The Town of Amherstburg…

The Town of Amherstburg administration offers the following comments about the proposed changes regarding parkland conveyance, dedication, encumbered parkland and POPS:

1. The distribution of parkland that serves various areas may be in adequate for the needs of the community.
2. The proposed changes could potentially saddle municipalities with more maintenance and burdens of un-developable parkland that offers communities the amenities they require to service specific areas.
3. The cost of maintenance could increase drastically depending on what is conveyed.
4. The governance and maintenance of these lands becomes questionable and must be very detailed for all development agreements which we should stipulate an elongated timeframe to digest the various plausible situations that could be conveyed.
5. The direct correlation of parkland may not be what the community needs and might now fit within the Towns’ strategic plan lending developers to be able to convey lands that will only increase costs for the municipality for little recreational gain on a larger scale.
6. Municipalities should be able to enact changes to the OP to provide opportunities for comment and acceptance of land conveyed to the Town must be in the best interest of the municipality or cash in lieu be provided as an option.
7. Any land conveyed as easement for services the town needs access to at it’s sole discretion and maintenance of these areas must be carefully considered before acceptance.
8. The proposed legislation will reduce the Town's ability to refuse parkland conveyances including POPS that are less desirable to meet community needs.
9. The proposed legislation will provide developers more options as to how they provide parkland to the Town for new developments.
10. The proposed legislation will result in increased municipal administrative workload related to formal notification about whether proposed parkland will be accepted or refused.
11. The proposed legislation exposes municipalities to increased risk of appeal to the Ontario Land Tribunal should a municipality not accept a parkland conveyance proposed by a developer or fail to make a decision on a proposed parkland conveyance within the new timelines.
12. Clarity is required about how the proposed legislative changes would impact existing approved municipal Official Plan or Master Plan policies pertaining to parkland.

The Town of Amherstburg administration offers the following comments about the proposed changes regarding streamlining and standardizing Official Plans:

1. The Town is supportive of the proposed changes to streamline and standardize Official Plans.
2. The Town is nearing the completion of a re-write of the Official Plan and seeks clarity about when the proposed changes will need to be implemented and if a housekeeping amendment is an acceptable approach to bringing the new Official Plan into conformity with the proposed Bill 98 changes to the Planning Act.

The Town of Amherstburg administration offers the following comments about the proposed changes regarding complementary changes to support implementation of streamlining and standardizing Official Plans:

1. The Town is concerned about the proposed removal of climate change policies from the Official Plan.
2. The Town needs local planning policies to preserve and enhance the natural heritage to and protect the Town from the impacts of rising temperatures and more frequent severe precipitation events.
3. Land use planning policy is an important tool to protect the Town's people, infrastructure and investments from the impacts of climate change.

The Town of Amherstburg administration offers the following comments about the proposed changes regarding minimum lot sizes:

1. The Town is concerned about the proposed minimum lot size of 175 square meters.
2. The Town appreciates that the Province is trying to create more building lots to support the construction of more homes.
3. Existing Town infrastructure is not designed to support this level of intensification.
4. The proposed changes would allow for development to occur on 20 or 25 or 30 foot lot frontages whereas the existing water, sanitary and stormwater infrastructure has been designed for 50+ foot lot frontages.
5. It appears that the proposed changes would allow additional residential units (ARUs) to be built in conjunction with the proposed new minimum lot sizes. This would further strain the existing infrastructure system.
6. While new subdivision developments would be required to create infrastructure supportive of the new minimum lot sizes, the Town's water, stormwater and sanitary systems have not been designed to accommodate this level of intensification.
7. Consents to sever land to create minimum size lots in accordance with the proposed changes should only be allowed where sufficient infrastructure capacity is deemed to exist by a qualified professional.
8. Clarity about how funding sources for redevelopment, enhancement and construction of infrastructure systems would need to be identified to support such levels of intensification envisioned by the proposed legislative changes.

Thank you for the opportunity to comment on the proposed legislative changes.