File 23T08505/OP0801/ZC0306 – 1897 Gordon Street Draft Plan of
Subdivision, OP and Zoning AmendmentWe are concerned that the proposed rezoning of the Bird property will further impact the long term protection and health of the Hanlon Creek Watershed ecosystem. The PPS supports planning on a watershed basis; however, this proposal does not represent good planning on a watershed basis.
The 1994 Hanlon Creek Watershed Plan was a comprehensive environmental impact study designed to protect and enhance the valued natural resources which include the cold water fisheries and the Hanlon Creek Provincially significant wetland, one of the largest natural ecosystems in the city.
The hilly moraine areas of the watershed provide the recharge that maintains the groundwater regime necessary for the long term survival of the Hanlon ecosystem, including the cold water Hanlon Creek and the Hanlon provincially significant wetland. The Bird Property is on the moraine. Developers like to point out that developing their portion of the watershed will not negatively impact the overall groundwater recharge that maintains the creek and wetlands, and that their development is sustainable – at best a questionable notion.
The watershed plan looked at what would happen with increasing urbanization in the entire watershed. Parts of the proposed development do not conform with the recommendations in the original Hanlon Creek Watershed Study nor in the updated State of the Hanlon Creek Watershed Study. Therefore, parts of the proposed zoning represent the very type of piecemeal planning the watershed study was designed to prevent.
The Hanlon Creek Watershed Study was subject to extensive public and developer involvement. The entire watershed plan recommendations were approved and zoning to implement the plan was developed and approved by the council of the day. A council that included our present Mayor Farbridge and Councillor Kovach.
Therefore, we believe it is simply a betrayal of the public trust for City Council and our Mayor to approve any development that destroys a portion of the links, buffers or core areas that were recommended in the Hanlon Creek Watershed Study.
We submit that the city has no way of predicting what the impacts of developing the Bird property will be on the overall health of the Hanlon Ecosystem, since comprehensive yearly Hanlon watershed monitoring approved by the 1994 Council has never been implemented.As far as we are aware, the last monitoring to determine development impacts on the watershed was conducted in 2000 for the State of the Hanlon Creek Watershed Study. Between 1991 and 2000, 314 hectares of the watershed have been bulldozed for development. (Stats – From City of Guelph Natural Heritage Strategy – Phase 1 FINAL REPORT – March 2005 pg. 9)
The city planners should be able to comment on how many hundreds of hectares have been altered since 2000 and what the impacts have or have not been on the Hanlon ecosystem – please ask this question. Is there data that would prove the Hanlon Creek ecosystem remains healthy and no negative impacts related to development have occurred?
We suspect staff cannot give a definitive answer because the last comprehensive watershed monitoring was in 2000, precisely 11 years and many developments ago. New monitoring data was supposed to be collected in 2008-2009. Has it been done and evaluated? To date we have seen no evidence this has been done. We submit that city staff cannot know what the impact of this proposal will be on the long term health of the ecosystem without updated overall ecosystem monitoring data. All development must be consistent with the Provincial Policy Statements.
The PPS stipulates that natural features and areas should be protected for the long term. It stipulates that diversity and connectivity, long term ecological functions and biodiversity of natural systems should be maintained, restored and improved, recognizing linkages between the features themselves as well as their relationship to groundwater and surface water. The city has the means to determine the long term impacts of this development by evaluating what changes have already occurred in the watershed.
We therefore suggest that approval of the Bird Property redevelopment is premature, as the long term impacts of the proposed density and required site alterations, including the removal of wooded areas and a large majority of the noncore greenlands on the property, cannot be definitively assessed at this time. The State of the Hanlon Creek Watershed Study recommended that there be no further encroachments to the core and non-core Greenland areas.
The development proposal does not represent good planning. Consider the results of the Smart Guelph consultations, that a greener, non-polluted environment with connected natural areas was identified as the highest priority in the community’s vision for Guelph. This development does not meet these goals. Economically it makes sense to protect a healthy Hanlon Creek ecosystem in perpetuity. A 2009 report to the MNR estimated ecosystem value per hectare per year as:
Urban Forests $25,843 per hectare per year
Urban Herbaceous greenspace $43,788 per hectare per year
Urban Wetlands $161,420 per hectare per year
FROM: Estimating Ecosystem Services in Southern Ontario
By: Spatial Informatics Group, Austin Troy & Ken Bagstad (2009)
Planning Issues
1. The proposed development does not conform to the Official Plan.
The lands proposed for development contain “complex topography” with slopes of up to 25% as well as an up to 5 meter difference in elevation from north to south. Therefore, in order to develop this land it is apparent that extensive grading and filling will be required. The EIS does not address the impacts of this grading on adjacent properties. Why not? Are portions of these lands “hazard lands”? Will the extensive grading proposed on this property lead to a “deterioration or degradation of the surrounding environment” as described in the OP definition of “hazard lands”?
The OP describes Hazard Lands “lands which are or may be inappropriate for urban development by reason of having inherent or natural environmental hazards such as susceptibility to flood or erosion, poor drainage, unstable soils, steep slopes or any other physical condition or limitation and which, if developed, may lead to the deterioration or degradation of the environment or cause property damage or loss of life.” (p. 201)
2. Conformity with the OP South Guelph Secondary Plan Area
The proposed development lies within the area defined in the OP as the South Secondary Plan Area. There was extensive public input into the secondary plan before it was incorporated into our OP. As stated in Section 3.6.1, “This Plan promotes the creation of a “sense of place” which will set Guelph apart from other municipalities.”
The rolling hummocky areas south of Clair Rd. form part of the heritage viewscapes, cultural landscapes and natural heritage which add character and visual beauty to our city. This is what sets our municipality apart from other cities such as Mississauga, Brampton and Milton and makes it an attractive place to live.
This Draft Plan of Subdivision proposes nothing new or innovative, just the usual bulldoze and build with no apparent attempt to comply with the Objectives of the South Secondary Plan, which are not even mentioned in the report before you tonight or referred to in the proponent’s EIS . The wetland on the property will become part of the open space for this property. It is our fear that the wetland will be degraded from encroachment as there does not appear to be an adequate amount of active parkland for the proposed densities. Therefore, this draft plan does not appear to conform to Section 3.3.2 of the OP which states:
“The City will promote environmentally sustainable development by:
a) Pursuing development practices that are sensitive to the natural Environment and implementing programs such as monitoring systems, to maintain environmental quality;
b) Continuing to move towards planning policies that are based on the principles of watershed planning, ecological systems planning and natural heritage systems planning, taking into account both landscape and ecosystem values;
c) Encouraging the use of environmentally-friendly design concepts;”
As well, this development does not represent planning on a watershed basis as it ignores the recommendations of the 1994 Hanlon Creek Watershed Plan and the 2004 State of the Hanlon Creek Watershed Report. For instance, how does the removal of the complex moraine topography which will reduce the recharge of clean water to our aquifer and the proposed removal of the pine forest on site (comprised of many pine species including 4 native species) meet Section 3.6 Urban Design Objectives a, b, c, e, f, h and i (p. 18) as seen below? The removal of the pine forest will further reduce our tree canopy cover goal of 40%. Note that the MNR is promoting the retention and rehabilitation of plantations as habitat.Other parts of the OP not met under Section 3.6:
a) To recognize that the image of Guelph is a composite product of the founders
and earlier residents of the City as well as the perceptions of its current residents
and visitors.
b) To enhance the image of the City as defined by this Plan’s Operating Principles,
Major Goals and Community Form Statement.
c) To practice environmentally sustainable urban development by adhering to urban
design principles that respect the natural features, reinforce natural processes
and conserve natural resources
e) To ensure that the design of the built environment strengthens and enhances the
character of the existing distinctive landmarks, areas and neighbourhoods of the
City.
f) To ensure that the design of the built environment in new growth areas integrates
with the natural setting and uses built-form elements from the older, established
areas of Guelph
h) To encourage compatibility and quality in the built environment while allowing for
a diverse expression of site design by establishing design principles and
guidelines to encourage excellence in design.
i) To develop an attractive, safe and functional network of open spaces by ensuring
mutually supportive relationships between public and private open spaces,
between the built forms that enclose them and with the links that connect them.”
Furthermore, does this proposed plan meet the following objectives in our OP?
“c) Provide an opportunity for and encouragement of innovative development which
will reflect the City’s commitment to environmental sustainability at the local,
regional and national scales.
d) Provide an opportunity for new growth occurring in this area to develop in a
manner reflecting a commitment to sustainable development (environmental,
economic and social).
g) Encourage interim land stewardship practices, as identified through watershed
plans, which maintain and enhance natural heritage features and functions forthe South Guelph lands prior to the area’s development.”Does this proposal support the objectives of our OP 3.9 Urban Fringe Areas:
“a) To lay out a planning framework for land use change on lands within the City of
Guelph that is found on the urbanizing fringe of the community.
3. In the preparation of development plans in fringe areas of the community, the
City will carefully examine the best means to integrate the agricultural/rural land
uses into the City. Aspects that will be considered include the cultural heritage
landscape resources associated with farmsteads as well as opportunities for
integration of natural heritage features.”These lands are located in the Stage 2 and 3 areas of the South Secondary Plan. This section of the OP sets out the reasons why this development is premature without a Storm water and infrastructure master plan. One other concern is the current economic situation. How will the city finance the required upgrades if the housing market continues to decline?
Municipal General Servicing Considerations – South Guelph Secondary Plan Area p. 43
“Where such properties are designated ‘General Residential’ or ‘Reserve Lands’ by this Plan, they shall be recognized as a permitted use. Future redevelopment, infill, or major intensification of such property shall not be permitted until full municipal services become available and such redevelopment, infill, or major intensification proposal conforms to and is consistent with all other applicable policies of this Plan.”
4.2 Staging of Development
The following staging of development policies will be applied within the City of Guelph:4.2.1 The rate and direction of development in new growth areas will be governed by the City’s ability to provide and extend municipal services, as required, and by the City’s ability to meet the financial obligations for the provision of the required services
b) STAGE 2
Priority for the extension of municipal trunk services to support new urban development shall be given to those lands designated as Stage 2 servicing areas. Development proposals in Stage 2 areas will be considered as services become available to the various parcels, and Council indicates that the City is prepared to provide the required trunk services. The implementing Zoning By-law, and its associated amendment process, may be used as a regulatory mechanism to prevent pre-mature zoning of land for activities that do not have adequate municipal services associated with them.c) STAGE 3
Development within a Stage 3 servicing area of the City may be considered subject to the adoption of a secondary plan in accordance with the provisions of subsection 9.5 of this Plan. In those areas where a secondary plan has been approved, development applications will be
considered as services become available to the various parcels and the City is prepared to provide the required trunk services. The implementing Zoning By-law, and its associated amendment process, may be used as a regulatory mechanism to prevent the pre-mature zoning of lands for activities that do not have adequate municipal services. Generally, the implementing Zoning By-law to this Plan will recognize existing legal uses only.”b) Easterly Portion of Phase 1:
i. Extension of the south end trunk sanitary sewer;ii. Extension of the existing trunk sanitary sewer from the present termination points on Clair Road;
iii. Connection as required to the existing trunk watermain located on Clair Road. The southerly limit of this phase is governed by topography. Areas to be developed, which are above a ground surface elevation of approximately 344 metres above sea level (masl) will require that water
pressure be boosted to acceptable service levels. As such, the existing water distribution system and pressure zone can be extended only as far as the topography (post area grading) will allow.6. Phase 3
Prior to development occurring in areas shown as Phase 3 on Schedule 4B, the following must occur:a) Extension of the trunk sanitary sewer from the intersection of Clair Road and Gordon Street, southerly along Gordon Street. The primary constraint in servicing this area is topography, and the associated depth of cover on the sewer.
b) Extension of the new water pressure zone (as referenced in Phase 2) is required before development can proceed in this area.”
The parkland dedication in this proposal is inappropriate and inadequate. There is no link to the Trail system for the regional parkland to the west. Why Not?
Based on the above planning concerns we believe that application is premature and that planning staff and proponent should demonstrate how this proposal complies with the City of Guelph Official Plan, the Goals and Objectives of the South Secondary Plan, the 1994 Hanlon Creek Watershed Plan and the recommendations contained in the 2004 State of the Hanlon Creek Watershed Report.DM