RE: Draft Guidance to…

RE: Draft Guidance to Support the Implementation of the Growth Plan for the Greater Golden Horseshoe, 2017
Application of the Intensification and Density Targets

This letter is in response to the Draft Guidance to Support the Implementation of the Growth Plan for the Greater Golden Horseshoe, 2017 as it deals with the Application of the Intensification and Density Targets document, dated March 2018. Staff from the City of Vaughan Policy Planning and Environmental Sustainability Department offer the following comments.

The application of Major Transit Station Area (MTSA) Density Targets

The intent of the MTSA’s is commendable. Specifically, City staff are supportive of the intent to prioritize the planning of MTSA’s in the Growth Plan (2017) and the application of density targets to ensure the intent is realized. In addition, the City supports the notion of prohibiting land use and built form that would adversely affect the achievement of the minimum density targets of the Growth Plan (2017), which is further supported though the protection from LPAT appeals afforded under Section 17 (36.1.4) of the Planning Act. All of these elements reinforce the importance that the Province places in aligning higher order transit with growth.

It is the belief of City staff that upper and lower-tier municipalities must have the discretion to delineate MTSA boundaries to achieve the objectives of intensification while ensuring compatible development, rather than strictly adhering to the 500 metre radius in every case. Each MTSA must be evaluated based on the surrounding context and show sensitivity to land use. The City’s primary concern is that this guidance document appears to indicate a preference by the Province to include stable areas within the delineation of the MTSA boundaries. Given that legislation now protects these areas from appeal and establishes a minimum density requirement, careful consideration and judgement should be used in the delineating exercise.

Vaughan Official Plan 2010 provides an Urban Structure that identifies the fundamental elements of the City. The basis of the City’s Urban Structure relies on the distinction between stable “Community Areas” that are not intended to experience significant physical change, and “Intensification Areas” where the majority of growth will be directed. The City has undertaken a thorough exercise to strategically identify the location of Intensification Areas in Vaughan to accommodate growth and to achieve the City’s required targets.

The draft guidance document identifies stable areas as suitable for being included in MTSA’s most explicitly in section 7.1.1, which states:

MTSAs are not required to be solely areas of high density. Many MTSAs could contain portions of stable neighbourhoods or other areas where the potential for redevelopment is constrained (e.g., certain infrastructure rights-of-way). It is expected that delineation of MTSAs should be done in a transit-supportive manner that supports the goal to maximize the number of potential transit users that are within walking distance of the station or stop. This approach is intended to recognize that even stable neighbourhoods inevitably change somewhat over time, and some level of increased density may eventually be appropriate in these locations which offer excellent access to higher order transit services. A broader delineation from the onset may mitigate the need to revisit the delineation as these areas (and their readiness for redevelopment) continue to evolve over time.

We bring to your attention the following conditions in Vaughan.

• Many of the stable residential areas adjacent to the identified transit stations consist of reverse lot frontages with no access or only limited pedestrian access to the adjacent arterial road system;
• They are characterized by relatively small lots, which were built over the last 30 years, so redevelopment would not be expected to occur in the immediate future;
• Redevelopment within these areas could potentially create a destabilizing effect;
• The City’s Secondary Suite OP policies and zoning are in effect, which gives homeowners an option other than redevelopment;
• In most instances, the transit service has been identified, however are not established. Therefore, it would be premature to conclude that the market reaction would result in immediate intensification;
• Such lands would probably be expensive to assemble and would be unlikely to produce more affordable housing stock if it was replaced with more ground related housing; and
• The City has already designated areas where intensification and redevelopment potential is permitted that are intended to provide higher density and more affordable development on better suited lands (i.e. frontage on and access to an arterial), which will meet the City’s current and long-term intensification needs.

We understand that it is not the intent of the Growth Plan to destabilize neighbourhoods. For these reasons the regional and local municipalities should have the maximum amount of flexibility in defining the MTSA boundaries, based on local conditions, subject to demonstrating that the Regional intensification targets can be met. The Growth Plan provides guidance to 2041. It is quite possible that a future update of the Regional and City Official Plans, between now and 2041, could further expand the boundaries. This would also allow for detailed planning and land use designations to be applied based on specific cases to address some of the issues identified above, in order to ensure an orderly intensification process.

Greater Clarification Required to distinguish the roles between Upper- and Lower- Tier Municipalities in Growth Plan, 2017 Policies and Guideline Document

There is a variety of ways that the Growth Plan (2017) refers to municipalities. When specified directly, such as using “upper- and single-tier municipalities, in consultation with lower-tier municipalities”, the intent is clear. However, in some instances, the use of the term “municipalities” is used generally. For example, policy 2.2.6.4 states, “Municipalities will maintain at all times where development is to occur, land with servicing capacity sufficient to provide at least a three-year supply of residential units.”, in contrast, the phrase “all municipalities” is used in policy 2.2.2.4, “All municipalities will develop a strategy…”. Is the intent of both uses to apply to all single, upper, and lower-tier municipalities in every case? Clarity on this matter, particularly as it relates to the application of density targets in the guidance document would be valuable. Further, the draft Guidance document often refers generally to “municipalities”, however it is not always clear to which tier of municipality it applies.

Thank you for the opportunity to comment on this document. We appreciate the opportunity to be involved in the development of these important Provincial initiatives.