The province’s proposed changes to its growth plan for cities in the Greater Golden Horseshoe area are “overly ambitious for Guelph” and could result in a host of negative effects, including a faster decline in the local supply of “ground-oriented housing,” says a new city hall report.
Council will discuss the hard-hitting report, which is city staff’s response to a major land-use planning review being done by the province, on Oct. 24. Staff want council to endorse the report and submit it to the province by an Oct. 31 deadline.
The province’s proposed higher intensification targets “will present significant challenges in planning for future growth in Guelph,” the report says. They would “require the city to revisit the vision for the city” set out in Guelph’s local growth management strategy, “including a reconsideration of the height, density and form of future development.”
Guelph’s local growth management strategy was developed over a period of years as the city’s way of dealing with the province’s Places to Grow Act of 2005. Through a later amendment in 2013, the province’s growth plan set a new population target for Guelph of 177,000 people by 2031 and 191,000 by 2041, with job targets to match.
Now the province is proposing further changes that would raise the required percentage of new development that must go into built-up areas of the city to 60 per cent, from the 40 per cent currently called for in the growth plan. Minimum density targets for residents and jobs in the city’s remaining greenfield area would also be increased.
The report says the province’s proposed amendments to the growth plan are “overly ambitious for Guelph as a single-tier, outer ring municipality” on the edge of the area covered by the Greater Golden Horseshoe area.
“The density targets introduced by the proposed growth plan will create an unrealistic growth scenario for the city,” it says. “As currently proposed, the policies will require the density of future growth to compensate for the greenfield development that has been planned over the past 10 years” under the existing growth plan’s target of 50 residents and jobs per hectare in greenfield areas.
To satisfy the proposed higher greenfield density target of 80 residents and jobs per hectare, Guelph’s remaining greenfield area “would have to be planned at densities between 95 and 100 residents and jobs per hectare,” the report says.
“The effect of this will be that the densest neighbourhoods outside of the downtown will be positioned towards the fringe of the city. This will result in an inefficient distribution of growth and servicing infrastructure.”
City hall started work on the local growth management strategy in 2006 as a multi-year process with public involvement. The aim was to determine how to conform to the provincial growth requirements while maintaining Guelph’s “existing character” and accommodating growth “in appropriate areas at a scale and density that maintains the city’s mid-rise form,” the report says.
Since 2008, an average of 474 residential units a year has been built in the city’s built-up area, accounting for 40 per cent of new development, it says. The proposed higher intensification target of 60 per cent would mean that an average of about 700 residential units a year would need to be constructed in the built-up area in order to meet both the increased intensification target and the growth plan’s population forecasts.
Opportunities to provide a desirable range and mix of housing types that are affordable to city residents is a concern with the proposed new density and intensification targets, the report says.
“Housing choice and affordability is becoming an issue in some parts of the Greater Golden Horseshoe, where the supply of ground-oriented housing has declined in favour of multi-unit mid to high rise development,” it says.
“Guelph is supportive of the evolving housing mix resulting from the current growth plan and aims to gradually evolve the city’s housing mix such that 50 per cent of development will be in multi-unit forms by the year 2031, with the remaining 50 per cent in low density ground-oriented forms.
“However, the divergence from the existing growth plan to significantly increase the densities and intensification target will result in a much more significant and rapid decline in the supply of ground-oriented housing,” the report warns.
City staff want the province to change its mind about imposing the same new requirements on all municipalities in the Greater Golden Horseshoe area, saying that this “creates unnecessary challenges” in fulfilling the vision of Guelph’s growth plan.
“It has become apparent that imposing the same requirements and targets for all municipalities in the Greater Golden Horseshoe is not appropriate given the diverse nature of those municipalities,” the report says.
One of the different things about Guelph is its reliance on groundwater and on a small river that limits how much wastewater can be discharged, says the report.
It says the city doesn’t want to be forced by unrealistic growth expectations to have to look beyond its finite local water resources. City hall is “committed to growing the city through the sustainable use of local water resources. The City of Guelph is not supportive of growth levels that would trigger the need to examine inordinately expensive regional or provincial servicing solutions.”
The province’s growth plan should recognized that Guelph has water resource limitations and that servicing constraints might limit the city’s ability to accommodate future growth allocated beyond 2031, the report says. “The province should also enhance funding for infrastructure projects that would support locally sustainable solutions,” it says.
The report also calls for the province to “shield” municipalities from appeals to the Ontario Municipal Board when they amend their Official Plans to conform to the province’s growth plan. Guelph’s Official Plan amendment No. 48, the final phase of its Official Plan amendments to conform with the province’s original growth plan for the Greater Golden Horseshoe area, is still under appeal at the OMB, the report notes.
The province’s current land use planning review is a co-ordinated review of four provincial plans – the growth plan for the Greater Golden Horseshoe area, the Greenbelt Plan, the Niagara Escarpment Plan and the Oak Ridges Moraine Conservation Plan. The simultaneous review of all four plans is intended to recognize the common geography and interconnected nature of the policies, the report says.
The Greenbelt doesn’t currently reach as far as Guelph, and no changes for expanding the Greenbelt that would directly impact Guelph are being proposed at this time as part of the province’s coordinated review.
While the province is proposing new urban river valley connections through the Greater Toronto Area to Lake Ontario, no connections to Lake Erie – including through Guelph – are being proposed in the coordinated review, the report says. Guelph’s two rivers drain into the Grand River, which drains into Lake Erie.
Support for community energy planning
A common theme to the province’s proposed amendments to the four plans is that proposed changes aim to help Ontario in “being a leader in the fight against climate change,” the report says.
One of the city hall report’s responses to the province’s concerns about addressing climate change calls on the province to increase its support for community energy planning and thermal-energy distribution systems.
This staff response comes in the context of an ongoing review of the city’s Community Energy Initiative, as well as considerable controversy in Guelph this year over the future of district energy systems, which heat and cool buildings through hot and cold water sent through underground pipes.
“Thermal distribution systems provide a pathway for municipalities to achieve very low or net-zero greenhouse gas emissions across their communities,” the report states.
“The province could enhance their support for community energy planning by providing additional funding and establishing provincial standards for community energy planning that can functionally be implemented by municipalities,” it says.
“The province could provide additional support for thermal distribution systems by providing municipalities with additional tools to motivate users to connect to the system, including providing financial support for municipalities, agencies and their partners to build and expand thermal distribution infrastructure to reduce the financial burden on municipalities.
“The economic viability of a municipal thermal distribution system comes into question when municipalities must bear the large up-front cost of building and installing the system when considering that these systems have a long payback period,” it says.
Among other things, the report also asks the province to back off when it comes to encouraging use of geothermal energy in places like Guelph that rely on groundwater for drinking.
The city “recommends caution with the promotion of technology that poses environmental concerns,” the report states.
“The proposed growth plan promotes the identification of opportunities for energy conservation, including renewable energy systems and geothermal technologies,” it says. However, “it should be noted that geothermal technology has the potential to leak contaminants into the ground and groundwater, which creates concern for a community such as Guelph which relies on groundwater as its primary supply of water.
“Source water protection must have priority over alternative energy systems,” says the report.