Re: Comments on Draft …

Re: Comments on Draft “Application of the Intensification and Density Targets” Guidelines and “Implementation of the Municipal Comprehensive Review Process”

City of Waterloo staff previously provided comments during the development of the updated Growth Plan. The following are comments on the draft “Application of the Intensification and Density Targets” and draft “implementation of the Municipal Comprehensive Review Process” documents:

Greenfield Density
City Staff have previously noted that achieving a density target of 80 p+j/ha on developable lands will require planning for actual densities that are significantly higher than 80 p+j/ha. Higher densities are required to take into account undevelopable land such as parks, stormwater management ponds, roads etc. and lands already planned and built since 2006.
The City of Waterloo has limited continuous greenfield land available, thus it will be challenging to achieve densities at 80 p+j/ha on the remaining greenfield sites. The majority of remaining greenfield lands in Waterloo are generally located far from frequent transit, fragmented, are small in size ,and are adjacent to existing low rise neighbourhoods. Therefore, the City will be interested in collaborating with the Region of Waterloo to explore an alternative density target for DGA lands.
The draft guideline document outlines several factors to take into consideration to determine the appropriateness of an alternative density target (e.g. infrastructure feasibility, absorption rates), as detailed on page 29 of the guideline document. However, there are no explicit considerations for the site context, geographic location of the DGA lands (e.g. lands located at the edge of the City adjacent to rural areas), the proximity and feasibility of transit, and importantly factors such as community character and compatibility with adjacent and existing development. In addition to a technical exercise as outlined in the guidelines document, the above would contribute to good planning and building complete communities when assessing the appropriateness of alternative DGA density targets. By solely focusing on density targets, community features that contribute to complete communities (e.g. parks) may be reduced or restricted in greenfield areas in an attempt to meet the target numbers. City staff recommend a more balanced approach be taken into consideration for assessing the appropriateness of alternative density targets for DGA lands so as to balance the goals of increased density and maintaining community character.
The draft guidelines recommend municipalities offer incentive tools to encourage higher densities on DGA lands. However, there may be limited demand for higher density development in a municipality, especially outside the inner ring of the Growth Plan area. What is the appropriateness of adding incentives for DGA density when the City may prefer to direct additional densities to more appropriate areas such as node and corridors, the growth centre and MTSAs?
Section 3.4.2 of the draft guideline document refers to planning approvals that are consistent with to the 2006 Growth Plan. The final guidelines document should be clear that recent Secondary Plans and District Plans that conform to the 2006 Growth Plan should be allowed to continue as planned. Such planning documents involve extensive public consultation and resources to develop while the overall objectives of the updated Growth Plan remain similar to the initial 2006 Growth Plan.

Intensification Target
The draft guidelines outline that intensification is to be measured on a yearly basis. While Waterloo has been able to meet and exceed the intensification target since 2006, annual fluctuations in market demand or a time lag getting developments from approval to completion may occur, making the intensification target more challenging in any given single year. A more accurate measure should track intensification over a period of time (e.g. a five-year running average). Such a measure would account for natural fluctuations in market demand and ability to bring new developments forward.
There has been no update to the built boundary in the updated 2017 Growth Plan. Using the built boundary from 2006 means that 10 plus years of development will be counted towards the DGA target rather than the delineated built-up area and intensification rate. This puts even greater pressure on new areas to be developed at densities that far exceed 80 pj/ha. Such high densities in certain areas may far exceed what is appropriate. It is suggested that upper-tier municipalities be given the flexibility to make refinements to the delineated built-up area, where appropriate.
The City Official Plan currently includes a structure with a series of nodes and corridors at various scales. Given the Regional Official Plan will identify, “Strategic Growth Areas,” will these local areas need to be reflected in the Regional Official Plan? The scale of some of the smaller neighbourhood nodes may not be appropriate for a Regional Official Plan. It is unclear if the local municipalities can identify intensification areas outside of what is identified at the Regional level; we believe that flexibility should be provided.

Major Transit Station Areas (MTSAs)
The City of Waterloo recently completed an extensive MTSA planning process over the course of several years. The Station Area Plans (SAP) were adopted by Official Plan Amendment in June 2017. The SAP process was an extensive, open public process that involved many stakeholders, landowners and collaboration with adjacent municipalities and the Region of Waterloo. Part of the planning process was to determine the limits of the SAP areas where new policies apply. The SPA boundaries and policies were adopted by Waterloo City Council and subsequently approved by the Region of Waterloo. The draft guideline documents outline that upper-tier municipalities will delineate station areas boundaries as part of an MCR. Provisions in the guidelines should clarify that comprehensive planning of MTSAs that have been recently approved should be recognized, where applicable. The SAP already outlines land use direction and policy that will help to ensure Station Areas are planned to be transit supportive, and meet the intent and objectives of the Growth Plan.
Unlike greenfield or Employment Areas, the draft guidelines detail that density in MTSAs should be measured on a gross level without any exclusion areas. The result of such a measure is higher densities to account for areas that do not allow for development such as parks. The LRT in Waterloo includes a station stop in Waterloo Park (a large City-wide park in central Waterloo). The park adds great amenity to the City, and serves as a popular destination point. Land uses such as these should be able to be excluded from the density requirements of MTSAs, otherwise densities of surrounding areas may need to be increased significantly to make up for the park’s lack of density.
Page 48 of the document notes that one of the goals of MTSAs is, “maximizing the number of potential transit users.” Areas such as city-wide parks can attract large numbers of transit riders, thought they do not contribute to planned density. Parks do, however help to create complete communities and make transit station areas more attractive and viable. One way to mitigate some of the density requirements is to allow density to be averaged over several MTSAs rather than at each individual station area.

Municipal Comprehensive Review
Given that the Region of Waterloo does not currently include Employment Areas in the Regional Official Plan, the City has strong interests in participating in the MCR process for Employment Areas. Furthermore, to fully implement the policy direction from the Station Area Plans, considerations for additional uses will be required for the City’s Employment Lands given that many in Waterloo overlap with identified MTSAs.
City staff recommend the direction provided in the MCR guidelines more explicitly specify the local- tier municipalities’ role to ensure local municipalities have a strong voice in the MCR process given that much knowledge and expertise, particularly employment area expertise, currently lies at the local level. Local municipalities should have a role in participating in the MCR beyond providing data and mapping; local municipalities should be fully involved throughout the MCR process beyond being consulted for the process.
Some additional guidance could be provided regarding how to manage development applications received before an MCR is completed. Various scenarios could be considered. For example, the City’s greenfield density policies in the Official Plan are currently deferred. Other municipalities may have similar policies under appeal.