by many factors beyond a
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municipal approved plan for a certain density target. This is especially true for
apartment blocks which may take up to or beyond the horizon to fully build out
and there presumably would have to be more of them as the required density
increases.
We do note that a good way to achieve a desired density target is through mixed
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use buildings, commercial/office uses, stacked townhouses and other low rise
forms of multiple dwellings.
Further confirmation may be needed but it is assumed from this and other
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policies in the plan that a new greenfield density target would take effect
immediately upon approval of the plan and could apply to unapproved plans. We
suggest that any Secondary Plans that have been approved prior to the new
Growth Plan should continue to see development proceed in accordance with the
minimum density that was intended in such plans (i.e. the Rosenberg Secondary
Plan in Kitchener).
As a community builds out under different planning frameworks, there is an
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interesting level of density that could be observed in changes to the urban fabric
from the post-war subdivisions, to those in the 80s/90s into the 2000s and then
those occurring now under the current density targets. Having the further
suburban fringe with a higher density than the earlier areas may not be as
desirable unless transit and other community infrastructure could equally be as
available.
We will need to further consider the detailed implications of a proposed shift of
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greenfield density requirements to 80 residents and jobs per hectare. Perhaps
the outer ring (with an urban growth centre) should have a policy that considers
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an alternate target that is somewhere between the existing and proposed higher
target.
2.2.7.3 (take-outs)
In some areas, including Kitchener, there are many objectives regarding
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stormwater management, groundwater infiltration, along with local level natural
and cultural heritage conservation that impact the net development of land.
Although there are some proposed changes to the land that can be excluded
from the density calculation, not all objectives will be fully captured in the
definitions and thus the density of the developable area will be higher than that
stipulated in the target.
The inclusion or exclusion of ‘buffer areas’ to natural heritage features requires
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further confirmation.
Cemeteries should be a take-out exclusion.
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Further detailed review will again be required to confirm what this means for
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remaining “developable land” and the implications within Kitchener.
2.2.8 Settlement Boundary Expansions
The direction in the PPS regarding consideration of intensification supply first should be
further considered in the approach to these policies
The policy relies on the land needs assessment to be provided via the Minister. As such,
any additional information regarding the methodology would be of assistance to further
understanding the implications of the settlement area policies.
It would be interesting to further discuss and understand the mechanisms for how a
settlement area expansion to add more greenfield land supply would not adversely affect
the future achievement of the intensification level target.
2.2.8.b) – the clause about the financial viability over the life cycle of infrastructure and
public service facilities is a crucially important criteria for managing growth and should
be carried forward in the final version of the plan
2.2.8.f) – is ‘where possible’ needed?
2.2.8.3 – further consideration is needed regarding the concept, policies and implications
of ‘excess lands’. It is unclear why identifying additional land that can’t be developed in
the horizon of the plan is needed. Is there criteria? Appeals? Perhaps this should be
scoped to mostly relate to minor boundary adjustments/rationalizations?
Section 3 – Infrastructure to Support Growth
3.2.1 Integrated Planning
This is a very important section. Although many municipalities, such as Kitchener, strive
to integrate infrastructure planning and investment with land use planning through
growth management and other actions, it is quite important to have this provincial plan
state the need.
There are many implications and possibilities with these policies.
3.2.1.2 – Kitchener has expended efforts on many of the items identified
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including infrastructure master planning, asset management, community energy
plan, watershed planning, financial planning, etc. There are many inherent
challenges with each initiative. Additional support and funding from the province
assists in leveraging and achieving the greatest implementation.
3.2.1.2.a), 3.2.1.3 and 3.2.1.5 – Provincial investment in transit and inter-regional
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transportation could significantly contribute to the further achievement of growth
and development within our downtown/urban growth centre and other strategic
growth areas
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3.2.3.b) – Kitchener has investigated and modelled infrastructure capacity for
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growth areas, primarily based on the current intensification area direction and
now for major transit station areas. Should the changes to the Growth Plan lead
to further refinement or direction for these (or new) growth areas, we may have to
revisit this work (which will require resources)
3.2.3.c) – regarding the full life cycle costs of infrastructure, we continue to build
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up our asset management and infrastructure replacement program. Paying for
the costs over the long-term remains a major issue. Provincial and other support
in this endeavour is crucial.
3.2.3.d) and 3.2.1.4 – considering the impacts of climate change and assessing
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the resiliency of infrastructure and needed efforts and important policies to
include. Having said that, the assessment could be resource intensive and the
resulting recommendations could have big cost implications for municipalities
and new development.
3.2.2 Transportation
Similar to the link between infrastructure and land use planning, the coordination with
transportation system planning has become more evident and prevalent in contemporary
growth management practice and city building efforts.
3.2.2.2.b) – the provision of ‘transportation choices’ is so critical for the environmental,
social, health, transportation, economic, etc. benefits that this directive should be
highlighted significantly more in the earlier sections and principles of the plan. This is
what will help shape our future communities.
3.2.2.3 – many municipalities are adopting the complete streets approach. Those
involved in the design and reconstruction of the street network have identified significant
challenges within a right-of-way or financially to utilizing this approach in all
circumstances. It is important to maintain this direction; however, perhaps some
flexibility at the local level should be considered.
3.2.2.4 – Kitchener has had transportation demand management type of policies in our
Official Plan since 1984 with an updated section in our new Official Plan. The actual
application and implementation of these practices in new development and in municipal-
led projects is now starting to take shape. Additional funding for cycling and pedestrian
infrastructure and promotion programs is always welcome.
3.2.3 – the words ‘land use planning’ should be added to 3.2.3.1. It is important that
public transit be a high priority. Walking and cycling should remain high priorities for
transportation infrastructure planning and are often the first and last part of the trip for
transit usage.
3.2.3.1 – the principles of the criteria listed in this policy are generally sound and
supportable; however, further consideration may be needed as to the potential
implications of ‘all’ decisions adhering to the criteria.
3.2.3.4 – ‘land use planning and development’ should be added to this important policy
about active transportation network integration.
3.2.5 – it is assumed through the definition of planned corridors that these policies
involve provincial-related infrastructure. It is slightly unclear as to the inclusion of upper-
tier municipalities.
3.2.6 Water and Wastewater Systems
For the most part Waterloo Region and Kitchener have been practicing good
approaches to ensure the long-term viability of the quality and quantity of our water
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system along with continual improvements to our wastewater system. Many of the
policies in this section will be helpful for many areas of the province.
It would appear that the direction for watershed planning is more related to ‘water’ supply
and not exactly comparable to the subwatershed planning that is utilized in our area
which covers more aspects of water management and ecological functions.
3.2.7 Stormwater Management
The policies in this section appear to be in line with other provincial direction and
aspects such as low impact development and green infrastructure are supportable. This
section could also include mention of climate change which will have ramifications for
stormwater master plans and infrastructure.
Kitchener has recently completed an updated master plan policy which based on our
understanding appears to be aligned with the proposed policies of the Growth Plan
(including incorporating low impact development techniques and stormwater retrofits).
The resultant impact of following through with these policies and master plans
(especially regarding full life cycle costs and maintenance costs) means significant
financial costs. This can be a major hurdle in moving forward quickly to respond to an
increasing risk. Most master plans will result in numerous capital projects that will take
time to complete.
3.2.7.2 – this provincial policy is starting to get quite far into the municipal development
process.
3.2.8 Public Service Facilities
We assume that public service facilities is an evolution of community infrastructure from
the current plan.
The planning and priority of this topic is crucially important to integrate into how our
communities grow and have a high quality of life. This topic perhaps should be a more
prevalent role in the plan and perhaps moved forward in the document instead of being
the last portion of Section 3.
A “community hub” should be defined.
It is important to link the timing and financial viability of these facilities with the timing and
type of growth.
Section 4 – Protecting What is Valuable
The proposed Growth Plan distinguishes between “key hydrologic area” (significant
groundwater recharge areas, highly vulnerable aquifers and significant surface water
contribution areas) and “key hydrologic feature” (permanent and intermittent streams,
inland lakes, seepage areas / springs and wetlands). The difference is between
components of a groundwater / drinking water system (“area”) versus the water-
dependent components of a natural heritage system (“feature”).
Kitchener, Waterloo Region, the GRCA and the local development industry have a
history of subwatershed planning and conserving our water and natural systems. We will
continue to review and consider the terminology and policies of the plan with respect to
“watershed planning”, “key hydrologic areas” and “key hydrologic features”.
It would appear as though many of the policies within sections 4.2.1 to 4.2.4 are aimed
at locations outside settlement areas and thus the PPS would continue to be relied upon
for locations inside settlement areas.
The proposed policies would possibly strengthen our ability to manage rural / agricultural
development in and adjacent to Natural Heritage and Water Resource systems which
would be in a small part of Kitchener.
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Any further policy direction regarding the management and ecological improvement of
watercourses within the Built-up Area (including strategic growth areas) would be of
assistance.
There may be some uncertainty with respect to the alignment of the Cultural Heritage
Resource policies of 4.2.7 with the PPS.
4.2.9 Culture of Conservation – these policies are quite important and supportable. Our
new Kitchener Official Plan includes dedicated sections regarding water and energy
(along with waste and other) conservation. Any additional strength in wording to help
with implementation is appreciated.
4.2.10 Climate Change – these policies also reflect the direction that our municipality,
region, province, nation and global initiatives are striving towards. The policies do
provide an added push. One of the major implications of implementing the climate
change plans and greenhouse gas emission reduction targets is the significant cost and
resource implications of making the major, big moves.
In this section there are no specific policies reference the relationship between climate
change mitigation and natural heritage conservation (vegetation as a carbon sink) or
climate change adaptation and natural heritage and water resource conservation
(cooling in urban heat island, flood protection, water supply protection); it is just
generally discussed in the preamble.
Section 5 – Implementation and Interpretation
5.2.2 Supplementary Direction
Please confirm the expected timing for c) standard methodology for land needs
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Please provide further information about the province proceeding with identifying
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prime employment areas and what “where necessary” means
Please confirm what is meant by the province establishing planning requirements
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for priority transit corridors means. The assumption is that it is the policies of the
plan and perhaps supplementary transit supportive development guidelines.
The province will be identifying the Natural Heritage System outside settlement
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areas where the protective polices controlling development and/or site alteration
would apply (Sections 4.2.3 and 4.2.4) within and adjacent to key features. The
scale and implications of this work will need to be further understood. Although
there is only a small portion of Kitchener to which this may apply, we should have
some involvement in any mapping exercise that the province may be undertaking
with respect to the natural heritage system. We recently completed our Kitchener
Natural Heritage System which would covers the whole of the city, includes key
provincial and other features, and is reflected within mapping and policies of our
new Official Plan. We can provide the necessary information as needed.
5.2.3 Co-ordination – the lower tier municipality has direct responsibility for land use,
design, in many cases development approval authority, and our local plans identify
growth areas such as nodes and corridors. As a result, we should have a higher priority
role regarding the establishment of density targets for strategic growth areas and
intensification targets than what is indicated in 5.2.3.2.
5.2.5 Targets – we generally understand and support these policies.
5.2.6 Indicators and Monitoring – we have been monitoring implementation of several
aspects of the growth plan for many years now. It would be of further assistance to have
any guidelines, standards or reporting requirements from the province.
Consideration should be given to municipalities that are still in the process of dealing
with appeals and deferrals of matters that relate to the 2006 Growth Plan implementation
being able to complete the initiatives prior to the enactment of new requirements.
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Definitions
Community Hub – suggest adding a definition for this term referred to in several policies.
Complete Communities - suggest replacing “neighbourhoods” with “areas”.
Excess Lands – this statement does not seem like a good planning principle.
Greyfields – would this include former institutional properties that may also be
characterized as underutilized, derelict or vacant or should that have its own term
(possibly referred to as “bluefields”)
Key Hydrologic Areas, Key Hydrologic Features and Key Natural Heritage Features – we
will need to continue to review these definitions and associated policies to further
understand the implications along with having clarity of what aspects of the natural
heritage system are and are not included.
Large-scale Development – it would be helpful to have a definition added for this term if
it is to be included within a policy of the plan.
Major Office – the revision to a much lower size (from 10,000 to 4,000 square metres)
and number of jobs from 500 to 200 for office buildings is problematic. It should be clear
whether this is for an individual building or a cluster of office buildings. Also, the ‘jobs’
component is not practical and difficult to measure. This is especially the case when it
comes down to encoding within a Zoning By-law or dealing with a specific site. There are
part-time employees, changes in the space utilization per employee, etc that are difficult
to track and too resource intensive. The jobs component should be eliminated from the
definition.
Major Retail – this definition does not go far enough to clarify matters (one building or
multiple building?, size?).
Municipal Comprehensive Review - *this definition needs to include a lower-tier
municipality.
Significant woodlands are not mentioned within any definition regarding natural heritage.
Prime Employment Area – including wording such as “and appropriate associated uses”
is too broad and could pose challenges.
Priority Transit Corridors – we assume these do not necessarily need to be “emerging”
but could be existing corridors.
Strategic Growth Areas – what would include “other areas that have been identified by
…the Province”? Is this perhaps referring to Urban Growth Centres or are there other
areas?
Schedules
Schedule 3 – Distribution of Population and Employment
The Region of Waterloo and local municipalities should be further consulted with
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regarding the longer term projection figures. Including estimates that are too
high and/or in a future horizon such as 2041 could be problematic. The
implications could drill down to the preparation of Development Charge
studies/by-laws that utilize this information as an anchor to establishing the
charge and may ultimately lead to potential financial shortfalls and impacts to the
timing of infrastructure to support growth. Often in our area, population figures
are somewhat high and employment numbers are low (especially given that our
area is one of the prime economic engines in the province).
Schedule 5 – Moving People – Transit
This is a major step forward to indicate a Future High-Speed Rail Corridor and
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we are excited to work with the province on bringing this plan to reality.
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