Thank you for the…

Thank you for the opportunity to comment on proposed changes to Ontario's Growth Plan for the Greater Golden Horseshoe.

1. Kitchener appreciates the opportunity to review and comment on the proposed amendments, regulations and provincially significant employment zones. At a high level, staff will be able to adjust and work with the majority of the modifications.

2. Additional clarification on implementation would be appreciated. As a local-level municipality, Kitchener is the front-line for implementation in zoning, official plans and dealing with development applications, proposals and the industry.

3. It would appear as if much of the focus remains on upper- and single-tier municipalities, “in consultation with” lower-tier municipalities. Please confirm that is the case throughout the plan and specifically for proposed Policy 2.2.8.4 (settlement area boundary adjustments) which mentions ‘municipalities.’

4. Kitchener is well-positioned to have the capacity and ability to plan to achieve all of the targets: UGC, MTSA, Intensification Level, DGA density and Employment Area density that are set out or to be established for our upper-tier municipality (Region of Waterloo).
• From Kitchener’s experience, and given the amount and scale of annual development in our Region, staff recommend the Intensification level target is based on a five-year average. This is close to being consistent with the province’s first monitoring report and could align with census years for other data report reasons.

5. Although reference to “environmentally sustainable communities” is maintained throughout the plan, it would be more ideal to retain and establish more specific, definitive targets – such as net-zero ready. A general, encompassing word like ‘sustainable’ makes it challenging for stakeholders, including the development industry, to strive for. A specific goal or target helps.

6. Lack of housing supply is mentioned and the statement about there being an adequate supply of land designated for development is deleted. Given that Kitchener has an appropriate supply, perhaps these generalizations throughout the GGH could be adjusted.

7. On page 12, there is newly proposed text about providing flexibility for local decision-makers; however, in the plan it remains primarily upper-tier decisions.

8. It would appear that Transit Supportive development is not broadly supported through GGH and only promoted in “larger urban centres” (p.12) but it is not clear what constitutes a larger urban centre. A more focused application of transit supportive development principles implies that lower density single use development will be supported in some areas of the GGH. Kitchener is concerned that this form or urban growth is not manageable.

9. If development is to be for “people-first,” the wording about high quality, attractive public realm, site design and urban design standards should not be removed. Intensification (and greenfield development) works best with a great public realm which can be achieved through urban design approaches.

10. Kitchener appreciates the addition of the word ‘capacity’ in 2.2.2.4 as that is an appropriate way to demonstrate if the target could/couldn’t be achieved.

11. For 2.2.3, although there are no changes proposed, Kitchener has established a target of 225 RJs/ha in our Official Plan and is well on its way to achieving that before 2031. Staff may be willing to see that added, or perhaps even a target of 250, in the Growth Plan to separate the City from the rest of the pack identified in 2.2.3.2.b).

12. *Policy 2.2.2.5 – staff need the ability to delineate MTSA boundaries and density targets in the ‘local-level’ Official Plan in advance of an MCR/Upper-tier comprehensive amendment.

13. With all of the proposed modifications to the Employment policies in 2.2.5, there appears to be less direction and certainty. Kitchener primarily has employment areas or lands (non-provincially significant). Deletion of ‘prohibiting’ could be problematic and lead to more “grey area” in terms of implementation and development proposals. This is important at the local, zoning level. The proposed changes to the policies have the effect of limiting the original intent with respect to the desire to truly protect employment areas, save and except provincially significant employment areas. Staff would argue that non-provincially significant employment areas are equally important to the economy and should garner some consideration for protection. Once these areas are removed as employment areas, they are gone. All employment areas are important in contributing to places for jobs, and are typically in more accessible locations that do not require long commutes. They are also important for a complete community, particularly in the Kitchener context.

14. It would appear that the changes to the density targets for employment areas is to allow for different targets for different forms of employment areas. If this is the case, it could be more clearly stated.

15. Deletion of existing Policy 2.2.5.4 – clarity sought on whether an employment strategy needed is still required.

16. New Policy 2.2.5.7 – establishing a size or scale threshold for major retail within an employment area is problematic and appears to contradict the intent of these areas for skilled labour and professional jobs. Once these industrial and/or office employment areas are converted or used for commercial or other purposes, they are rarely ever re-established. This makes it significantly difficult to retain a sufficient land supply into the future for a balanced economy. Major retail should be prohibited. New Policy 2.2.2.11 is not ideal and should be removed for clarity.

17. Staff disagrees that new Policy 2.2.2.10 does not require b) and c) of the preceding policy to be satisfied. The primary goal should be to ensure we have enough land to accommodate employment growth (and for the long term).

18. Can a proposed conversion of employment areas/lands be initiated privately or by lower-tier municipality or upper-/single-tier municipality? Who has to demonstrate the ‘need’? We suggest the policies be clarified to be for municipalities to initiate.

19. Policy 2.2.5.10 b) – clarity sought on what a significant number of jobs entails.

20. Provincially Significant Employment Zones:
• Can the word ‘Zone’ be changed to ‘Area’, ‘Location’ or ‘District’? It may become confusing at the implementation stage with zoning.
• We have review the small portion of proposed location #23 – Cambridge North that is within the City of Kitchener. These appear to primarily be provincially owned lands, but for the most part they are not designated nor appropriate for industrial employment uses. We have prepared a map illustrating the local land use designations, such as Commercial and Natural Heritage Conservation, to illustrate. There is portion of land fronting Sportsworld Drive that we recommend could be included within a revised boundary. Please see attached.

21. Staff agree with new Policy 2.2.2.14. This principle of retaining space for a similar number of jobs on an employment redevelopment is a good one to achieve and that we are utilizing for some of our sites in our LRT area that are undergoing this transition. Having said that, it is still somewhat unclear and there remains some confusion with employment ‘area’ vs employment ‘lands’.

22. It would appear that an office park is no longer considered an employment area? This could be of concern. Perhaps the ’office park’ term should not be revised to remove it as an employment area and instead Employment Area term should be revised to include office parks.

23. Policy 2.2.7.a) – there is still a bit of unknown with the wording of ‘achieve within the horizon of this plan’. A municipality can ‘plan’ for targets and can designate and zone land to allow it to be achieved, but we do not fully control the timing of when it is built, which is tough if it needs to be by a certain year.

24. Section 2.2.8:
• Can “in consultation with the lower-tier municipality” please be added to clause 2 and any others?
• We expect our Regional Municipality to have comments on this section given that settlement/urban areas are determined through their process and Official Plan.
• The Grand River Conservation Authority may comment as well. In our area, watershed planning has consistently been a cornerstone of planning our urban and rural areas and the proposed amendment wording appears to “water down” the importance of that.
• For Policy 2.2.8.4 – please clarify if intent and use of ‘municipalities’ means ‘upper- or single-tier’ take the lead and ‘lower-tier’ would reflect in our plan once the adjustment is made in the upper-tier plan. Regarding clause a) no net increase in land – this is a good principle.
• What if a land needs assessment identified that additional lands are not needed for a settlement expansion? This does not seem to be addressed. Policy 2.2.8.5 e) appears to be looking at it ‘after the fact’ and therefore is not proper planning and should be removed/ revised.
• We are not sure what the background, or data, is behind the 40 hectare clause.

25. Policies 3.2.6.2.c) and 3.2.7a) – clarity sought on what would qualify as ‘equivalent.’

26. Section 4.2 – informed by watershed planning should be retained. Watershed planning also typically includes identification and analysis of the significant natural heritage features. This could be identified in 4.2.1.3.

27. Section 5.2:
• Policy 5.2.2.3 – does ‘municipal request’ include by a lower-tier?
• Policy 5.2.5.3 – since ‘delineate’ is used in the qualifier statement it may not be needed in ‘delineated’ built-up area. The designated greenfield area is delineated in upper and lower tier official plans so it is unclear why that whole clause is to be removed. Should the DGA stay or is intended to not be listed?
• It is not clear how the plan of subdivision lapsing provisions mentioned in 5.2.8.3 and 5.2.8.4 help manage the supply of land as noted in 2.2.1.6.

28. It is not clear why upper case 'M' in legends on Maps is used.

29. Some items in the legends of the Maps are difficult to locate or interpret, especially on Schedules 5 and 6.

30. Overall, it may be more challenging, and potentially slower, for upper-tier municipalities to conduct and finish the MCR if there are numerous ad-hoc applications, conversions or changes proposed in advance that must be dealt with. This could have the opposite effect of getting these reviews done.

31. Stability in the provincial planning policy environment would be helpful. There is a lag-time to get to full implementation complete at the local level and it can be challenging if there are continuous changes at the provincial and upper-tier level.