Please Note, the following…

 Please Note, the following letter containing comments  for O.Reg 311/06 is being submitted on behalf of the Mayor of Waterloo - a signed copy of the letter has also been mailed for the official record:

   Dear Ms. Tan:

  Re:Proposed Transitional matters and modifications to O.Reg 311/06: Comments

  This letter is in reference to EBR Registry Number:  013-0426 regarding transitional matters outlined in proposed modifications to O.Reg 311/06.

 The recently released Growth Plan includes significant changes to provincial planning policy for the Greater Golden Horseshoe (GGH) area. The City of Waterloo has been involved throughout the coordinated land use review process and submitted several comments on the proposed changes. These comments and specific concerns were highlighted in a staff report that City of Waterloo Council endorsed at its Committee of the Whole Meeting on October 3, 2016.

 The City of Waterloo has significant concerns regarding the changes to the Municipal Comprehensive Review (MCR) process given that lower-tier municipalities will no longer be permitted to undertake such studies. In particular, the City is concerned with a lack of transition provisions dealing with MCRs that have been commenced as per the 2006 Growth Plan requirements, but prior to the July 1, 2007 effective date of the new Plan.

 The Region of Waterloo is building a Light Rail Transit (LRT) system through the region, with significant financial contribution from the Provincial and Federal governments in partnership with the Region of Waterloo. The Region’s first LRT line is being built to improve transit, manage growth, foster economic activity, and built complete communities - consistent with the vision and policies of the updated Growth Plan.

 Furthermore, the City of Waterloo has been undertaking an extensive planning process for the areas around the LRT stations. The draft Station Area Plans propose several recommendations in order to facilitate and support opportunities for intensification, economic development and provide an updated land use framework. One of the key recommendations from the draft Station Area Plans includes provisions to allow for limited residential uses in areas near select station stops. Allowing for residential uses is intended to provide for a greater mix of uses, which is an important factor in promoting increased activity and vitality of an area, especially near transit. Provincial and Regional land use policy further encourages and directs mixed-uses in areas around higher order transit. However, the City of Waterloo is in the unique position where several of the City’s LRT stations are found within designated Employment Lands. Provincial planning requirements restrict several non-employment uses including residential within Employment Lands.

 Therefore, on May 29, 2017, Waterloo City Council directed staff to initiate a MCR of the City’s designated Employment Lands and to initiate an Official Plan Amendment application to address any potential implications of the MCR. However, the new Growth Plan and associated transitional matters regulation limits the ability of our local municipality to complete the study. The City of Waterloo is committed to conforming to the Growth Plan, but ask that our in-process MCR be permitted to be completed. With Regional support in launching our MCR, and Regional approval needed for the implementing Official Plan Amendment, I believe the transitional regulation should be capable of capturing this circumstance without risk to the Province.

 I ask that you review this matter in a timely manner and consider making consideration to allow the City of Waterloo to complete the MCR that Council has already directed to be commenced.

  Kind regards,

   Mayor David Jaworsky

 City of Waterloo

[Original Comment ID: 209597]