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.

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