In reviewing the proposed…

In reviewing the proposed guideline, it would appear that AOI's are proposed to be increased significantly - in almost all cases more than 2x, if not 5x when comparing the proposed AOI's with current Potential Influence Areas. I would like to know specifically how this corresponds with Provincial Policies aimed at facilitating residential intensification and infill development? What about housing affordability?

For example, in my community, Sault Ste. Marie, we have Algoma Steel, a long standing, significant employer, surrounded by numerous residential neighbourhoods. The 2km AOI encompasses many of these neighbourhoods, not to mention a significant portion of our Downtown. In fact, when applying the new AOI's to known industrial uses in our community, I suspect a significant portion of our urban residential neighbourhoods are within an AOI and vice versa. The nature of development in SSM is relatively small scale, to a point where the required studies for a small scale residential intensification project could be a deal breaker for the developer. Again, how does this align with PPS policies on residential intensification and infill development? I would like to see amendments that might provide exemptions or flexibilities based upon the overall scale of development. I understand that subdivisions and large scale residential developments should do the required studies, but requiring a study as part of a complete site plan control application for a 4-plex seems like overkill.

Section 4.2.3 of the proposed guideline speaks to 'considerations for infill and intensification scenarios' and notes that 'it is recognized that locating sensitive land uses outside AOIs and MSDs may be more complicated...', but the ensuing discussion fails to address these complications in any meaningful way. Rather, the discussion reiterates that compatibility needs to be adhered to and fails to recognize what infill development actually consists of, at least in the context of SSM - new small scale development surrounded by existing development. There is no recognition of small scale development. Furthermore, going back to the Algoma Steel example, a parcel 1.5km away would be separated by 1.5km of urban development - that could be as much as 10 city blocks! To this end, I would also like to see a recognition that 'intervening development' between a noxious and sensitive use may be such that it is appropriate to waive the need for a study under certain circumstances.

I also note that the City of Sault Ste. Marie is currently in the process of creating a new Official Plan, as well as an EA to expand the City landfill. The draft policy does not have any dialogue related to transitional matters. Given the significant increases in AOIs, this could have significant implications on both projects and these matters should be communicated now, as part of this EBR posting.

Unlike many parts of the GTA, SSM is not growing to a point employment areas and large scale neighbourhoods are being planned for and developed over the course of a decade. In SSM, our development is truly 'infill' and small scale, the type of development that may not proceed if an additional study is required to assess impacts of an industrial use that is 2km away with 2km of urban development between the noxious and sensitive use. I feel that the guideline as proposed will simply drive developers to the periphery or rural area of the community, which is not in keeping with PPS directions on intensification, infill development, etc...