June 14, 2017…

   June 14, 2017

  Cindy Tan, Manager

 Ministry of Municipal Affairs and Housing

 Ontario Growth Secretariat

 777 Bay Street

 Toronto Ontario

 M5G 2E5

  Dear Ms. Tan,

  Re:  Modification to Ontario Regulation 311/06 (Transitional Matters - Growth Plans) - EBR Number 013-0426

  The following comments are provided with respect to the Environmental Registry posting on the proposed modifications to Ontario Regulation 311/06 (Transitional Matters – Growth Plan). Region of Waterloo staff continue to have concerns regarding ongoing planning matters and the impact of the new Growth Plan. The Proposed Growth Plan for the Greater Golden Horseshoe, 2016 was released for public consultation in May 2016.  In October 2016, the Region of Waterloo provided comments on the proposed plan through report PDL-CPL-16-41 (attached) as approved by Regional Council on October 19, 2016.  Included in this report were comments regarding transition policies.  These comments highlighted the concern of the Region (see excerpt below from PDL-CPL-16-41).

  Transition Policies

  The implementation policies of the proposed Growth Plan require that all decisions with respect to planning matters shall conform to this Plan as of its effective date.  Regional staff are concerned with the impact of this transition provision on development applications in process, the implementation of secondary plans, district plans and community plans, Area Municipal official plans that are before the OMB for adjudication, and the policies of the ROP which implement items related to conformity with the 2006 Growth Plan (as amended).  As currently proposed, these transition policies would not allow municipalities to complete conformity exercises with respect to the 2006 Growth Plan and would require municipalities to revisit development applications in process and approved secondary plans, district plans or community plans to ensure conformity with the revised targets of the new Growth Plan.

 There is a specific concern regarding the requirement that would have the 80 persons and job per hectare density target effective immediately upon the Proposed Growth Plan coming into force. Several of the Region’s area municipal official plans are currently before the OMB and any decisions made by the OMB would need to conform to the 80 persons and jobs density requirement. This would mean that the OMB could require the area municipal official plans to contain the new, higher density targets before the Region has had the opportunity to undertake the process to comprehensively assess and allocate the new density requirements across the Region.

  Recommendation:  That the Province provide transition provisions similar to that of Amendment 2 to the 2006 Growth Plan which would permit municipalities to complete the implementation of policies and development approvals associated with the exercises to achieve conformity with the 2006 Growth Plan (as amended).

  The Region of Waterloo continues to request that transition be provided through Ontario Regulation 311/06 to permit municipalities to complete the implementation of policies and approvals associated with ongoing planning exercises to achieve conformity with the 2006 Growth Plan (as amended). Please feel free to contact Michelle Sergi at Msergi@regionofwaterloo.ca or 519-575-4521 if you require any additional information or have any questions.

  Regards,

  Rod Regier

 Commissioner

 Planning, Development and Legislative Services

  A signed version of this letter and the attachment will be sent directly to Ms. Cindy Tan as well as the London office of Ministry of Municipal Affairs.

[Original Comment ID: 209683]