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The Corporation of the Township of Brock

Clerk's Department

Planning / Economic Development Co-ordinator to the Planning Committee

Report: 2016-PL-07

Date: Monday, October 24, 2016

Subject

Co-ordinated land Use Planning Review - Comments for Proposed Plans

Recommendation

That the Planning Committee receive this report for infonnation and that it be submitted to the Ministry of Municipal Affairs as the Township's fonnal comments with copies to the Regional Planning Department and the area municipalities.

Attachments

Attachment No. 1: Report 2015-PL-02 Attachment No. 2: Regional Official Plan Schedule 'B' - Map :~.tai ... . . .

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Background

Four provincial land use plans work together to.. provide policy direction for Ontario's Greater Golden Horseshoe (GGH) and the Niagara Escarpment area:,the Growth Plan for , the Greater Golden Horseshoe (Growth Plan), the Gr_eenbelt Plan, thEt O~.k Ri4.9es . : Moraine Conservation Plan, and the Niagara Escarpment Plan. "the.Province initiated a co-ordinated review of these plans in 201s. Members-:ot;' the P.t.Jblic:--stakehotders, municipalities, organizations, and Indigenous communities were given opportuhitfes fo" provide feedback relating to the perfonnance of the plans and how the planscoutd tie improved. The Province appointed an advisory panel, chaired by David Crombie, to assist with the co-ordinated review. The panel attended public meetings, reviewed submissions, and consulted with stakeholders and experts. In December 2015, the advisory panel provided a report containing recommendations specific to improving the plans. Taking these recommendations and all other feedback into consideration, the Province released changes to the four plans in May 2016 and has requested comments by October 31, 2016.

This report is available in alternate formats upon request.

Please contact the Clerk's Department at 70&-432-2355.

As the Township of Brock is only subject to the Growth Plan and the Greenbelt Plan, the focus of this report will be dedicated to them. The report will provide a summary of the proposed changes to these plans, analyze previous Township recommendations In relation to the proposed changes (Attachment No. 1), and provide comments for Provincial consideration.

To assist in the preparation of this report staff attended a technical briefing sponsored by the MMA in June, 2016 and consulted with the Region and the area municipalities at a meeting held in August, 2016. In addition, the Mayor and staff attended a GTHA Summit, hosted by Hazel Mccallion, on September 30, 2016 to hear presentations on the contents of the revised Plans from a member of the Regional Planning Commissioners of Ontario. a member of the Crombie panel, and the Principal of Malone Given Parsons. All participants were provided the opportunity to identify issues related to the Plans and the collective impact on each municipality.

Overview of Proposed Changes

Overview ofProposed Growth Plan and Greenbelt

In order to better coordinate both plans with the Provincial Policy Statement and with one another, the policy framework, terminology, and definitions among plans would be streamlined and aligned

New goals for settlement areas would encourage the development of complete communities that support the ultimate goal of becoming net-zero communities

Municipalities would be required to facilitate the development of community hubs in order to achieve thfs

The development of complete communities and net-zero communities would require municipalities to integrate climate change considerations into the planning of settlement areas

The revised tenn, complete communities, would refer to mixed-use places with an increased emphasis on accessibility that offer and support a variety of jobs, stores and services, and a full range of housing and public facilities

The new term, net-zero communities, would refer to energy efficient communities that rely on low-carbon forms of energy

Settlement areas of the Greenbelt Plan would be subject to the policies of the Growth Plan

Proposed Growth Plan

The minimum intensification target for all upper- and single-tier municipalities would be increased from 40 per cent to 60 per cent at the time ofthe next municipal comprehensive review

The designated greenfield area density target for all upper- or single-tier municipalities would be increased from 50 to 80 residents and jobs combined per hectare

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Density target measurements would exclude areas such as natural heritage features and areas, rights-of-way for certain infrastructure, and prime employment areas

Alternative targets would only be available for upper- or single-tier municipalities located within the outer ring of the GGH that do not have an urban growth centre (i.e. County of Northumberland, County of Peterborough, City of Kawartha Lakes, City of Orillia, County of Simcoe, County of Dufferin, County ofWellington, County of Brant, and Haldimand County)

Municipalities would be required to identify and designate prime employment areas for uses that are land extensive and have low employment densities

Prime employment areas would be protected over the long-term with limited permitted uses and conversion of these lands for non-employment uses would not be permitted

Municipalities would also be required to designate employment areas that support a wider range of employment uses

Existing criteria for the expansion of municipal water and wastewater services would be increased by placing an emphasis on watershed planning which would integrate master planning with infrastructure planning

Proposed Greenbelt Plan

Settlement area boundary expansions for towns/villages (Beaverton, Cannington, Sunderland} would be pennitted in accordance with the requirements of the Growth Plan as opposed to the existing 10-year review period

The Province would be encouraged to continue exploring opportunities for growing the Greenbelt

The Province would be able to identify potential areas to be added to the Greenbelt in order to further protect sensitive areas from development pressures and municipal support would not be required to add identified areas

The introduction of the Urban River Valley designation would protect key river valleys in urban areas and connect the rest of the Greenbelt to the Great Lakes and other inland lakes

This designation would only apply to publicly owned lands within the main corridors of river valleys and associated lands (e.g. Camrthers Creek, Duffins Creek, Rouge River)

The introduction of a new term, on-farm diversified uses, would permit agrl-tourism uses on farms

Flexibility for larger sized agriculture-related uses within the Protected Countryside would be permitted (e.g. farm-related commercial and industrial uses such as local farm product retailers and grain dryers)

The agricultural system would be updated to include an agricultural support network which would refer to the infrastructure, services, and assets that support the whole system in addition to the land base

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In order to avoid adverse impacts, the completion of an agricultural impact assessment would be required when non-agricultural uses are proposed In specialty crop areas and prime agricultural areas that would evaluate potential impacts and suggest ways to avoid or at least mitigate adverse impacts

New buildings and structures dedicated for agricultural, agriculture-related, or onfann diversified uses, would be exempt from completing a natural heritage or hydrologic evaluation (subject to meeting criteria)

General Comments

Natural Heritage/Hydrologic Evaluation

Under the existing policies of the Greenbelt Plan, a proposal for new development or site alteration within 120 metres of a key natural heritage or hydrologic feature requires the completion of a natural heritage or hydrologic evaluation. However, the proposed Plan would include a new policy that exempts new buildings and structures from this evaluation if they are dedicated for agricultural uses, provided the proposed development meets the following requirements:

new buildings or structures are required to provide and maintain a 30 metre vegetation protection zone from a key natural heritage or hydrologic feature;

connectivity between key natural heritage and/or hydrologlc features must be maintained;

new buildings or structures must be located as far away as possible from the key feature and if possible, clustered with existing development;

measures must be put in place for stormwater management and erosion control; purpose, size and scale of the development as well as the sensitivity of the nearby

feature(s) need to be considered in order to determine any potential impacts of the proposal.

It is noted that the Township contains numerous key natural heritage and hydrologic features all of which are linked as part of the Greenbelt Natural Heritage System (Attachment No. 2)

Despite the intention of the new policy, the extent of requirements that must be met would demand a considerable amount of time and planning similar as to what would be required for completing an evaluation. It Is acknowledged that the Province is seeking clarification, but the proposed criteria essentially limits the Intended flexibility and almost defeats the purpose of the exemption.

Increased Targets

The proposed Growth Plan would increase the minimum intensification and density targets for upper- or single-tier municipalities. Proposed changes to both Plans encourage the development of complete communities and net-zero communities. While it is understood that inaeased density and complete communities promotes smart growth, these polices are much more appropriate for urban municipalities. Increased intensification, reliance on

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transit, and development of community hubs in support of developing complete and energy efficient communities is not practical In small rural municipalities like Brock.

The targets serve as comprehensive targets that are meant to be achieved at the uppertier level. In order to achieve these targets, the Region will have to allocate specific targets amongst the lakeshore municipalities.

Regional and area municipal staff from the lakeshore communities have confirmed that the intended intensification and density targets will not likely be achievable. Achievement of these targets on a Region-wide basis will likely require much higher targets in the designated growth centres of Pickering and Oshawa. Furthermore, much of the land draft. approved for development in the southern municipalities has been planned for the existing targets but not yet built-out.

This is compounded by the lack of a consistent methodology to calculate a land needs budget across the GTHA. The transition policies would require compliance with the increased density and Intensification targets immediately upon adoption; however, development of a consistent methodology is not anticipated to commence until 2018. In addition, the increased targets will create financial pressures on lower and upper-tier municipalities to provide necessary hard and soft services. Under existing financing measures afforded through the Development Charges Act, existing ratepayers will become responsible for a portion of the additional costs.

It would appear as though the Province has not considered the unique characteristics of each Region in the development of this one-size-fits-all approach. Accordlngly, the intended targets are not feasible nor are they supported.

Challenges in Brock

The requirements of the Growth Plan to promote intensification require the provision of municipal water and sewage services. While there are no apparent constraints in Beaverton, both Cannington and Sunderland (post Fairgate Homes and Kaitlin Corporation developments) require servicing enhancements to support the objectives of the Growth Plan.

The agricultural areas in-between do not provide opportunities for development and the proposed amendments to the Greenbelt Plan do not appear to provide opportunities beyond what exists at present. The Greenbelt Plan does provide for some opportunities within their rural lands designation; unfortunately, those lands within Brock are designated within the Region's Major Open Space System and contain numerous constraints to achieve practical development opportunities.

Collectively, the impact of both Plans places a continuing financial burden on the Township. It is further compounded by additional layers of legislative requirements imposed by Source Water Protection and the Lake Simcoe Protection Plan.

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Specific Comments

Recent ORGA/ROMA and AMO conferences have given the Township of Brock the ability to present various recommendations to the Province and address specific municipal concerns. The co-ordinated review also provided Brock with the opportunity to provide feedback on these plans. Much of this feedback echoed previous comments and recommendations.

Natural Heritage Syst.em

Within the Greenbelt, the Natural Heritage System is composed of core areas and linkage areas with the highest concentration of the most sensitive or significant natural features and functions. However, linkage areas do not necessarily include any natural heritage features. As a result of this, agricultural lands without any specific features are subject to stringent regulations which limit the ability of a fanning operation.To avoid this unintended negative impact. the Township previously recommended that the Greenbelt Plan provide more accurate mapping for the Natural Heritage System. specifically in regard to the linkage areas.

After reviewing the proposed Plan, it appears that no changes have been made to the Natural Heritage System mapping. While it is acknowledged that protecting linkage areas is important, In some cases it is preventing agricultural lands from being actively farmed. It remains suggested that the Province reconsider the mapping for the linkage areas. A heavier reliance on field work. and site-level ground-truthing as opposed to aerial photography is recommended to accurately define such features.

Settlement Area Adjustments

The Township previously recommended that the Greenbelt Plan include policies related to settlement area adjustments. These adjustments would allow for the transfer of undevelopable lands within a settlement area for devetopable lands adjacent to the settlement area. Such transfer would be an equal exchange that would not result in an overall net gain in order to avoid expansion. Portions of the Township's existing settlement areas are constrained by natural features which render these lands undevelopable.

The existing Greenbelt Plan provides for modest settlement area expansions for towns/villages at the 10-year review period. The Region confinned that, on the whole, there was sufficient designated land, specifically in reference to Beaverton, to accommodate the growth forecast Unfortunately, this holistic approach does not recognize the Mure viability of each urban area and prevents expansions where localized demand is becoming apparent (I.e. Sunderland}. This concern has been expressed to senior political and staff representatives of the Region. The proposed Plan would permit upper- or single-tier municipalities to expand settlement area boundaries as part of a municipal comprehensive review in accordance with the proposed Growth Plan. Policy direction in both of the proposed Plans does not speak to any settlement area adjustments or transfer/exchange of lands in the absence of a municipal comprehensive review.

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Demonstrating the need for a settlement area expansion would be a very difficult process considering the limited growth and servicing capacity constraints within the Township. Therefore, it Is recommended that provincial policy provide the ability for municipalities to make minor modifications to settlement areas where no expansion would result. It is appropriate that municipalities be provided autonomy to plan for their own future with respect to urban area boundaries. The ability to make appropriate adjustments would assist the Township to achieve the objectives of the Growth Plan.

Highway 404 Extension/Employment Amas

Despite the approval of an environmental assessment that would extend Highway 404 to the Highway 12/48 junction, the Province has not committed to an extension north of Ravenshoe Road. The planned extension of Highway 404 beyond Ravenshoe Road has never been included within the Growth Plan. This future extension would create a major highway corridor network to service the amicipated growth in the Township as a result of favourable house prices relative to other municipalities in the GT A as \Yell as present employment land opportunities. However, the Growth Plan limits the designation of employment lands to fully-serviced settlement areas. Considering the most effective industrial and commercial land is not necessarily located within settlement areas, this limits economic development opportunities within rural municipalities. Highway commercial and rural Industrial uses are common in rural municipalities and play a key role in supporting the local economy.

In January 2012, an amendment was made to the Growth Plan which introduced section 6, the Simcoe Sub-area. The Simcoe Sub-area refers to a geographic area consisting of the County of Simcoe, the City of Barrie, and the City of Orillia. The policies of section 6 identify four unique employment areas. With this amendment, the Province acknowledged the significance of rural employment areas within the vicinity of highway corridors.

Since being introduced, these specific employment policies have not been applied to any other areas outside of the Simcoe sub-area. Due to this, the Township previously recommended that the Simcoe sub-area amendment be applied to other areas within the GGH or that the Growth Plan be amended to enable an employment land designation outside of settlement areas. This would present Brock with the opportunity to designate employmem lands in proximity to the Highway 12/48 junction in anticipation of a future Highway 404 extension as identified in the Township's Potential Rural Employment Areas report adopted by Council in 2002.

It is also recommended that the Province commit to the continued extension of the 404 in accordance with the approved environmental assessment and commence the planning and design stage to support it. As the extension of Highway 404 is not recognized beyond Ravenshoe Road in either the existing or proposed Plan, it is suggested that amendments be considered as well.

Permitted Uses

The existing Greenbelt Plan allows for a range of uses outside of agricultural uses, as recreational and tourism uses are pennitted within the rural lands designation. Rural lands

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refer to lands not designated as prime agricultural areas that are located outside of settlement areas. Unfortunately, under the Regional Official Plan the majority of Brock is designated as prime agricultural areas which do not permit such recreational and tourism uses. Jn addition, the majority of the rural lands (designated as maJor open space areas in the Regional Official Plan) are highly regulated as they contain key natural heritage and hydrologic features.

The uses afforded by the Greenbelt Plan rural land designation have effectively been removed as a result of the Region's decision to remove the former General Agricultural Area designation in favour of the Prime Agricultural Area designation. As such, it is recommended that the Region of Durham re-Introduce the General Agricultural Area designation to recognize those non-prime agricultural lands. It is understood that a review of the Regional Official Plan is not likely to commence until 2018.

Prime agricultural areas represent a large portion of the Township. Considering the restrictive policies of this designation, besides from the current limited permitted uses, no tangible additional uses exist for these lands. This limits future opportunities for development and growth within the Township and ultimately jeopardizes the Township's vitality.

Expansion of Municipal Services

The Township previously recommended that the Greenbelt Plan eliminate the requirement that an environmental assessment supporting expanded water and sewage services be completed prior to a settlement area expansion. The proposed Plan would eliminate this requirement and would also require that the planning of sewage and water infrastructure be subject to the policies of the proposed Growth Plan.

Both the existing and proposed Greenbelt Plan permit the extension of municipal services outside of a settlement area in order to address health issues or to service existing development that is adjacent to the settlement area. However, the existing and proposed Growth Plan state that plans for new municipal services or the expansion of services are to support the achievement ofgrowth targets. Nowhere within the policies does it indicate that municipal servicing is permitted outside of settlement areas. This inconsistency between the two Plans makes it difficult to understand what is permitted. It is suggested that the Growth Plan speak to the possible extension of municipal services outside of settlement areas in order to better align the Plans.

The existing Greenbelt Plan does not permit expansions of Great Lake or Lake Simcoe based water and sewage services to settlement areas without Great Lake or Lake Simcoe based services, unless in the case of public health issues. With the proposed changes, the Growth Plan would contain a similar policy adapted from the original that would use the term "Great Lakes source and make no specific reference to Lake Simcoe. Without a proper definition of the term, the wording of this policy makes it unclear as to whether the policy applies to Lake Simcoe.

With the existing Greenbelt Plan policy, extending services from Beaverton to either Cannington or Sunderland would not be permitted. Conversely, with the new policy, if Lake

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Simcoe is not considered as a "Great Lakes source this could represent an option to address servicing constraints in Cannington and Sunderland.

Summary

The Township has had active participation related to the performance of the Growth Plan and Greenbelt Plan implementation since their inception. This has included deputations before a number of Ministers, resolutions of concern, and participation in the review of both Plans prior to the release of the amended Plans in 2016.

The Township's growth potential is constrained by a lack of servicing capacity in two urban areas which will impede achievement of goals of the Growth Plan related to intensification and density targets together with restricted opportunities for development within the rural areas. Restrictions within the agricultural areas are driven, in part, to the lack of opportunities provided within the Regional Official Plan.

It would appear as though the Province has adopted a one-size-fits-all approach consistent throughout all municipalities affected by the Growth Plan and Greenbelt Plan to address the public perception of urban sprawl created by those urbanized municipalities outside the City of Toronto. The fact remains that municipalities like Brock have never contributed to urban sprawl and is now being penalized through Provincial policy due to Hs membership in the inner ring of the Growth Plan. The restrictive policies, albeit certain exceptions are provided within the Greenbelt Plan, applicable to the agricultural areas of a municipality would appear to suggest that rural municipalities within the GTA are intended to be "designated" as the urbanized GTA municipalities' "playground".

The implication of such a designation. coupled with overlapping levels of legislative requirements (more prevalent in rural municipalities to the south) mean that the existing ratepayers of Brock must bear the entire cost of supporting such Provincial initiatives due to the limited realistic development opportunities granted by such legislative impositions.

In recognition of these concerns, the Province and Region must take proactive steps to provide opportunities for rural municipalities to survive as suggested in the above-noted comments contained within this report. Based on our review of the aforementioned Plans, aside from the removal of the requirement for the completion of an environmental assessment in support of a settlement area expansion, It would appear as though none of the municipality's concerns expressed over the years have been addressed by the Province.

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Respectfully submitted,

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Planning / Economic Development Co-ordinator

Reviewed by,

Thomas G. Gettinby, MA, MCIP, RPP, CMO CAO & Municipal Clerk

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Ii ntE CORPORATION OF ntE TOWNSHIP OF BROCK

Clerk's Department

PlaMlng Consuftant to 1he Planning Committee

Report: 201s.PL-02

Date: Monday, May 26, 2016

SU&JECT

Report related to the Provincial Plans Plan Review- Directions and Recommanda:t6is.

RECOIIMENDA]JONS

1. THAT the attached report tJtled "Provinclal Plans Review - Background and Recommendatlons9 be submltled to the Mlnlstry of Municipal Affairs and Housing as the Township's formal Input to the 2016 Provincial Plans Review of the Greenbelt Plan, Growth Plan for the Greater Golden Horseshoe, Oak Ridges Moraine Conservation Plan and Niagara Escarpment Plan.

REPORT

1.0 PURPOSE

The Province of Ontario Is currently undertaking a review of various Provincial planning documents, Including the Growth Plan tor the Greater Golden Horseshoe (GPGGH), the Greenbelt Plan, the Oak Ridges Moraile Conservation Plan, and the Niagara Escarpment Pfan. As part of the review process, the Province is accepting comments from municipalitle&, agencies, and olher stakeholders. The following report outlines Issues specificaJly related to two of the Provincial Plans affecting the Township of Brock - the GPGGH and the Greenbelt Plan.

2.0 BACKGROUND

The GPGGH came Into full force and effect In 2005 by way of the Places to GrowAct. The GPGGH Is Intended to provide the Province YAth land use planning policies that support -smart-growlW' lnitiattves such as intensiflcation, emphasis en local public transit, and protection of lands beyond urban growth boundariea. The Plan emphasizes growth within existing urban settlement areas and prohibits development outside of settlement areas that Is not related to msnagemsnt or use of resources, resource-based recreational actMtles, and rural land uses thatcannot be locatsd in ssttlement areas'.

This report is available in alternate fonnats.

ase contact the Clerk's Department at 705432-2355. Ple

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The Greenbelt Plan was aieo established in 2006 through the Greenbelt Act The eponymous "Greanbelr encompasses a large area within the GTA and beyond, including all rural lalXls within the Region of Durham. The Greenbelt Plan policies establish the "'Graenbelr and provide protection of theea lands by prohi>lting uses that are unrelated to agriculture,1'8Cf8811on, and resource management. The GreenbeltPta,1 also Identifies and protects natural heritage syatems, particularly those relal&d to the Oak Ridges Moraine and the Nlagam Escarpment

Under the Places to Grow Actand Greenbelt~ 1he Province Is required to review the GPGGH and the Greenbelt Plan every ten years. M such, the Province has undertaken a series of public Information 8888lons and has circulated various agencies and stakeholdera owr the pest 8-1Omonths il an effort to detennlne the effactiwnass of the Plans1 Although the GPGGH and Greenbelt Plan have effectively protected thousands of acres of farmland and natural heritage features from extenatve development, there have been some unittended consequences resulUng from 1he polcles of the Provlncial Plans, particularty ii the more rural munlctpaitles.

Some of these Issues have been outlined In staff reports and have been dlacuaaed at length by staff and Council for th~ Township of Brock. Furthermore, staff at the Region of Durham have compiled a review of the Greenbelt Plan and have provided comments to the Province. This report attempts to assemble the recurring Growth Plan and Greenbelt Plan issues wl1hJn the Township, as well as the conunents lrom the Regional RevJew related to ihe Township. Also fncfuded below are comments end observations from EcoVue Consulting. If accepted by Council, this report wll serve as the fonnal comments to the Province relatsd to the GPGGH and the Greenbelt Plan.

3.0 GENERAL COMMENlS RELATED TO THE GROWTH PUN FOR THE GREATER GOLDEN HORSESHOE

It Is Important 1hat the foDowing Issues are addressed as part al the Province's review of theGPGGH:

1. Rini Employment Area - M per Section 2.2.2.1 (i}, munlclpaHties cannot designate lands for Industrial and commercial development beyond settlement boundaries. The only exception would be those uses which by their very nature must be located In rural and resource areas.

tt Is staled In Section 2.2.6.2 of the GPGGH that munlcipalities must promote economic devek>pment and competitiveness byproviding far an apprr,prtate mix of smplc,Jm6ntUS8S Including lndustrlal, commetClaland lnstitutionBI uses to meet long-tsnn IH!ltldll'. It is also stated that an adequate ~ of employment lands must be provided and that munlclpalitl6s am encouraged to designate and preserve lands within settlement areas In the vicinity of existing major highway lnterchangss ...as at8BS for manufacturing, warehousing, and associated retall, offics and anclllary faclllties, where spproprtate".

1 The review also Includes a review of the Oak Ridges Moraine Consef'vatfon Plan and the

Niagara Eac:arpment Plan,

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The GPGGH does not reflect the realities of rural areas and smaler munlclpalltles within the Greater Golden Horseshoe. In many smaller municipalities, the most viable commerolal and Industrial land fs not focat8d within the urban areas. Highway commercial and rural lndu&lrfal uses are quite common In rural muiclpaltles and, togaiher with agrtcuttural uses, fonn the backbone of the rural economy. This Is evident In.the Township of Brock, where growth within the ttree (3) prinary urban settlement areas Is 88V8l'efyconsbalned (see bek,w). In order to provide an appropriate mix ofemployment lands, theTOMIShip clBrod(must have the option of designating rural lands for ernpla/ment U88S beyond those that have already been designated.

The pollcies ct the GPGGH are problematic for the Township as there are viable emplO'ifnent lands located in the vicinity of the 48/12 Junction that would be ideal for afuture employment designation. These lands are sbateglcally located In cloee proxinity to a future 404 hlgtMay corridor; Although 1here Iscurren1fy no munlclpal servicing available to this area, the8e lands would be suitable for small Industrial firms that do not require services, such as dry-Industrial uses. Further, there may be options for seMCing of these lands In the fubJre (private/public and communal servicing options). Future employment lands nearthe Highway 404/48/12 junction preeent a great opportunity to strengthen the rural economy of the Township. However, this area cannot be ullzed for its highest and best uae because the policies of the GPGGH ffmil employment lends 1D areas with existing municipal senridng. Further, Secllon 2.2.6.9 assumea that an major highway interchanges are k>cated within settlementaraaa, de&plte specific circumstances to1he contrary.

Al"""""'8PolicyApptOIIClle9

In 2012, the Ministry ol lnfrastruclure completed an amendment cl the GPGGH. TheSimcoe Sub-area. which encompasses the entire County ofSimcoe, tncludlng separated munlclpalities of Barrie and Orfllla, was 88lalJllshed through this amendment The Simcoe Sul>-area i'1cludes policies related to ernpkl'jment lands (Section 6.4), which Identify four (4) *stratsg/c setllBmBnt employment areal. These four 81'888 Include Important nodes 1hat are located Within the rural areas Of the County of Sincoe, Including the *Rama Roac/ economic employment dlBtrk:r which encompasses an area In ctoae proximity to castno Rama in the Township of Ramara. These areas are pmtscted for employmentuses ltratrequ/rs latge lolB ofland8l'ld dependupon Bfficlsntmovementofgoods andaccess to Highway 400 [and}.,. not Nfflenllnt...,,. Through the Simcoe Sub-area amendment, the Province eesentlally acknowledged the exi8tence and need for rural emptoyment areas. However, to date, no 81888 outside of the County of Simcoe have been identified as strategic settl6msnt employmentaraas within the GPGGH.

Recommandallon: It is recommended that the pollcles of Section 6 (Simcoe Subarea) of the GPGGH be applied to lands outside the County of Simcoe. which would benefit from 1he establishment of strategic settlement employment areas. The aforementioned lands In proximity to Highways 48, 12 and 404 (future) are a clear e>CB1Tiple of such an area.

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2. lntenalflcatlon and Uman lnfraatructure - The GPGGH dlracts growth to exls11ng urban areas so that new development In 1hese areas can 1ake advantage of existing infrastructure. However, many smaller municipalities 8Ud1 as the TOWIShlp of Brockcannotaccommodate further growth without rna;or upgrades to existing munlcfpal water and wastewater systems within urban settlement boundaries. The ca.pHal cost associated with these t4>Qrades Is unaffordable for smaller muntcipaJffles as they do not possess a sufficien1fy large tax base to support these upgrades and/or e>epanstons. Therefore, the requirement that lntenslfk::e.tiQ occur on existing services means that Intensification targels cannot be met in the Township of Brock and In similar rural communities, beyond the GTA proper.

Recommandallon: It Is recommended that 1he GPGGH include alternative serw:ing options for urban areas ,n smaller municipaities, where upgrades to municipal servicing are not financially feasible. It Is further recommended that intensification targets for these communities be reviewed In tight of the serious limits associated with limited munlcipal Infrastructure.

3. lJrbln.Cenbic Policies - The application of the policies of the GPGGH over the past10 years has proven thatpo8cies related to large urban areas such asToronto cannot be effectively applied in smaller municipalities Ike the Township of Brock. The recently released -Perfonnance lndicatonf for the GPGGH Illustrate 1hat the statisUcs for1heTownship of Brockare Inconsistentwith 1he Intended resufts of the policies. Density of development is far below expected levels, the mix of housing stock shows an 'owrrellance' on single detached dwelHngs, and transit/commuter trips falls far short of those recorded elsewhere. Some havesuggested that this Is because planning decisions made in this area are not consistent with the policies of the Growth Plan. In fact, this Is not the case at al Rather, the statistics are highlighting the fundamental differences between this area and those areas for which the policies were specfflcally designed.

Although the TOM1Shlp pf Brock Is located within the Region of Durtlam, and Is therefore consklered part of the GTA/Inner Ring, conditions in the area are much different from the Region's lakeshore munlcipaJIUes. It Is our opinion that the Province must move away from urban-centric, one-size-fits.all policy for rural and small urban areas beyond the densely popuJated areas of the GTA. It seems that the fear of urban sprawl and out-of-c>ntrol growth, which has dominated the GTA for many years, remains the basis for policy plannlng in areas where the conditions are quite djfferent. The application of urban-centred land use poHcy to rural lands has meant that local SOiutions have not been considered. Recent changes In the Provincial Policy Statement (PPS) suggest that there may be a chance to apply a rur&l lens2 to plannlng outside the prfrnanly urban munlcipallties. This approach should be seriously constdered during the 2015 co-omlnated review of the GPGGH.

2 The Rural Lens Is aconcept developed by the County ofHuron to enable amore complete understandt111 ofthe lmpad:that speciflc pclldes have on rural areas.

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RaCOlmlll'ldldlon: It Is recommended that the GPGGH Include new pollcles more closely aflgned with the needs of rural areas. The policies could allow for local lntetpielation, slmDar to the rural poUcies Introduced In the 2014 PPS. These policies could be developed In consultation with the Mntstry of Agriculture, Food, and Rural Affairs (OMAFRA), to pnMde for flexl>Ulty In rural areas and smaler settlement areas, like canntngton, Beawrton and Sunderland, whOe still respecting the overall requirements for protection of prine agricultural lands.

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4.0 GENERAL COIIIIENIS RELATED TO THE GREENBELT PLAN

It Is Important that the following Issues are addressed as part of the Province's review of the Greenbelt Plan:

1. Natural Hartlage Systenl llapplng - The mapping of the Natural Heritage Systarn In the Greenbelt Plan is quite broad end may Include ~ that do not requra a protective designation. For Instance, a large amou~ of land Included within the Natural Heritage System mapping does not lnciude a natu'al heritage faallru, but rattler has been Identified as a "coonectlod' or -ankage" between fea1uras. WhBe It is ~ that connections between features are bnportant. It Is dlfflcult to detennlne where aconnection should be established for pio1ectlon wilhout delailed knowledge of the specfflc feature and 1he site charactarislics

Due 1D Inflexibility In Greenbelt Plan pollcieS, the broad appllcatlon of the Natural Heritage System across extensive rural areas has had a negative effect on the agricultural community. The Natural Heritage System Identified In the Greenbelt Plan lnciudes many heclares of fannland without any specfflc natural heritage feat1les Identified by Ministry of Natural Resol.l'ces and Foresby (MNRF) or the local conservation authority. The Conservation Aulhority then Is required by Ontario Regulation 178/06 to regulate the use of these lands, lncludfng all epp1cations for 'development'. These policies have a direct Impact on those agricultural lands which have not been actively fanned since 2006, despite their vfablity and lack of environmental constraints. Ironically, the Greenbelt kt. encourages agricultural uses and Is Intended to protect prime agricultl.ral lands.

Aecommandallon: It Is recommended that the Greenbelt Plan provide more accurate mapping of the Natural Heritage System, particularty as It pertaJns 1D linkage areas. Moreover, the Greenbelt etan could also Include polk:les that allow for local Interpretation of the extent of the Natur:e) HerHage Systems.

2. S8lllarnant AnNI Adjuabnanta - The Township of Brock Includes three primary ulben s8lllement areas: Beaverton, C&nninglon, and Sundertand. Further development within each of these sett1ement areas Is constrained by various factors - primarily, Dmltations asaoclatBd with natural heritage and natural hazard features. This ls evident in the eastern partlon of Beaverton, near Highway 12, where a large wetland Impacts future devekJpment.

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Furthermore, 1here is a large portion of the southeast area of Cennlngton 1hat is consb"ai1ed by the wellhead proteclfon area. Therefore, It is desirable for 1he Township to adjust the boundaries of each of the settlement areas in order to accommodate future growth. Although the Greenbelt Plan speaks to settlement area expansions, It does not include poliCies for the transfer of undeveiopable settlement area lands for usable lands In a -one-tor one- exchange, where such a transferdoes not result In an overall net gain.

Recommendation: It Is recommended that the Greenbelt Plan include policies thatallow for an equal exchange of oodevelopable lands within a settlement area for d8YBlopable lands adjacentto the settlement area, where the exchangecan be supported on the basis of sound land use plannlng.

3. Expansion of llunlclpal Services-AB per Section 4.2.2.4, any expansions to existing urban settfement areas (Towns/VIiiages) require an environmental assessment (EA) for future 88Nicfng. Notwithstanc:lng the policies of the Greenbelt Plan, a Municfpal Class Environmental Assessment 18 required by the Ministry of Environment and Climate Change prior to any expansion of munlcfpal services. Therefore, the Greenbelt Plan introduces an unnecessary layerof approvals within the EA process. This addttional layer of approvals is problematfc for munlcipafdies such as the Township of Brock, because:

a. the costs of doing an EA well In advance of actual development may not be recovered; and

b. the EAs themselves have a limited time frame for implementation.

The Greenbelt Plan provides for the extension of municipal services beyond the settlemeot area boundary in cases where health concerns are raised or to 58nice e>dsting development beyond the settlement bolndary. The Growth Plan for the GreaterGolden Horseshoe (3.2.5.4) provides greater restrictions on the extension Of munldpal 88fVlces beyond the settlement area boundary. These restrictions would preclude theTownship of Brock from extendlng services to areas of existing development along Lake Simcoe. Whtie It is understood why these policies exist, the Lake Simcoe Protection Plan requires that existing private septic systems withn 100 metres of Lake Simcoe be inspected and replaced, ifnecessary. Given the number of private sewage systems located adjacent to the Beaverton settlement area boundary, It may be a benefit to the health of Lake Simcoe to permit the expansion of Beaverton's municipal sewage services to these areas.

Recommenclallon: It is recommended that Section 4.2.2.4 (and 3.4.2.4) of the Greenbelt Plan not Include a requirement for an EA as part d a settlement area expansion. It ls also recommended that the policies of Section 3.2.5.4 of the GraNth Plan for the Greater Golden Horseshoe provide options for extending services beyond the settlement area boundary In certain circumstances.

4. Expanded Non-Agricultural Uaes In Aural Areas - The Greenbelt Ran Is qutte restrictive regarding recreational and tourism uses, Including country wedding venues, golf courses, and other similar uses. It Is Important that rural areas of

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munlcipaJitiea be able to accommodate uses that are beyond typical agricultural and agriculture-related uses, partkllarty In areas whele the economics of agr1cullural production limit the viability of smaller farm operations. Expanding the potential rural commercial uses 'MIi help create a stronger and more diverse (and thus, more resilient) rural economy.

Recommendation: It is recommended that the Greenbelt Pian Include an 8llp8l1ded list of pennlttad U88S Within the Pmtecled Countryside. In addition, the Greenbelt Plan should allow greater fle>ci>llily for municipalities when evaluating recreationalllourlsm development applications In rural ar988,

5.0 RECOMMENDATION

It Is recommended that this report. Provincls/ Plans Review - Dlrsctlons and Recomm6ndstlons, be received by Counctl end forwarded to the t.lnlstry of Munldpal Affairs and Housing as the Township of Brock's fomlal comments regarding the ProvtnclaJ Plans review.

Respectfully submittedt

ECOWE CONSULTING SERVICES

~~ HealherSadler, BA. M.A, MCIP, APP Principal end Senior Planner

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OFFICIAL PLAN OF THE REGIONAL MUNICIPALITY OF DURHAM

SCHEDULE a MAP '81a' GREENBELT NATURAL HERITAGE SYSTEM & KEY NATURAL HERITAGE AND H't'DROLOGIC FEATURES

StructureRe: .Co-ordinated Land Use Planning Review Township of Brock Comments Subject Co-ordinated land Use Planning Review -Comments for Proposed Plans Recommendation Attachments Report Background Overview of Proposed Changes Overview ofProposed Growth Plan and Greenbelt Proposed Growth Plan Proposed Greenbelt Plan General Comments Natural Heritage/Hydrologic Evaluation Increased Targets Challenges in Brock Specific Comments Natural Heritage Syst.em Settlement Area Adjustments Highway 404 Extension/Employment Amas Permitted Uses Expansion of Municipal Services Summary ntE CORPORATION OF ntE TOWNSHIP OF BROCK SU&JECT Report related to the Provincial Plans Plan Review-Directions and Recommanda:t6is. RECOIIMENDA]JONS REPORT 1.0 PURPOSE 2.0 BACKGROUND 3.0 GENERAL COMMENlS RELATED TO THE GROWTH PUN FOR THE GREATER GOLDEN HORSESHOE Al"""""'8PolicyApptOIIClle9 4.0 GENERAL COIIIIENIS RELATED TO THE GREENBELT PLAN 5.0 RECOMMENDATION OFFICIAL PLAN OF THE REGIONAL MUNICIPALITY OF DURHAM SCHEDULE a MAP '81a' GREENBELT NATURAL HERITAGE SYSTEM & KEY NATURAL HERITAGE AND H't'DROLOGIC FEATURES