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COMMENTS ON OFFICIAL PLAN OF THE TOWNSHIP OF ALNWICK / HALDIMAND
PREPRARED ON BEHALF OF VALLEY VOICES RESIDENTS ASSOCIATION
Introduction
Valley Voices Residents Association (“VVRA”) has a membership of over 200 Township residents located predominately in the south of the Township. Although VVRA’s main object is to represent its members in opposition to the application for gravel pit licence by Shelter Valley Aggregates, it recognizes that the Township’s Official Plan is one of the most important planning documents affecting all members. VVRA understands that the current Official Plan was adopted by Council in July 1994, subsequently approved by the Province in 1996. This Plan will be replaced by the proposed draft Official Plan which also includes the former Township of Alnwick.
The goals, objectives, and policies contained in this Official Plan will guide the development of this Township for the next 20 years and must be carefully considered.
Provincial Policy Statement
The Council of Alnwick / Haldimand has always been most concerned about costs and in particular, keeping costs and taxes as low as possible. VVRA commends the Council for this responsible approach. Nonetheless, VVRA believes it is short sighted if the Council adopts this Official Plan at this time without awaiting for provincial planning reform contemplated in the consultation discussion papers; in particular, the Provincial Policy Statements (“PPS”) (Discussion Paper #2). This proposed Official Plan has regard to the existing PPS. Many radical changes to the PPS are proposed, as well as amendments to the Planning Act to give the Policy Statements greater importance in the planning process (i.e. the decision may be required “to be consistent with the PPS”). Council has indicated that they will let the Province make the changes because the Province has to approve the Official Plan under the Planning Act. Looking at past approvals, since the Province may take a considerable length of time to approve the Plan, it may be prudent for Council to wait for the legislative changes and provide an Official Plan that is consistent with the PPS rather than waiting for the Ministry to look at the Official Plan and refer parts back for modification. This double review will cost more than waiting. VVRA does not understand the rush. A five year review of the Plan is no longer required under the Planning Act and much of the Township is under the Oak Ridges Moraine legislation.
The PPS, of course, if implemented, would require many changes to this OP including the differentiation between the rural and prime agricultural areas which limit residential development in rural areas, the promotion of development and implementation of planning strategies for rural areas, discouragement of scattered and strip development, limitations on lot creation, the elimination of rural non-farm severances ( i.e. farm retirement lots), protection of specialty crop areas and, aggregate extraction will need to manage social and environmental impacts.
Oak Ridges Moraine
The mapping of the Oak Ridges Moraine boundaries in the Township is of concern to VVRA. VVRA understands that the mapping has been done by the Ministry of Natural Resources and questions whether the Council has discussed the mapping of the southern boundary of the Moraine. The mapping of the Moraine shown on the maps for the Official Plan and the Secondary Plan does not appear to make sense at the south end. There was an opportunity to have these reviewed and we understand that the municipality did not undertake the review because of the cost. This is short sighted. VVRA would suggest that all possible avenues be explored to ensure that the southern boundary of the Moraine is properly mapped. We understand this needs to be done through consultation with the Ministry of Natural Resources and the Ministry of Municipal Affairs and Housing and it is not too late.
Specific Policies
VVRA has the following comments on some of the policies in the Official Plan.
Policy 1.3.1 - General
It might be helpful to refer to the purpose of an Official Plan, i.e. “Statement of principles, goals, objectives and policies intended to guide future land use, physical development and change.”
It might be helpful to be more specific about how the Plan will direct Council vis-à-vis public decision making, i.e. “The basis for preparing zoning and other by-laws to implement planned use.”
Although the Oak Ridges Moraine Plan is referred to in Policy 11.1, it would be helpful to reference the relationship between this Official Plan and the Oak Ridges Moraine and legislation in the general Policy 1.3.1.
Policy 2
The objectives of the Plan do not include the development of Tourism which has been recognized as economically important to the Township, both on Rice Lake and in the south, including Shelter Valley. Heritage Conservation and the unique environmental features are the basis of this Tourism. It would be helpful if the objectives were reworked to recognize Tourism. We note that Policy 2.3.7 would be contrary to the proposed PPS.
Policy 2.3.8
“Public services” are not a defined term in the Plan and Policy 3 refers to “services” and Policy 3.8.2 refers to “public services”. There should be consistency.
Policy 2.3.9
This should be consistent with Policy 2.3.2 and would be best included in Policy 2.3.2.
Policy 2.3.1
Policy 2.3.1 addresses “high agricultural capability”. It is not a defined term and potentially is in conflict with the new PPSA.
Policy 3.4 - Parks and Recreation
This is a predominately rural municipality. It is difficult to understand why such a complex park hierarchy is being proposed in this Plan. These are the kinds of hierarchies that are generally applicable in large urban centres. Keep it simple.
Policy 3.6
It is not clear if Environmental Protection Area can extent outside the ESA. If Tourism is important and typography is what makes the Township unique then reference to Tourism should also be included or there should be a cross reference between Tourism and this Policy and as indicated there should be a separate Policy on Tourism.
Policy 3.7.1
The lot size refers to Policy 3.2. These policies address water supply and sewage. Should there not be some reference to the location? i.e. Whether it is in hamlet or not? Also, this may be contrary to the new PPS and will be amended.
Policy 3.10 Aggregate Resource
These policies reflect the existing PPS but will not be consistent with the new PPS.
Policy 3.11.2
What is a “major development”?
Policy 3.12 Land Use Compatibility
Compatibility should address more than sensitive land uses and industrial uses. There is no recognition or compatibility between agricultural and rural residential. The Nutrient Management legislation should also be considered. Agricultural usage should be protected against residential encroachment and complaints.
Policy 3.17
This Policy should establish appropriate locations for Bed and Breakfast establishments consistent with Tourism provisions which have to be developed. What happens when B&B’s are in a rural setting? Where should they be located? The policies, as drafted, appear to be those that are more appropriate for an urban centre and perhaps should be part of a “Tourism” Policy.
Policy 4.2 Land Severance
These Policies will be contrary to the new Official Plan (4.2.3 in particular).
Scenic Routes
Scenic routes should be able to be identified and protected in the Plan. Whether this is part of Tourism Policy or included in Policy 8 or 9 is to be determined.
Policy 8
Natural environmental features are key to this Plan and are referred to in Policy 2.3.2 as “environmental qualities” but, in Policy 8 as natural environmental features. There should be consistency between Policy 8 and Policy 2.3.2.
Policy 8.7
How are the “fish and significant wildlife habitat’s” in Schedule “A” identified? Was the DFO involved?
Conclusion
As stated, this is a very unique Township for many reasons including the natural environment. VVRA believes that a further opportunity should be given to the ratepayers to review the Plan in more detail. The next 20 years could be crucial to the development of the Township and Tourism may become its chief economic engine. If the Township Council is prepared to wait until the Provincial policies are in place, it will have a better Official Plan because there will be more input from its residents. VVRA does no understand the rush to approve the Plan, but hope these comments are helpful.
