Halton Region Official Plan Review - Written Submission
7/11/2021
We Love Millcroft is a neighbourhood association which represents the residents of the Millcroft community and Burlington. The main focus of our association is to maintain the existing Millcroft Golf Course lands as Major Parks and Open Space permanently.
On behalf of our community, we have reviewed Halton’s ROPA 38, ROPA 48, the ROPR presentations, the Strategic Business Plan and the Natural Heritage Discussion Paper to check the alignment of our goal. Additionally, we have reviewed the “Submission on the Land Use Planning Framework in Halton provided to the Review Panel for the proposed Milton Logistics Hub Project”, (May 29, 2019). The highlights of these documents, together with our comments and conclusions follow.
In the Regions words,
“1. This Regional Official Plan, or commonly referred to as The Regional Plan, is
adopted by the Council of the Regional Municipality of Halton to solidify decisions taken
in the past and to give clear direction as to how physical development should take place
in Halton to meet the current and future needs of its people. It is also intended to reflect
their collective aims and aspirations, as to the character of the landscape and the quality
of life to be preserved and fostered within Halton. Finally, the Plan clarifies and assists in
the delivery of Regional services and responsibilities as set out in the Planning Act, the
Municipal Act, and other pertinent Provincial legislation.
2. This Plan outlines a long term vision for Halton's physical form and community
character. To pursue that vision, it sets forth goals and objectives, describes an urban
structure for accommodating growth, states the policies to be followed, and outlines the
means for implementing the policies within its property tax base and other financial
resources.
3. Policies of this Plan indicate positions to which Regional Council is committed or
which Council will work towards attaining. They also describe processes to be followed
in arriving at decisions, changes to be sought in Provincial legislation, and policy
positions to be required in the Official Plans and Zoning By-laws of Burlington, Oakville,
Milton and Halton Hills. “Strives to define planning expectations for each category to provide a comprehensive land use framework. The “zero-sum” framework means that a loss to an identified planned function represents a cumulative effect.”
The Region of Halton Official Plan Amendment 38 received approval from the Province in 2011. This document provides a clear vision for the future growth and development in the Region including infrastructure and development to the year 2031.
Section 5.3 provides Halton’s Planning Vision through the Official Plan advocating at the beginning of Part II (Basic Position, Halton’s Planning Vision) as a balanced approach to land use planning including protecting the natural environment. Section 25 of the ROP states: “Regional Council supports the concept of “sustainable development” meeting the needs of present and future generations.”
The Region’s principles of sustainability include that:
- natural resources are not being overused
- natural environment is not degraded
- this and future generations capacity to meet their physical, social and economic needs are not being compromised.
The overall goal is to enhance the quality of life for all people of Halton today and into the future. It is stated that the emphasis on this core value is on “quality of life” and the focus is not only this but future generations.
In section 26, the Region’s approach to and its position on Growth is
…”In this regard, Halton will undertake the necessary steps to ensure that growth will accommodated in a fashion that is orderly, manageable, yet sensitive to the natural environment, heritage and culture. To maintain Halton as a desirable and identifiable place for this and future generations, certain landscapes must be preserved permanently. This concept of “landscape permanence” represents Halton’s fundamental value in land use planning and will guide its decisions and actions on proposed land use changes accordingly.”
The concept of “landscape permanence” is a proactive way of dealing with land use changes – advocating a gradual pace of incremental changes in the landscape over time such that Halton will remain recognizable and maintain its character. This approach of identifying categories of land uses and setting out clear objectives and policies to define planning expectations for each category to provide a comprehensive land use framework. The “zero-sum” framework means that a loss to an identified planned function represents a cumulative effect.
Key Messages from the Community
1) The importance and role of the natural environment for current and future generations quality of life. Millcroft Golf Club (MGC) continues to be identified in both the Region of Halton and City of Burlington’s official plans as Major Parks and Open Space for this purpose.
2)To maintain certain identifiable landscapes permanently. MGC is the identity of the Millcroft neighbourhood and was developed to provide a natural environment within our neighbourhood and City. Many marketing programs for new development in North Burlington advertise the proximity to the Millcroft Golf Club. Adi in Alton and Branthaven in Millcroft are examples.
3) The zero-sum equation for land use is critically important for residents of the City of Burlington (COB). If the Millcroft Golf Course were to be developed, this greenspace is gone forever.
Highlights for City of Burlington from Adopted Regional Official Plan Amendment 48
Regional Nodes are defined as strategic growth areas which have a role in accommodating mixed-use intensification and supporting the regional transit network. Uptown Urban Center located at the corner of Appleby Line and Upper Middle Road is designated as a Primary Regional Node.
Dundas Street and Appleby Line are designated as Higher Order Transit Corridors. Dundas Street connects Burlington to Hamilton to the west and Oakville to the east. Appleby Line has an interchange at Highway 407, QEW and is a transportation route to the Appleby Go Station, considered a Major Transit Station Area.
Burlington residential housing growth going forward is limited to mixed use and brownfield higher density development. ROPA 48 does not include any no new greenfield development within the current urban boundary.
Growth targets for the City of Burlington will be achieved by densification/intensification.
The Region has engaged a consultant to study and minimize GHG emissions as part of the ROPA 48
Key Messages from the Community
Millcroft Neighbourhood is bordered by Dundas Street to the north, Appleby Line to the east and Upper Middle Road to the south. In addition to ROPA 48, the CN Rail line which, if approved will experience more frequent trains and increase truck traffic along the east side of our neighbourhood. It is of note that the Region of Halton has launched a lawsuit to stop the CN Rail Hub based on environmental concerns. The proximity of our neighbourhood to the Rail line, two Higher Order Transit Corridors and the Uptown Urban Centre will result in significant GHG emissions, a significant topic of the ROPA 48. MGC is and area of approximately 100 hectares of turf that is home to a significant, mature tree canopy. This is a significant mitigating factor for GHGs must taken seriously and this greenspace must be permanently protected for this and future generations.
Submission on the Land Use Planning Framework in Halton, provided to the Review Panel for the Proposed Milton Logistics Hub Project (May 29, 2019) by Curt Benson
The Panel’s interest in expert opinions highlights areas of concern that should be addressed by the Region of Halton.
The Panel was interested in expertise related to
- the magnitude, geographic extent, timing, frequency, duration, reversibility, and ecological and social context of the Project’s anticipated adverse environmental effects
- the predicted effectiveness of proposed mitigation measures
The Review Panel also asked Halton Municipalities to provide expertise related to municipal interests and standards in water, natural heritage, transportation, agriculture, residential and employment matters.
The Regions response identified the importance of the land use planning framework in defining standards for managing and assessing growth and development in Halton.
In this regard, the submission highlighted the following information to address:
· the importance of the Regional Official Plan in the land use planning framework, including the significant process undertaken to define a comprehensive vision for Halton through Sustainable Halton;
· Regional Council’s long-standing interest in planning, growth management and the protection of natural and agricultural resources given Halton’s context in the greater Toronto-Hamilton area;
· The integrated nature of planning in Halton and the approach taken to ensure that growth only occurs in a coordinated and comprehensive fashion, and that growth includes infrastructure and financial plans to ensure the development pays its share of costs related to growth; and
· The core values found throughout the Regional Official Plan of environmental protection, farmland preservation, proper management, coordination and financing of growth, the support for “complete” and healthy communities, and sharing of planning responsibilities with the local municipalities.
Key Messages from the Community
- integrated nature of planning to ensure growth only occurs in a coordinated and comprehensive fashion. MGC zoning as Major Parks and Open Space should not be compromised in any way.
- core values found throughout the Regional Official Plan of environmental protection, support for complete and healthy communities. Millcroft, is a complete community and the MGC functions as a carbon sink to offset GHG emissions including from the CN Rail Line.
Halton Region Strategic Business Plan 2019 – 2022
The Strategic Business Plan provides a comprehensive review, examining the Region’s interrelationship of growth, natural heritage systems, agricultural heritage systems and climate change.
The purpose is to ensure that the necessary infrastructure and services are in place to maintain the high quality of life as the Region continues to grow. It addresses Environmental Sustainability and Climate Change by identifying related UN Global Sustainable Development Goals (SDGs).
The five categories of the Strategic Business Plan are:
Within these categories, two are very applicable to our concerns for preserving the MGC
1) Planning and Growth Management includes two actions that have specific interest
- Natural Heritage System and Review
- Climate Change mitigation and Adaptation
2) Environmental Sustainability and Climate Change includes of interest to our goal
- Review the Region’s Greenland securement and Regional Forest programs, including opportunities for enhanced coordination with Conservation Halton
Key Messages from the Community
MGC plays an important role in stormwater management for our community and for downstream Burlington. Three watersheds, Sheldon Creek, Appleby Creek and Shoreacres Creek are impacted by the green infrastructure stormwater management system that is an integral part of the MGC design. The importance of this function resulted in OPA 117 (1984) and is supported by engineering reports. The establishment of this stormwater system before the current heightened concerns for flooding as a result of climate change are notable. The golf course currently has an extensive, mature, parkland tree canopy which assists with GHG mitigation, flooding mitigation, a cooling effect and noise abatement. The entire MGC should be saved from the threat of development. We believe that a forest saved from development may qualify as a carbon offset for GHG emissions.
Natural Heritage Discussion Paper (June 2020)
The Natural Heritage is central to the Planning Vision for the Region of Halton. Halton has been at the forefront of natural area planning since the 1980’s.
“A Natural Heritage System is defined in the NHS protection and enhancement is an important part of responding to climate change in terms of both adaptation and mitigation. The NHS provides for more resilient environments and can allow opportunities to reduce impacts of flooding and other risks associated with extreme weather events. NHS protection and enhancement can also play an important role in acting as a carbon sink to reduce green house gas emissions.”
Our review of this document notes two main concepts
1. Sustainable Development – protecting the natural environment is a vital factor
2. Landscape Permanence – although the Region will urbanize and change, certain landscapes must be preserved permanently.
A Natural Heritage System (NHS) is defined in the PPS 2020 as:
“…a system made up of natural heritage features and areas, and linkages intended to provide connectivity (at the regional or site level) and support natural processes which are necessary to maintain biological and geological diversity, natural functions, viable populations of indigenous species, and ecosystems. These systems can include natural heritage features and areas, federal and provincial parks and conservation reserves, other natural heritage features, lands that have been restored or have the potential to be restored to a natural state, areas that support hydrologic functions, and working landscapes that enable ecological functions to continue…”
The Growth Plan 2019 suggests a similar approach to that of the Greenbelt Plan 2017.
In this regard, Section 4.1 of the Growth Plan 2019 states in part the following:
This Official Plan also provides for the identification and protection of a Natural Heritage System for the GGH outside of the Greenbelt Area and settlement areas, and applies protections similar to those in the Greenbelt Plan to provide consistent and long-term protection throughout the GGH. The goal of a Natural Heritage Strategy would be to provide a framework for initiatives to:
• restore habitat and increase forest cover through restoration and stewardship;
• promote natural heritage education and community awareness;
• secure greenlands and their linkages;
• explore opportunities to mitigate climate change; and
• promote and protect the natural environment.
Halton Region has existing programs that would fall under this strategy and help
achieve, maintain, protect and enhance Halton’s NHS. These existing programs include
Greenland Securement, State of NHS Reporting, Halton Region’s Tree By-law, Forest
Management Plans, and strategies for natural heritage preservation and restoration for
the Waterfront Parks Masterplans. Consideration should be given on how to incorporate
policies in the ROP that would support the development of a Natural Heritage Strategy.
Climate Change
Halton’s NHS protection and enhancement is an important part of responding to climate
change in terms of both adaptation and mitigation. The NHS provides for more resilient
environments and can allow for opportunities to reduce impacts of flooding and other
risks associated with the more frequent and severe weather events. NHS protection and
enhancement can also play an important role in acting as a carbon sink to reduce green
house gas emissions.
Through the ROPR, there are opportunities to strengthen a number of natural heritage
hazard lands and water resource goals, objectives and policies to better respond to
climate change and address provincial conformity requirements. ROP policies should be
enhanced to address climate change mitigation and adaptation measures, including the following:
• Building on the existing research and literature to require studies such as
Sub watershed studies to mitigate climate change and extreme weather impacts
on NHS features;
• Development of a Natural Heritage Strategy for Halton Region;
• Preserve and restore biological diversity, water resources and natural features;
• Explore ways to mitigate against climate change events and protect water
resources using low impact development and green infrastructure approaches to
stormwater management; and
• Encouraging joint partnerships with local municipalities and conservation
authorities to find opportunities to enhance and restore Halton’s NHS to help
Natural Hazards
PPS 2020, Section 3.0 Protecting Public Health and Safety, has revised policies to
indicate greater emphasis on avoidance as compared to mitigation of natural and
human-made hazards. The PPS indicates that development should be directed away
from areas where there is an unacceptable risk to public health or safety or of property
damage, and not create new or aggravate existing hazards. The PPS also emphasizes
reducing the potential for public cost or risk to Ontario’s residents from natural or
human-made hazards. Natural Hazards in the PPS include hazardous lands, flooding
hazards, erosion hazards, dynamic beach hazards and wildland fire.
The current ROP policies relating to Natural Hazards need to be strengthened and do
not provide clear direction on Natural Hazard policy and mapping requirements for Local
Municipalities. Consideration also needs to be given on how to include the revised PPS.
Key Messages from the Community
Our review of the Natural Heritage Discussion Paper leads us to the conclusion that there is a compelling case to protect the MGC’s vital natural environment permanently by designating it as Natural Heritage. This commitment by the Region will recognize a very early example (1980’s) of green infrastructure that was established through the “creek-like” intermittent streams built into the fairways of the golf course. As a stormwater management system for the neighbourhood and downstream Burlington it reduces flooding hazards during significant weather events. The golf course consists of greenlands and a mature, significant tree canopy which provide an important mitigation features for GHG emissions in an area designated for growth and major transportation corridors including Appleby Line, Dundas Street and the CN Rail Line.
