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HomeMy WebLinkAboutPLN 03-15 00 _ Report to === Planning & Development Committee PI KERING Report Number: PLN 03-15 Date: May 11, 2015 From: Thomas Melymuk Director, City Development Paul Bigioni Director, Corporate Services & City Solicitor Subject: Bill 73 — Proposed Smart Growth for Our Communities Act Proposed Changes to the Planning Act and the Development Charges Act Recommendation: 1. That Report PLN 03-15 of the Director, City Development and the Director, Corporate Services & City Solicitor regarding Bill 73 - Proposed Smart Growth for Our Communities Act be received; 2. That the comments with respect to changes to the Development Charges Act, 1997, contained in Report PLN 03-15 on Bill 73 — Proposed Smart Growth for Our Communities Act be endorsed, and that the Province be requested to: a. produce a Regulation pursuant to the Development Charges Act, 1997 which identifies all eligible services as "prescribed services" so that all development charges can be calculated based upon the City's planned level of service over the ten-year period immediately following the preparation of its development charge background studies; and b. delete or substantially amend section 59.1 of Bill 73 — Proposed Smart Growth for our Communities Act so as to enable the City to continue to negotiate agreements with developers for financial contributions over and above the development charges recoverable under the Development Charges Act, 1997; 3. That the comments with respect to changes to the Planning Act contained in Report PLN 03-15 on Bill 73 — Proposed Smart Growth for Our Communities Act be endorsed, and that the Province be requested to: a. extend the timeframe between official plan reviews to 10 years, regardless of whether a municipality is introducing a new official plan, or undertaking.a comprehensive review through an amendment process; b. maintain the current approval process for official plan amendment_ - applications, during the two-year period following the adoption of a new official plan; c. maintain the current approval process for zoning by-law amendment applications, during the two-year period following the adoption of a new comprehensive zoning by-law; 104 Report PLN 03-15 May 11, 2015 Subject: Bill 73 — Proposed Smart Growth for Our Communities Act Page 2 d. maintain the current approval process for minor variance applications and not require applications for minor variances to be permitted only with council approval, during the two-year period following an owner-initiated site-specific rezoning; • e. maintain the current criteria for Committee of Adjustment decisions; f. maintain the current alternative parkland dedication provisions for cash-in-lieu to be calculated at the value of one hectare of land for each 300 dwelling units proposed; g. not include provisions that would allow the Minister or upper tier municipality to force the adoption of a development permit system by a local municipality; and h. include provisions that would enable the closing of dormant planning applications; 4. That the Ministry of Municipal Affairs and Housing be requested to include a City of Pickering representative on the Planning Working Group; and 5. Further, that a copy of Report PLN 03-15 and Pickering Council's resolution on the matter be forwarded to the Region of Durham, other Durham Area Municipalities, and the Ministry of Municipal Affairs and Housing. . I Executive Summary: In March 2015, the Province announced proposed legislative amendments to the Development Charges Act, 1997 and the Planning Act, 1990, through Bill 73 - Smart Growth for Our Communities Act. Bill 73 has been posted on Ontario's Environmental Registry and submissions on the proposed legislation are due no later than June 3, 2015. This report provides a response to the proposed changes to the Development Charges Act, 1997 and the Planning Act, 1990. Financial Implications: Not applicable p pp 1. Background 1.1 Previous Consultations From October 2013 to January 2014, the Province undertook consultations on the land use planning and appeal system, and the development charges system. The review included discussions with the development community and the municipal sector, in addition to consultation with the Regional Planning Commissioners of Ontario, the Regional Treasurers of Ontario, Environmental Defense, Sustainable Prosperity and the Greenbelt Council. 105 Report PLN 03-15 May 11, 2015 Subject: Bill 73 — Proposed Smart Growth for Our Communities Act Page 3 The consultations focused on: • how the Province's land use planning and appeal system can be improved; • the Development Charges Act; • parkland dedication; and • section 37 of the Planning Act, which enables a municipality to negotiate with a developer to provide community benefits, such as a community centre or affordable housing, in exchange for increased development density or building heights. In January 2014, the City provided comments to the Province on the review of the land use planning and appeal and development charges systems (see Pickering's Response to the Province on Its Review of the Planning Act and Development Charges Act, Attachment#1). 1.2 Proposed Legislation In response to comments received through their consultations, the Province announced proposed legislative amendments to the Development Charges Act, 1997 and the Planning Act, through Bill 73 - Smart Growth for Our Communities Act. Bill 73 received first reading on March 5, 2015. The Province has indicated that if passed, Bill 73 is intended to: give residents more say in how their communities grow; set out clearer rules for land use planning; give municipalities more independence to make local decisions; and make it easier to resolve disputes. The Bill would also give municipalities more opportunities to fund growth-related infrastructure, like transit; make the development charges, section 37 density bonusing, and parkland dedication systems more predictable, transparent and accountable; and, support higher density development to create jobs and grow the economy. Bill 73 has been posted on the Ontario Environmental Registry for a 90 day comment period. Submissions on the proposed legislation are due no later than June 3, 2015. 2. Comments and Recommendations on the Changes to the Development Charges Act, 1997 2.1 Purpose of the Development Charges Act, 1997 The Development Charges Act, 1997, ("DCA") provides the authority and the rules for municipalities to levy a development charge. Development charges are a revenue tool designed to assist municipalities in paying for a portion of growth- related capital costs incurred to provide services to new residents and businesses. Development charges are charges imposed by municipalities on developers to pay for increased capital costs related to growth. These costs are typically passed on to consumers. Development charges do not pay for operating costs or the future repair and rehabilitation of ihfrastructure. The Act is designed to try to ensure that a municipality's existing taxpayers are not required to pay the capital cost of services and facilities required to serve new development. 106 Report PLN 03-15 May 11, 2015 Subject: Bill 73 — Proposed Smart Growth for Our Communities Act Page 4 2.2 Nature of the Proposed Changes 2.2.1 Historical Service Level Cap Bill 73 proposes to amend the DCA to allow the calculation of development charges based upon the "planned level of service" during the ten years immediately following the preparation of a development charge background study. The amendment could be very helpful to the City because it would permit development charges to be calculated based on future needs rather than the • prior 10 years' historical level of service. It must be noted, however, that this amendment will only apply to services which are prescribed by Regulation. The Regulation has not yet been drawn up, so it is not certain which services will be granted this favourable treatment. 2.2.2 Mandatory 10% Reduction The DCA currently contains a mandatory 10% reduction from the development charge calculation for most services. Bill 73 proposes to remove that deduction as it applies to transit services. This amendment is beneficial because it will allow for greater recovery of transit-related servicing costs. While staff regard this,amendment as good public policy, it does not directly impact the City, given that transit is a regional responsibility. 2.2.3 Voluntary Payments Bill 73 contains a provision stating that a municipality "shall not impose, directly or indirectly, a charge related to a development or a requirement to construct a service related to development, except as permitted by this Act or another Act." This amendment appears to prohibit any requirement for financial contributions over and above what can be imposed under the DCA. Although the language is not clear, it is very likely that this amendment would prohibit any future agreements with developers for payments over and above what can be charged under the DCA. Staff have grave concerns about the impact of this proposed amendment on the City. It is widely recognized that development does not pay for itself. If the amount of financial.contributions which the City can collect is limited strictly to development charges permitted under the DCA, then the City will be deprived of the ability to collect from developers the real infrastructure costs associated with their development proposals. Staff have sought input from Watson &Associates Economists Ltd. concerning this very important issue. Watson and Associates are a part of the Provincial working group which is reviewing Bill 73. The impact of Bill 73 on Seaton and on the City generally will be the subject of a future staff report to Council. 107 Report PLN 03-15 May 11, 2015 Subject: Bill 73 — Proposed Smart Growth for Our Communities Act Page 5. 2.2.4 Asset Management Plan Bill 73 requires that development charge background studies contain an asset management plan addressing the cost of those assets which are proposed to be funded under the development charges. This will require municipalities to account in greater detail for the capital costs it intends to pass on to developers through development charges. This is in keeping with the Province's broader focus on ensuring that municipalities plan for and invest in critical infrastructure. Fortunately, the City has already prepared an asset management plan for roads and bridges, and is in the course of preparing an asset management plan for its facilities. The City is therefore well-positioned to comply with this requirement should Bill 73 become law. 2.2.5 Area Specific Charges The DCA currently allows a municipality to apply development charges either to the entire municipality or only to a portion of it. Bill 73 would empower the Province to impose upon any municipality an obligation to use area specific development charges to pursue strategic land use planning objectives. This power would be exercised through Provincial Regulation. Those Regulations have not been written yet, so it is unclear what impact, if any, this amendment might have on the City. In any event, this amendment could limit the City's flexibility in financial planning, given that the choice between area specific and city-wide charges could be foisted on the City by the Province. 3. Comments and Recommendations on the Changes to the Planning Act 3.1 Purpose of the Planning Act The Planning Act sets out the ground rules for land use planning in Ontario. It defines the approach to planning and assigns or provides for roles and responsibilities for decision-makers and applicants. It also sets out consultation and public engagement requirements. It is the legislative basis for processes that are central to the exercise of land use planning (e.g. official plans, zoning by-laws, creation of new lots by consent, and plans of subdivision). In addition, the Act provides for other municipal planning tools including site plan control, community improvement plans, and a development permit system. 3.2 Nature of the Proposed Changes Bill 73 proposes a number of changes to the Planning Act that are intended to streamline the planning process and ensure greater opportunities for public input. Attachment#2 is a Table that provides an overview of the proposed changes to the Act, and staffs response to each of the changes. 108 Report PLN 03-15 May 11, 2015 Subject: Bill 73 — Proposed Smart Growth for Our Communities Act . Page 6 Bill 73 addresses many of the comments that were made by the City in January 2014, including: • extending municipal official plan update cycles from 5 to 10 years, after the preparation of a new, comprehensive official plan • establishing more rigorous requirements for making an appeal to the Ontario Municipal Board • removing the ability for an appellant to appeal the entirety of a new official plan • providing optional dispute resolution mechanisms • removing the ability to appeal official plans and official plan amendments that implement certain provincially approved matters (e.g. source water protection) Although these amendments are welcomed, there are some additional changes to the Bill that should be considered, dealing with: the timelines for official plan reviews that do not follow a new official plan; restrictions on the approval of official.plan amendment, zoning by-law amendment, and minor variance applications; additional prescribed criteria for Committee of Adjustment decisions; alternative parkland dedication requirements; provincial requirement to adopt a development permit system; and the closure of dormant planning applications. 3.2.1 Approval of Amendments Following a New Official Plan or Comprehensive Zoning By-law The Province is proposing that during the two-year period following the adoption of a new official plan or the comprehensive replacement of a municipality's zoning by-laws, no private applications to amend the official plan or zoning by-law would be permitted. Although the proposed changes would protect the integrity of a new official plan or comprehensive zoning by-law from potentially inappropriate official plan and zoning applications (such as applications to reduce minimum height or density requirements), it would also prevent consideration of development proposals that may meet or exceed the community's goals (such as applications that would increase employment opportunities). It is also unclear how this moratorium would impact the use of holding by-laws and interim control by-laws. For example, since holding by-laws are used to phase development, the moratorium would not only prevent new zoning applications, but may prevent new development from occurring for a period of two years. • In addition, applying such a moratorium may precipitate a large number of premature and unwarranted applications or Ontario Municipal Board appeals prior to the approval of the new official plan or comprehensive zoning by-law. As such, it is recommended that current approval processes be maintained and that the proposed changes be deleted from the draft legislation. 109 Report PLN 03-15 May 11, 2015 Subject: Bill 73 — Proposed Smart Growth for Our Communities Act Page 7 3.2.2 Timelines for Official Plan Reviews Although the Province is recommending the extension of a municipal official plan update from 5 to 10 years following the introduction of a new official plan, the Province is continuing to recommend that official plans that are not "new" be updated every 5 years. This is impractical and unnecessary, especially within a two-tier municipal planning environment, where such reviews must follow the updates of both the Provincial Land Use Plans and upper tier (regional) plans. A 10 year timeframe would be consistent with the Provincial Land Use Plan, reviews, and the proposed Provincial Policy Statement review timeframes. It is recommended that the timeframe for an official plan review, regardless of whether a municipality is introducing a new official plan, or undertaking a comprehensive review through the amendment process, be 10 years. 3.2.3 Approval of Minor Variance Applications Following a Recent Rezoning The Province is proposing that during the two-year period following an owner- initiated site-specific rezoning, applications for minor variances should only be permitted with Council approval. This change would make the minor variance process more onerous and time consuming. By their nature, variances are meant to be minor, and often result from unintended or unforeseen circumstances in the early stages of construction (for example, the pouring of foundation that is fractionally too close to a lot line). The Committee of Adjustment has been very effective in assessing and making decisions on such applications in a timely fashion. As such, it is recommended that the current approval process be maintained and that the proposed change be deleted from the draft legislation. 3.2.4 Additional Requirements for Committee of Adjustment Decisions The Planning Act currently indicates that a Committee of Adjustment can make decisions on minor variances to a zoning by-law if in its opinion the Committee considers the minor variance is desirable for the appropriate development or use of the land, building or structure, and if in the opinion of the Committee the general intent and purpose of the by-law and of the official plan are maintained. Bill 73 proposes that additional criteria be prescribed, however the proposed changes to the Act do not reference what those criteria may be. It is assumed that the prescribed criteria may be defined under a new regulation. However, such a regulation has not been released for review. The current test and committee framework have served the City well, and there does not appear any justification for prescribing further criteria. As such, it is recommended that the current framework and tests remain unchanged. 110 Report PLN 03-15 May 11, 2015 Subject: Bill 73 — Proposed Smart Growth for Our Communities Act Page 8 3.2.5 Alternative Parkland Dedication Requirements The Province is proposing that before a municipality adopts official plan policies allowing it to pass by-laws using the alternative parkland requirement provisions, the municipality complete a parks plan that examines the need for parkland in the municipality. In addition, the Province is proposing that the cash-in-lieu collected under the alternative requirement be changed from the value of one hectare of land for each 300 dwelling units proposed, to a new limit of one hectare per 500 dwelling units. While Bill 73 includes a provision that the preparation of a park plan is not required for official plan policies adopted before the effective date of the Bill, the Bill includes a further provision that for any by-law that was adopted with the rate of one hectare of land for each 300 dwelling units, such by-law will be considered to be amended with the new rate of one hectare per 500 dwelling units. The City's official plan contains parkland provisions in accordance with current alternative parkland requirements, and has adopted a corresponding by-law which reflects these requirements. To date, the City has not yet used the alternative parkland dedication provision. However, with further intensification and increased population densities in South Pickering will come the need for greater outdoor park space. Furthermore,the highest intensity developments will likely occur in locations where land values are highest, which makes it fair and reasonable for the developers of these sites to fund parkland requirements at a higher rate. As such, it is recommended that the current value of one hectare per 300 dwelling units be maintained for cash-in-lieu collected under the alternative parkland requirements. 3.2.6 Requirements for Development Permit System The Development Permit System is a relatively new planning tool which combines zoning, site plan and minor variance processes into one application and approval process. The Province has proposed that the Minister can make an order requiring a local municipality to adopt a development permit system, or authorizing upper tier municipalities to impose similar requirements on lower tier municipalities. The new provision does not provide any direction as to the conditions under which the Minister or approval authority may make such a decision. The clause raises concerns with respect to transparency, stakeholder consultation, and local autonomy. If the Minister feels that there is matter of provincial interest at stake, the Minister has the power to establish a planning development area under the Ontario Planning and Development Act and/or impose a Minister's Zoning Order, as has been past practice. It is recommended that the proposed change be deleted from the draft legislation. 111 Report PLN 03-15 May 11, 2015 Subject: Bill 73 — Proposed Smart Growth for Our Communities Act Page 9 3.2.7 Closing Dormant Files The Planning Act does not provide approval authorities with the clear authority to close dormant planning applications. There are a number of dormant planning applications in the City that date back as far as 1986. It is recommended that the Planning Act be amended to enable municipalities to close files that are inactive and to withdraw planning approvals that are dormant. 4.0 Working Groups To advance Bill 73, the Province has announced that it plans to assemble development charges and planning working groups to provide feedback and make recommendations on the legislation. The Province has indicated that from a planning perspective, they will be seeking input on such matters as the regulations for minor variances, strategic locations for establishing Development Permit Systems, and the more effective use of local appeal bodies. As previously noted, the City's consultant (Watson and Associates) is a member of the Development Charges Working Group. However, it is recommended that the City request that a Pickering representative be included in the Planning Working Group. 5.0 Conclusion For the most part, the proposed changes to the Planning Act provide improved clarity, transparency, and opportunities for stakeholder engagement and input. However, the Province is recommending certain changes to the Act that staff believes should remain in place. These practices and processes are well established, and have served the public, the development industry and municipalities well. To advance the implementation of the Act, steps need to be taken to update the regulations which support the current and proposed Planning Act provisions. Accordingly, it is recommended that a City representative be included in the proposed Planning Working Groups to advance the City's interests and the recommendations offered in this report. With respect to the proposed changes to the Development Charges Act, the Province is requested to prepare the Regulation prescribing the services for which the level of service may be calculated based upon the City's planned level of service over the 10-year period immediately following the preparation of the development charge background study (as opposed to the historical 10-year period). Furthermore, the Province is requested to delete or amend proposed section 59.1 of the Bill so as to enable the City to continue to negotiate financial contributions from developers above and beyond development charges. 112 Report PLN 03-15 May 11, 2015 Subject: Bill 73 — Proposed Smart Growth for Our Communities Act Page 10 Attachments 1. Pickering's Response to the Province on Its Review of the Planning Act and Development Charges Act 2. Staff Response to Proposed Legislative Changes to the Planning Act Prepared By: Approved/Endorsed By: -7d,Zzerfd- Jeff Brooks, MCIP, RPP Thomas MelymtA, MCIP, RPP Manager, Policy & Geomatics Dire • City Development Catherine Rose, MCIP, RPP Paul B g • • Chief Planner Direct,r, Col...rate Services & City .olici •r JB:Id Recommended for the consideration of Pickering City Council / ,/oeu../ ZaIS Tony Prevedel, P.Eng. Chief Administrative Officer • 113 �aT Pickering Civic Complex Cali O ?�l'c� c�i� ���r� .-��9� � �`: One The Esplanade REP C!-Si:'i.' PL+���'? Pickering,Ontario Canada risil L1V 6K7 PICKE RIN^ Direct Access 905.420.4660 LH 1 (v' cityotpickering.com OFFICE OF THE CHIEF ADMINISTRATIVE OFFICER Department 905.420.4648 • Facsimile 905.420.6064 cao @citypickering.on.ca January 9, 2014 Development Charge Consultation Ministry of.Municipal Affairs and Housing Municipal Finance Policy Branch 777 Bay Street, 13th Floor • Toronto, ON M5G 2E5 - and Land Use Planning and Appeal System Consultation Ministry of Municipal Affairs.and Housing Provincial Planning Policy Branch 777. Bay Street, 14th Floor Toronto, ON M5G 2E5 • Subject: Comments on Development Charges and the Land Use Planning and Appeal System in Ontario— Fall 2013 File: L-1100-048—Planning & Development Charges Acts—Review 2013 The City of Pickering appreciates the opportunity to provide comments on the Provincial Reviews of Development Charges and the Land Use Planning and Appeal System in Ontario. . 1.0 Development Charges in Ontario 1.1 Preamble Development Charges are one of the important city building tools that enable municipalities to create healthy, safe and complete communities for current and future - residents. Development charges are required to support growth in built-up and greenfield areas. In Ontario, development must conform to Provincial-interests, be consistent with the Provincial Policy Statement and also conform to the objectives of . • various Provincial Plans including the Growth Plan for the Greater Golden Horseshoe. 114 . Comments on Development Charges and the January 9, 2014 Land Use Planning and Appeal System.in Ontario— Fall 2013 Page 2 of 6 Municipal decisions on planning applications must conform to a long list of Provincial interests which include (among others): adequate transportation, safe and healthy communities, adequate social, cultural and recreational facilities, protection of ecological systems, protection of the financial well-being of municipalities, sustainable development, public transit, and pedestrian orientation. Municipalities must be consistent with the vision and the policies for building strong communities contained'in the Provincial Policy Statement, which include long-term prosperity and social well-being, meeting the full range of current and future needs, optimizing public facilities and financial well-being over the long-term, creating strong and healthy communities and providing public service facilities that ensure long-term prosperity. Municipalities must conform to the Growth Plan which notes that decades of neglect have resulted in a current infrastructure deficit. Policies direct growth to built-up areas, promote transit supportive densities, efficient public transit,-community infrastructure to support growth and an integrated approach to waste management, among others. One of the guiding principles of the Growth Plan is to build compact, vibrant and complete communities and to optimize existing and new infrastructure to support growth. 1.2 Comment: Nowhere in the Ontario Planning Act, the Provincial Policy Statement, or the Provincial Growth Plan is there policy direction to municipalities that they need only to fulfill only 90% of their interests and objectives, deliver only 10 year old standards, or discount by 10% the provision of required "soft services" including,transit, parkland development, libraries, daycares and recreation facilities. Yet this is exactly what is mandated by the existing approach to Development Charges in Ontario. And this approach has direct and unfortunate impacts on municipalities. It shifts the burden of funding growth to existing residents and businesses (either immediately or through long-term debt instruments). As well, it could lead to lower service levels and a lower quality of life. It is unfair and inappropriate for development charges to be discounted by 10% for the soft services and to meet require the municipalities.only a 10 year historical service average cap. It is also unfair and inappropriate to deem certain required municipal • services as ineligible. The limitations on services eligible for Development Charges funding erodes the ability of the municipality to fulfill its responsibilities to both the Province and to its current and future citizens and businesses to provide for a full range of public services and create complete and healthy communities. 115 Al7W,TET,15 TO Comments on Development Charges and the. . . January. 9, 2014 Land Use Planning and Appeal System in Ontario — Fall 2013 Page 3 of 6 Changes made to the Development Charges Act in the 1990's by the Provincial Government of the day should be reversed in order to level the playing field and provide municipalities with a fairer means of meeting provincially mandated interests,objectives and requirements. Without change, it will be fiscally challenging for municipalities to provide safe, healthy, complete and sustainable communities with a fuller range of urban services. . The City of Pickering has reviewed and concurs with the findings of three recent analyses of the current Development Charges regime. These include the positions taken by the Region of Durham and the Association of Municipalities of Ontario, as well as an analysis produced by Watson &Associates Economists Ltd. in response to the Provincial Review of the Development Charges Act. Specifically, the City of Pickering supports the recommendations and comments of the Region of Durham Report# 2013-J-35, prepared in response to the consultation for the Provincial Review of the Development Charges Act(DCA) and the City encourages the Province to act on those recommendations: The City is particularly supportive of the Region's position that the DCA should ensure that"growth pays for growth". The City of Pickering also concurs with the arguments and reasoning set out by the Association of Municipalities of Ontario_(AMO) in the "Report to the.PMFSDR Infrastructure Table—Development Charges Subgroup", dated August 9, 2007, initially produced following adoption of the Development Charges Act 1997 and still the position of AMO. In addition, the City concurs with the positions taken in the AMO news release entitled "Development Charges — Make Municipal Voice Heard". Of particular note is the estimate that the restrictions imposed in 1997 by the Development Charges Act shifted $550 million in growth related costs from developers to existing property taxpayers, which created a public transit investment gap of over $1 billion as noted in the 2008 Provincial Municipal Fiscal and Service Delivery Review (and which has still not been acted on by the Province). In addition, the AMO news release noted that in 2013 the Ontario Environmental Commissioner called for reforms to the DCA in order to treat public transit equitably. The City of Pickering also agrees with the analysis and arguments contained in the Watson &Associates Economists Ltd. letter dated November 29, 2013 (see Attachment) respecting the Development Charges Review consultation. The City would like to draw particular attention to the estimate that the current Development Charges Act only allows for recovery of approximately 75% of the cost of growth due to the exemptions, reductions and limitations provided in the current Act. The City supports Watson's recommendations to remove from the current Development Charges Act the following exclusions: 116 • REK r„ Comments on Development Charges and the January 9, 2014 Land Use Planning and Appeal System in Ontario Fall 2013 . Page 4 of 6 • • municipal headquarters, cultural (including arts and heritage)facilities, museums, vehicles and equipment with average life of less than'seven years, and • computer equipment; and, • the mandatory 10% deduction and service level limitations, as set out in the City's recommendations. • . 1.3 Recommendations Respecting the Development Charges consultation, the City of Pickering recommends that, in order to support the principle that`growth should pay for growth' and to achieve the objectives of meeting Provincial interests; the Provincial Policy Statement and the Growth Plan for the Greater Golden Horseshoe, the Province of Ontario amend the • Development Charges Act as follows: 1. Ten year historical level service cap - Remove the ten year-historical service cap so that forward-looking service level standards can be applied to capital costs. . 2. Ineligible Services - Remove the category of services ineligible for development charges including: acquisition of land for parks, municipal • administrative buildings, cultural (including arts and heritage) facilities, museum, entertainment and tourism facilities, municipal contributions for hospital services, and waste management services. • 3. 10% Discount Services= Remove the mandatory 10% reduction for soft services; including'recreation facilities, libraries, parkland development, transit, homes for the aged, ambulance service, social housing, childcare, emergency shelters and vehicles and.equipment. . 4. Treatment of Grants, Subsidies and Other Contributions -Allow grants, subsidies and other contributions to be treated as general revenues so municipalities can apply these additional resources. 2.0 Land Use Planning and Appeal System . 2.1 General Comment The City of Pickering has reviewed and generally concurs with the recommendations made in the Region of Durham Report# 2014-P-3, prepared in response to the consultation for the.Provincial Review of Ontario's Land Use Planning and Appeal System. The City of Pickering encourages the Province to act on those . recommendations. . 117 p>'b_i laYf ii Comments on Development Charges and the January 9, 2014 Land Use Planning and Appeal System in Ontario— Fall 2013 • Page 5 of 6 • The City is particularly supportive of the Region's positions that the Planning Act be amended to require municipalities to undertake comprehensive updates to official plans every ten years, from the current five, and that timelines for making decisions on complex official plan amendments be suspended until completion of peer review processes. 2.2 Comment Respecting Parkland Dedication The Planning Act permits municipalities to require dedication of 5% of residential development land to the municipality for parkland or by a cash-in-lieu payment equal to the value of the land. An alternative ratio of one hectare per 300 dwelling units can be required, which allows municipalities to obtain either land or cash-in-lieu to purchase land to satisfy parkland needs for larger numbers of occupants of higher'intensity residential developments. In addition, municipalities may also require 2%of industrial/commercial land to be given as parkland or a cash-in-lieu payment for its value. The City of Pickering's experience has been that these provisions are generally adequate to provide for local and community park needs but fall short in their adequacy to provide lands for major City-wide/regional facilities. Accordingly, the City recommends that the Development Charges Act be revised to include parkland as an eligible development charge item for those parkland needs not adequately provided by the provisions of the Planning Act. The Province's Consultation Document noted that concerns have been raised that the alternative parkland dedication rate acts as a barrier to intensification and makes it-more difficult to reach the intensification goals of the Provincial Policy Statement and as set out in the Growth Plan for the Greater Golden Horseshoe. We also understand that BILD may be requesting that the Province place a cap on the parkland dedication fees at 5 to 10 per cent of the value of the development site, or the site's land area, as was done in Toronto. Should this be the case, the City of Pickering is opposed to this request because with greater population density comes'a need for greater outdoor park space, especially at ground level. In addition, the sites most likely to accommodate the highest intensity development are likely to have the highest land values which makes it fair and reasonable for the developers of these sites to fund parkland requirements without the imposition of an artificial and arbitrary cap. 118 AMISET JO • Comments on Development Charges and the January 9, 2014 'Land Use Planning and Appeal System in Ontario — Fall 2013 • • Page6of6 • 2.3 Recommendations • • Respecting the Land Use Planning and Appeal System consultation, the City of Pickering recommends that the Province of Ontario: • 1. Revise the Planning Act to implement the recommendations contained in the Region of Durham Report# 2014 —P-3, particularly to require municipalities to undertake comprehensive updates to official plans every ten years, from the current.five, and to suspend 'timelines for making decisions on complex official plan amendments until completion of peer review processes, Where warranted; 2. Revise the Development Charges Act to include parkland as:an eligible development charge item for those parkland needs not adequately provided by • the provisions of the Planning Act, and, • 3. Maintain the current.alternative parkland provisions and not revise the Planning Act to cap or restrict alternative parkland dedication rates for high intensity development. Thank you for the opportunity to comment on these two important topics Should you have any questions, please do not hesitate to contact my office. Yours truly • • Tony Prevedel, P.Eng. • Chief Administrative Officer • • SG:jf - J:1DocumentstLawlL-1100 Legislation&RegulationslL-1100-047 Planning 8 Development Charges Ads-Review 20131Comments on Land Use Planning d Development Charges Consultation,January 9, 2014.doc Attachment • Copy: Association of Municipalities of Ontario • - Building Industry and Land Development Association • Region of Durham . • Watson &Associates Economists Ltd. • Mayor Ryan • Members of Council Directors • Division Head; Finance &Treasurer Chief Planner Principal Planner, Policy (S. Gaunt) • • • • . 119 dLC E • LR.ri t i2 FL t U ._ j'7 Watson Plaza Three 101-2000 Argentia Rd. Mississauga,Ontario Q A1�ssociates Canada L5N 1V9 C)• Phone: (905)272-3600 ECONOMISTS LTD. Fax.(905)272-3602 e-mail:jnfo(a watson-econ.ca . I November 29, 2013 • • • To our Development Charge Clients: • Re: Development Charges Review Consultation • As you are probably aware, on October 24, 2013,the Ministry of Municipal Affairs announced public • consultations on the Development Charges Act(DCA). The announcement indicated that "Ontario is reviewing its development charges system, which includes the Development Charges Act and related municipal measures that levy costs on development(i.e. section 37 and parkland dedication provisions of the Planning Act) to make sure it is predictable, transparent, cost-effective and responsive to the changing needs of communities." A discussion paper was released (copy attached)with the announcement as a focal point for issues to be , • discussed. Nineteen questions are posed. Comments are invited to be submitted by January 10, 2014. Since the announcement was made, a number of our clients have contacted us regarding our perspectives on the questions posed and have asked if we would be responding to this document. On behalf of our clients, we are responding in several ways: • We have had initial discussions with, and have offered our assistance to, MFOA and AMO as they develop their respective positions on the consultation document; • We have been retained by several clients to assist in developing their response to the policy . questions posed; • We will be attending some of the consultation meeting(s)set up by the Province; and • As a consulting firm which prepares a substantial number of the development charge by-laws in Ontario, we will be preparing our own individual submission to the Province. • In addition to the above,we are providing our clients with our initial perspectives on the 19 questions posed:, These comments are not exhaustive and are not as technically detailed as our final submission is expected to be; however, they do•provide our clients with an initial perspective. We hope that this will assist you in formulating and submitting your own response to the Province. Response to Questions Posed A. The Development Charges Process • 1. Does the development charge methodology support the right level of investment in growth-related infrastructure? It is unclear what the Province determines to be the"right level of investment." Based on fiscal impact studies undertaken in the past,we would estimate that the present Development Charges Act only allows • for recovery of about 75% of the cost of growth. This results from exemptions, reductions and limitations provided in the current Act, as follows: • H:\DCA-GEN\DCProvindalReview-ag.doa d Planning for growth 120 Arrit�?a—i r TO FicPlwi rc P' a 3 - Watson &Associates Economists Ltd. 2. • • Exempt Services—which includes parkland acquisition, municipal headquarters,tourism facilities, arts/culture facilities, museums, solid waste services(recycle, re-use, landfill), • hospitals, vehicles &equipment with average life of less than seven years, and computer equipment; • Mandatory Exemptions—industrial building expansions(may expand by 50%with no DC; may add up to two apartments for a single family home; may add one additional unit in medium & high density buildings) and upper/lower tier governments and school boards; • Mandatory 10% Deduction—for all services except water, wastewater, stormwater, services related to a highway(i.e. roads),fire and police; and • Service Level Limitations—cannot include amounts in excess of 10-year historic service calculation. Based on the above, the concept of"growth paying for growth"is not presently achieved under the current Act. Any further limitations or reductions provided by a change to the Act would shift a higher burden onto existing taxpayers. 2. Should the Development Charges Act, 1997 more clearly define how municipalities determine the growth-related capital costs recoverable from development charges? For example, should the Act explicitly define what is meant by benefit to existing development? The current Act has been in place since 1997. Interpretation of the Act has evolved since that time through the combined efforts of economists, engineers, planners,finance and other service specialists interpreting the existing requirements of the Act. This interpretation has been further tested and refined as a result of over 50 Ontario Municipal Board hearings arising directly from appeals to the enacted DC by-laws. Given the diversity of services provided by municipalities, the expanse of rules and regulations imposed . by statutes to carry out those services and the changing nature for the planning and development of communities,we feel that an attempt to prescribe how concepts such as"growth-related capital costs" and"existing benefit"will be determined may result in restrictive, narrowly defined directives. Ultimately, as with any statute or regulation, interpretation plays an important role in determining how the legislation is addressed. The municipal sector has had 14 years to define the present Act through its application. These interpretations, along with many others, have been tested by the OMB and now form the basis for the calculation of the charge. We are unclear as to what benefit would be further derived by adding prescriptive wording to the DCA. 0 3. Is there enough rigour around the methodology by which municipalities calculate the maximum allowable development charges? The present approach to calculating the"maximum allowable charge" is to look back at the level of service provided over the past 10 years and, based on quantity/quality measures, establish the average • level of service as the basis for calculating the maximum. This approach is used for all services except water,wastewater and stormwater which are guided by environmental legislation. Historically,the concept of measuring service levels pre-dates the present DCA and the former DCA, 1989 (i.e.the"lot levy"era). Prior to an Act being implemented,these measures generally only • considered the quantity aspects of the service. When the DCA, 1989 was introduced, the requirement for quality as well as quantity measures was also introduced; however, the prior Act provided that the • • • H:DCA-GEMDC Provincial Review-ag.doac 121 • $L Wk«sill. F -1 03 - i • Watson&Associates Economists Ltd. 3. • maximum allowable charge be based on the highest level achieved over the past 10 years vs. the . average level of service required under the present Act. We are unclear what further"rigour" is to be applied to this calculation other than to define what the quantity and quality measures entail. Quantity is defined presently by the number or size of the assets you have had over the last 10 years. Quality is the cost to replace the asset if you were to purchase or construct the asset today. These measures appear to be reasonably defined at present. B. Eligible Services 4. The Development Charges Act, 1997'prevents municipalities from collecting development charges for specific services, such as hospitals and tourism facilities. Is the current list of ineligible services appropriate? • In response to questions 4 and 5, it is important to understand why these provisions were implemented. In "Notes for Remarks by Municipal Affairs and Housing Minister Al Leach to the Standing Committee of the Legislature on Bill 98,the Development Charges Act, 1997," Mr. Leach states: "in November 1995, • this government began a fundamental review of the Development Charges Act. We wanted to be sure that we could reduce the cost of development. We wanted to reduce the cost of constructing new homes and apartment buildings." Further, he indicates, "we have proposed changes to the Act that would increase municipal accountability. We are proposing that in the future municipalities make a contribution, from general revenues, of 30 per cent of the cost of new facilities like libraries and community centres" (note that the 30%was subsequently reduced to 10%). From the municipal perspective of having a financial contribution from development to pay for the growth component of infrastructure costs, both the service exemption and the 10%deduction present limitations to the municipality in funding these assets and should be removed. If the Province's objectives are the same as in 1995, then these limitations, or further restrictions, may seem appropriate. 5. The Development Charges Act, 1997, allows municipalities to collect 100%of growth-related capital • • costs for specific services. All other eligible services are subject to a 10%discount. Should the list of services subject to a 10%discount be re-examined? See item 4. • 6. Amendments to the Development Charges Act, 1997 provided Toronto and York Region an exemption from the 10 year historical service level average and the 10%discount for growth-related capita!costs for the Toronto-York subway extension. Should the targeted amendments enacted for the Toronto-York Subway Extension be applied to all transit projects in Ontario or only high-order (e.g. subways, light rail) transit projects? Presently, transit is considered a"soft"service and is subject to the service level cap and 10%deduction, thus limiting the recovery of revenue to fund the service. Part of the provincial initiatives is to reduce reliance on roads and to increase the use of alternative modes of transportation, such as public transit. From a DC perspective, this initiative is reducing reliance on a 100% service(i.e. roads) and replacing it with a 90% service (i.e. transit). As well,the increase in the transit service is limited by the service level cap which further places a financial burden on municipalities. Collectively, the present DC regime provides limitations in achieving the provincial goals and, hence, should have similar funding available. It should also be noted that one of the recommendations for funding Metrolinx was to provide access to development charges. This new requirement would affect the charges(i.e. increase)for the GGH R'DCA-GEMDC Provincial Review-ag.docx • 122 . TO 4YL"i"C.!birit Watson &Associates Economists Ltd. 4. • municipalities and some of the"Outer Rim"municipalities. Concern is raised that if Metrolinx is granted access to DC funding while, at the same time the Province has a goal of not increasing the overall DCs, then this will require further reductions, deductions or limitations on municipal services, thus providing a further loss of revenue for municipalities. C. Reserve Funds • 7. Is the requirement to submit a detailed reserve fund statement sufficient to determine how municipalities are spending reserves and whether the funds are being spent on the projects for which they were collected? Section 43 of the Act, along with section 12 of the Regulations, requires the.Treasurer to annually provide Council with "a financial statement relating to development charge by-laws and reserve funds." This statement is to.include opening and closing balances, revenues collected, monies used to fund capital works, interest allocation, debt payments, loans between services and credits given. In addition, the statement also includes two schedules—one denoting outstanding credits granted and another detailing the projects on which the DC monies were transferred (note that all other revenue funding sources for the project are also to be included on this statement). The existing legislated reporting requirements are quite detailed and we would consider the level of reporting to be transparent and • informative. 8. Should the development charge reserve funds statements be more broadly available to the public, for example, requiring mandatory posting on a municipal website? • The present requirement is to provide this information to Council; hence, the information is available to the public. However, requiring that this information also be available on the municipality's website does not appear to be unreasonable. 9. Should the reporting requirements of the reserve funds be more prescriptive, if so, how? As detailed in question 7, we feel that the present reporting requirements are quite prescriptive. D. Section 37(Density Bonusing) and Parkland Dedication Questions 10. How can Section 37 and parkland dedication processes be made more transparent and accountable? . I In regard to parkland dedication,the Planning Act allows for municipalities to collect 5% parkland dedications forresidential development and 2%dedications for commercial/industrial developments (note that as an alternative to land dedications, a cash-in-lieu payment may be made). The Planning Act also allows for a dedication of land equal to one hectare per 300 units which may be used for higher 1. density developments. For the one hectare per 300 units to be imposed, it requires policies to be included within the municipality's Official Plan and also requires a municipal by-law. This present process appears to be open and transparent to the public and relates predominantly to the acquisition of land for park•purposes. As the acquisition of parkland has been removed from the DCA, the Planning Act provides the only basis for acquiring land. • Section 37 of the Planning Act allows for a municipality to receive"facilities, services or matters" as a contribution for the approval of additional height or density above that provided for in the zoning by-law. Similar to parkland, the Planning Act does require Official Plan policies and provisions to be made in the zoning by-law. However, the services which may be collected for, and the quantum of service, etc., are • FI:�DCA-GEMDC Provincial Review-ag.doac 123 AT • : T LGert,•?rETJS 1 • Watson &Associates Economists Ltd. 5. not defined. This section of the Planning Act may require some methodological underpinning and reporting requirements similar to that of the DCA. 11. How can these tools be used to support the goals and objectives of the Provincial Policy Statement and the Growth Plan for the Greater Golden Horseshoe? Section 37 authorizes a municipality with appropriate Official Plan provisions to pass zoning by-laws involving increases in height or density otherwise permitted by the zoning by-law, in return for the provision by the owner of community benefits(i.e. day care facility, provisions for affordable housing, public art, transit facilities such as bus shelters, etc.). The fundamental principle of the Provincial Growth Plan and 2005 Provincial Policy Statement(PPS) is to plan for growth and development in a way that supports economic prosperity, protects the environment and helps.communities achieve a high quality of life across the Province. Fundamental to this objective is the development of compact, vibrant and complete communities which optimize the use of existing infrastructure and support the efficient use of land and natural resources. Section 37 supports these goals and objectives by encouraging new . businesses as well as increased community services and amenities in areas which are targeted for urban intensification (i.e. Urban Growth Centres(UGC)and built-up areas). As part of.the Growth Plan and PPS, municipalities are required to plan for.a range and mix of housing, taking into account affordable housing needs.• Section 37 is a tool for implementing certain Official Plan • • Housing and Heritage Resource policies when there is an increase in height and/or density. The provision of affordable housing as a first priority community benefit on large development sites, site preservation of existing rental housing on intensification sites, the replacement of existing rental housing • to be demolished, and the conservation of heritage resources on development sites, are fundamental Official Plan policy requirements. Section 37 provides the tool to implement these policies. E. Voluntary Payments 12. What role do voluntary payments outside of the Development Charges Act, 1997 play in developing • complete communities? Voluntary payments have generally been used by higher growth municipalities to assist in funding the non-recoverable DC component of growth-related projects(e.g. 1.0%deductions, exempt services, amounts in excess of service level cap). Often the requirement for these contributions and the quantum of the contribution are determined as part of a detailed fiscal impact assessment. In many cases, the net impact of growth requires considerable funding from the existing taxpayers causing significant increases on taxes and, in some cases, the potential to exceed the provincially mandated debt capacity limits. In • •these instances,the municipality either seeks additional financial assistance from development or seeks to limit the growth at affordable levels(which may result in not being able to meet the Places to Grow. targets). . • 13. Should municipalities have to identify and report on voluntary payments received from developers? At present, these payments are voluntary and outside of the Development Charges Act; hence, we are unclear of the statutory basis for requiring reporting on these funds. The individual agreements which have been entered into may or may not stipulate their own reporting requirements between the municipality and individuals. However, many municipalities who do receive these payments report the use of these funds through their budgeting process. • H:1DCA-GEN\DC Provincial Review-agdodt 124 . .kit• Y Watson&Associates Economists Ltd. 6. , • • 14. Should voluntary payments be reported in the annual reserve fund statement, which municipalities are required to submit to the Ministry of Municipal Affairs and Housing? • No, as noted.in question 13, these payments are voluntary(i.e. received outside of the Development Charges Act) and thus would be similar to other dedications, donations and/or receipts made to the municipality by others. As well, in certain cases,the contributions are not monetary and may take the form of a land or an asset contribution. The collection of these funds or assets is reported as part of the Fl R's and Financial Statements. V • F. Growth and Housing Affordability Questions . 15. How can the impacts of development charges on housing affordability be mitigated in the future? There are not many approaches to"limiting the impacts of development charges on housing affordability." In some cases,the calculation of an area-specific charge•may assist; however,this would generally only apply to services such as water, wastewater and storm sewers. Further, as discussed in item 17, area rating of these charges may not necessarily result in a lower charge. • Alternatively, a DC reduction may be made to certain areas, either statutorily or by the municipality; however,this would then shift the cost burden from new growth to the existing taxpayer. The shift of these costs onto taxes and rates.can then impact the affordability for existing residents. Alternatively, senior levels of government may consider cost incentives to new home purchases to assist in achieving these goals. • Lastly, while a municipality may lower its development charge to assist in housing affordability, there is no way of ensuring that the house price will reduce by the exact same amount. 16. How can development charges better support economic growth and job creation in Ontario? It is recognized that the construction industry plays an important role in providing jobs and economic growth. However, the construction industry involves both residential development-related construction as well as infrastructure construction. While reducing the development charge may have a perceived benefit on new home affordability, shifting the burden onto taxes and rates may slow or reduce infrastructure construction. V V G. High Density Growth Objectives . . 17. How can.the Development Charges Act, 1997 better support enhanced intensification and densities to meet both local and provincial objectives? . The general approach to calculating the development charge (i.e.varying the charge by type of unit based on average person per unitoccupancies)does allow for a reduced charge for medium and high density units over lower density units. However,further DC reductions to support enhanced intensification, without shifting the burden of cost reductions onto the existing tax or rate payer, are limited. These limitations arise for several reasons: • • Area Rating of Water and Wastewater Services—the water mains and sewers within the defined intensification area are generally sized for less dense development. To accommodate the increased density within redevelopment areas, these mains would have to be replaced with H:IDCA-GEMDC Provincial Review-ag.dooc 125 T• O • P 0 i --��� 0 • Watson &Associates Economists Ltd. 7. larger mains. The cost of main replacement in built up areas is usually 2-1/2 to 3 times the cost of a main built within the Greenfield areas; • Water and Wastewater Treatment—this is based on MOE standards and engineering design. Generally the usage for high density units is the same in intensification areas as within Greenfield areas, hence limited differentiation. In regard to water storage, conversion from a low • density area to a large high density area may warrant additional storage requirements in order to meet fire flow requirements;-and • Storm Water Requirements—low density development usually has higher amounts of permeable • land area which slows down the flow of storm water off the property. Intensification can reduce the amount of permeable land,thus increasing the rate of storm water flow. This can result in the need for additional storm water facilities. 18. How prescriptive should the framework be in mandating tools like area-rating and marginal cost pricing? For the reasons cited above, we would not suggest prescriptive tools on area rates or marginal costing. 19. What is the best way to offset the development charge incentives related to densities? There are a number of services related to or impacted by the Provincial Policy Statement and the Growth Plan. Refinements should be made to the DCA to broaden the opportunity to recover infrastructure costs to meet these objectives. This may include removing the 10%deduction, eliminating the service standard cap, etc. Summary At present, in regard to infrastructure, municipalities are being mandated to meet a number of provincial objectives including: • mandatory asset management plans under the"Provincial Municipal Infrastructure Strategy (2012)"for future capital grant approvals; • • pending asset management and sustainability plans for water, wastewater and stormwater under the Water Opportunities Act; and • potential accelerated replacement of water, wastewater, storm water(and potentially other assets) under the growth intensification requirements of Places to Grow. The development charge review discussed herein may provide the need for funding for growth-related assets should further reductions or limitations on revenue recovery be imposed. The review of development charges and the ability for municipalities to fund these expenditures outside of the DCA must be considered in light of all the other matters noted above. While it may be a concern of the development community and Province that the quantum of the DC provides pressure on the affordability . of housing,the level of taxes and water/wastewater rates which must be paid annually also directly affects the affordability of the home for both present and future residents and businesses. . Concluding Remarks • • • We would suggest that you consider the questions posed by the Province as they relate to your own municipality and provide a response to the Province by the January 10, 2014 deadline. 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O ca _c .0 N ca p Q O cn N = O -2 �W O N x— ^ 'C c ,- (, c '5 c N .� ,..�O •(a L- O Q c E c O c a) ) NON" a E � ca O O +-' O L c O a) -6 � L 03 O O (ato N >O • OI- '• O a) O4- U) Lim d ' E t� O Q ca.c • •C W M O = Op O ca cn o co ,o t �O N O N -2co....^� (a QU Q O c0 C.- c , O ;�N cD .19 Q -0 ° E O o c m k c cc m E a a) ti co is -0 (I) co ca >, o c > 0 ca�O C) co N -C C 's C � N Qc � U •m Q c � Ca ., o O Oc U . co CL c � c UcoT -c 0co �o � . , . ccD C) OrL � , >. a 4- o ,r)— • � O � Q (� (n c �' E o `.-0cno 0E — U to c ctS NO a) C fUU6 c = co N_O �. as , 1%.- c a) u) a I C N E a) _ .,_. Q- O O O 0 m O O fa O E i ".' *-• O O O 'a C C • UEc 2 "T O Q ^�^ > ca O a) O n Oo a) U i O N d c0 • O C O Q� ct r Qom--' 0.-0 O O N 4' - U `. '(n c E 'U ` . rn 0..7-6 O O ca O ` 0 (a L (a O co (NI .0 c - ca .0 ....d' dam' (a .0 1:)) Q_c O a) - O t O Q. .O 9 'D O O a) ,—(1) ti O N' . c E = Q+r -c a) V c _c Q = > 0 c o U U O a-- ,a r ..U) < 0 CO = ca ..0 >, O O - ca ca ca ca O 0 N— 131 ATTACHMF T L Z TO 1 REPORT# }LN Q3•-i5 `►- Co w- D O C "a O �-' C C O N Qi co N N c L N C to Q ■ to LO .c N O) 1 O O L O O 3 Q C C Q_C L O O U O >+ ° -0 O • O N E c - N O >+— T -0 N >, N ° 0 > C A Q o 1 E O •V c u) .0 c O C c O E �� N N Q "� N '-' U C Q d U N .�, Q 4. N op O N c a) a) Q O _c C ° O O C O p .c E N O Q C T- N o N > E L (I) Q CD 4--' ° .+, O U Q ?� N Q � = E � � Q Q cooE •� � ° � Lm—° ° ai _ oQ o 0) . >, ° cow E o Q � � �IS C C Q'L U N E N••C O Q'� L Q C 2?" X > = cc .O v- c o +. 1 Q E N U ' a. N o E E E •F+ U o cm c 'c O +. U.. QC () a) o -a _ ccaE ° u) .0c5 ° L t •L O - O . t +-. ++ ° CF) al ti .E QO � 0 = Qto "- Q — o O O . u'C O t •c L 0 N -C-CS o U E N O A • a• - EoEo `� a uQ) CO0 ° ° U - � °-w - � w -aE CZ E � � O (up' (a 0- > a) oC() � Q a) c c-Cj o -c to > c°)- c � o - Q0) ° o .o o � • _ L U Ca C ° •`ncQ � O 3ccoC .COCCa) ECCUEC � � ° � ° � ° .cocnQQ° EQC •LU � .L — L Co O N ° O N 0 0 0 0 0 a; C C C U ° Cv s�.c? ° o c o Q.c? (6.L O a) o U Q O Q E ' O U nh QcaU ° � U Q 0cc000_000c ._ _oEco No o Co u) cu o L L _Co r L > .125_ O O C L C CD O ° Q O .•� C O O U C p C C J o c >'°iN ,- o UU) U � O o —•V Q U O O O O C , Q U p CSI c L �' � EQ - � oca cU0 N >+ N __ '*r c o_._ ° Z c Q+,'' u) ti CO a) co (.1 �O Q U • 'E. >+ o C o Q p 0 t— O L N Q� O c O . �- O 0 ° 0 o 4- > °- c 4O O U CO_ ° Q N N o .CD O U a).� O .Q 0 o •d _0 > 0 .0 ° •U L N 4) C 4) L C C O > a • •,- O O 0 U 3 L u) N O O ,..0 CO ° Q L O > S -° 2 0 v) °. N 0 0 Q �•"= C OL O N O Q = L N N C j N ++ O Q :� O Q O co .� 0 U •• C d O . O O) C °. 0 O o > �+E E 0 Dl c C 0 O c U (0 •L U a) O U L Q C �- (B o N > O O O N O S. 0 0 Nt to ca ce U O o.•O $ N O N _c co o CO Q 0 0 U 'a Q Off_ v >+ C N O 0U U c cu to Uo >ti O N Q ( •L O .n ,co cn p _ O _c r -.--, c =Q. U r N _c _f6 -• 0 -0 NO C - ° O cn -0 O • 0.. CD •— O . C (2 C U C C O . L L ° L V � (n� I U N L .L ° � N "/ � ° L = = > _a >, - moo- = a) EE � •- '- o_ 0o. o3 -o < cnccOCC) 0c (() COM v) OEcO CV CO 132 /TTACHMViENT# 2- TO REPORT# PLN 03-15 1 c 4E' c o ca ca o O a-CU a) o CO ca - off ° � E ° ~-' 1 � a) o � ., 'c). 13 2 ° ca) ,_ � u°i •5 •(c-.) •� , c .5 ca ° 2 (aU ° O c .° N 0 U j " -a a) O O O w d a) ` 3 c = u) ° o N ca c O V CO 0 (a R5 a a) a._ a u)_c N Q c0o � �'coCDcFC c � cnE � � o N H1U o U U Oa a o 0 a c i"3 o U ca N u) O of .0 c c a) .c . E (a - E c cu Y o ' a) 03 2 0 E .ca c•� 7) c co 0 "5 .6 c`a a) o `o = ca E •(° -0 E a � 'oca-cN s- = a) cc II , ° � oE (Dcocca * ca a) c a) c ao ca a)a) o o .L a) ° a) D E a) a U ° o v o E ° •o c ca. a) • O4 UC cas o � 10 > +' •L a) u) ca c y d o ca E a.= N O ca _ = -a c .O c a) •_ _c a 4- L c ° o > 2 cI � o � as .c0ca) d 0 - 2 Q ° o o O . ''u) c _ca) •45 —o_ ST) ca E . 0) i=' Ua (n Q. •• ° ^ ° '> o ° � cnaa) = v � , QE � cao � .� c ° o �. � cnas ,_ t 0 O ° a U a) O ca c O _ N aj .u) 'U _c F- a) -4 t cca) c6 w ° = Eca)+- ca 2 0 5,-0 P. rn.� c m .c —° oa) Q rn� O > 6 >. 0 co ccOa. 0 c“...) .-.1 = ac 00< .c 0 � c � >,-) CL ca a) ° ° a) 2oc5 U _ a c a5 J +r o o a) CO c U p u) .>7 • in a c m • a) °,a c -0 'U O > o E V a ° a) c U ° a U < O a) a - a O O CO E � c om Q. c • 2 � ca O `0_ � I.L. •~ c a ` c W (a (a L a. ^' � a) � � a (a c E a -1-' •S a , .c a U a aa uc E �' ,1 �' a° - ca ca >+ Cl) d 3 O w a c a- Q Q c cn `° � co ca) cvnOC ° E .. • t o O v) c o O ca N `o to O ( U _D < c � o. U ,U) oo '> u) C a" N _a .0 > N I a)) co iii■ y CV fa 2 u) 0 'a a) (a > O N - N .Q 'U a) .- .I.r ca ++ Oa a c U -6 N U (a a) >.+., +, ..c Cl) O O u) -- a) ° c -c o ca a) - 4. U o 3 a) -4 •� N • c E co O L_ .j O " N co -- a) N F N •a .� a) 22 0 > t6 >. - a' a) Z 0_73 (a U N ° N .c N ° 2 .a 1 • 133 ATTACHMENT# 2- TO REPORT# f LN 63 15 c N >, a) N O N '`-' C _� c) a C >' t, O O -0 > , L 1/ 0 0 o M E as a) Y c > C (7) -- a.) (1103(/) 0 a) .22 2 CO +' (a CO (a O N N C , CD 0 (6U Q i0-• (a () a) = O O) -- 13 CO •D c 'T N a) O (n a) co A • O L N C Q.,.. L C� C ;� u) .- ca 0 .c o O o o -c O c L p a5 _ O L o fa C ' .}., C U V Q a) c 0 0 u to > -O a) t U 4- O O L as CD �� L o O U N 4, >, Q (a a) 5_ c a) N Q > 0 Q = c CC 0-_c _ � U .o0 "" E = a aic ,c > Ca off = �a313 � oas •= oCDcoiEa) M � c a L L L O C N a) W 20 y va U 4- C C Y oc (1' 13003 -0 -0 03 aLE -aCa — ) (/) 0 O L - O >+ O 0 '.7. O) V — co (a (n t N a Q-0 a C U 0 N � I- Y U •i 03Z a`) C /�� O L 0 a) (a ••-- 0) t"' E. a) (A () 0) Q 1-xi -0 = a) CD Q `u C .0 o-•_ C Q C c.) Y C • W C "0 C a) -c a) - 2 C a) o a) E Q a) o > o c .- Cli i_ (a o f a) c - o E :> .E ,c L Q (a -0 E Eo a) U ai > (6 a) (3)a .> Y 2 ." L ) 0 0 a) a) -C .- p 73 2 cu_ � o .Eaa) v) o (aom -t -1-, }� < 0. U) QQ0 L CO 4_ . O 'a > 4- L LM 0 R N z � -i-, � o .(, co as C > L a) a Q V O ON > � t C O Q > " U .c ca (D o = C) c a) a) a) L -0 c -C t o O)� a) c- N E. 0 Q 5 Q.o � Y .f.. O L +, .� Q •CEU) ai cv � aaa)) m � QZ o � co o i co (a .c .0 0-in .- O = — � L .^. a) 0 EL a nLc om -0 -0 >,c) r) r' •L- c .) o 000a) a) c. Lca) a) y- Oa) d (I) a) +� t .LY � E000 jcMCC4 � E (n CD ,- a) ca +O.• —O C E 0 5_ C O . O O (a cn o a) c (v CO _ N C Q L - o 0 a) O , (n L O O O O O O (� O .N L o C ...._ a) 0 C c.) _c .O -0 co a) a) = O 0 .0 c (/) CU Oo .. C 1-- CC. o s -0 N 0 ca m > E '� E 0 .E � ^ ca - E c o o a) (n a) = a) a N -0 ca o z • a as V N c d OO CO -0 AFF O r� � (a c S E c .- a) v o c (a (a (a > a) 'a O rl c o 0 0 0) C Q.Q -C Cl) O)4 j C C O V O C (a U (a 0 0 C O 4-:-,. a) o Y O O i Y C a) O 0-13 ) O CO O M E m �a � aE �a o aT, CO i E al CO ti r 134 I ATTACHMENT# 2. TO REPORT# kN 63 l• u) • > = a a) a) 3U :1--. -0 a) a) a) -p -y' E 0 Q _O -O L c c cu C P = -a O O U U .- c..) --+ = US O O > a) c ,_ U) L 3 O a) too � L CO = Q � a) �n -c a) YO0 � C 8....F., U a) Q E cu a) _ c6 O)_C 3 'a CO CO -0 L N a) N N > O •U) co C) v) >, • D L a) C C Q- N L C co V C a c ..0 Q a) .- ca a) _c c O o�O -- O_ ` O co U Q O a) 3 'c O �- Q"J C 'c Q"a a) .'-' ' a a Q� L Q. > CO O U) .0 LO (IS C C Q U) •> -O N U , 4- U N O Q ,1 w L a) Q O o .c C a v) A Q ca a) s- C a) co E- O c..)as 0 = 04 a 'a 4- .F. -sca Rs U Q _c cu . o 0" 0 E .c C U) _cu a) 4,, a)a) O '§ -a U O f6 •c c O U E ca U cu C 'O a) a CD .ca 3 U m L U O `) I a) -c U U a) U O C O U a) L 0 O c• 0• U0 -a c +' cui aim � � = ?'•- -C UI00 (D Y Q n 0 _0 O N a) as -0 -a O 3 ai — O .c a) =L.p v O � Q N co- "_ c a) •- Q E o c cam = a) ca E aa) U) U a sZU v) O C as U U � � F- Y U c a3 � a) +, Nom_ CO c a) a) cif 'a U) C .c a) cu •5 a) L O N U) a) f6 .5 > co c „v C 1— N O ±.. c .... cn I •� a C O C ^o -` a) a) c N Cr 2 cu a73 ccl �- +r -a c � U) L- c O Q] -, 0- Q U) L a) _, `) Na) c C a) ca .— LQca E ,c 0 Ems) N cv •c O 0.c c� U N c U) 0 O O U a) N•_ fa +r (lT (6 C >,-a 5 3Q. co > � N 7 „- _c O > = O Y .0 Y CD 0 Q.N (a t CO a) N C a gn OL co O a)cr 1 a a) c6 LO N a3 C (a c0 +> 5 U o E _a L _se co L.. Q U L 0 Z . O -a > y--• L Q a E Q. as N 0) C 2 al G) U '=„, J N o a3 NI- c4- 'a Q •2 O U C CU O N0)'c� O cu O L U O c a) e•-•••• E - a a Q- c a -- (/) O O L O C a) CL a al � E a) U U) pa CD s � c � c• . c �� � � = O E O U U C aN � � AIP a c d CO a U co O .0 O 0)•y.0 CO 'c 'c Q C (a U)13 U) a) -C N co 4- a) N c � U O U U c6 W. a) O L. Q L Q E L U U) �_ U N cu CL U E 7°a) a) O >+•U) � 5 °• E ca) > -a O -c C CO 0) 135 . ATTACHMENT# 2 TO REPORT / Pu'4 (53--/S - E o a) o te - a ) O. o N > a N 4= o 0) O t -- 'Q=oa) 0E VE � Q c°a ~ aa)) �' 92 ° a) a) a) a) L O E LO . • 0� O a) o 7 0- U 0 > aEt -0 CD U) -- _o 0_ o ° E O us 0 " 2 a) ° +, Q o I . ('� C •F+ L Q () ,_a) L Q Q � � �� Eo ° � •� � o � -.-4 N N +� U L Cl) C .u) c O N ca :~' 0 a.) ,,CI) cn -c ° _ o CZ ° v E o o _ ' > E = ai E " a >' E o2 .(7) a) >' O .c a) �. +r L- O CU - -0 >,1 o Q o c)c ccn C _c 'a U o c -a �*= � Cn � —° ° ° E ° - Cv ° a) 0 ° E ° " G) c aa)) coca = > 5 >' Q- a) ` '5 LE n ° � ° QJ .c '� L -2 a - oa-° _ o ° � aicn , (:) 00 0 ° o ° a•� °) �4= m> ° a 30Y +' � ° �, a) +� - oc ° .— coo ° -0 .NE a) cncaE cn cE Cl) d C a) co c .0 C O p ±, ca c c E a) O c ca O sZ U O a) E ._ O a c O O o. C O µ, O a) a) as - E L + C 0 - . +, :+_ >'4-, o o a) O a Q O U a) C c ctf c ° L > c. � co - c - Qca) E0" a5o >, Eo .a ° e - s = Eon ° -- oar E � 0LoU .0 o � -c ° va) cxaOaEO ° ° - C7N 'NYO � a) 0 cts }, I— co O 0 a) c as 0 >' Z .4 a o CO -0 i cyn •_ cUn =• c0 - N >' N L c � O U c O) N (a O) A N as c 0 E CO C +r O p E C CO Y O L a) 0 — ° r me aa) a) � c o ° c Co (a aas 3 CU co .a o ai � �a >' ° a) E EcoE m QLEoE 0 d a) O) O N p «) • c V 1- E O Q O L O E N C 4- , E O t Q- a) _U p O a) u°) c ts p a) as V to O L 0 c N > c co O -a U o. O a) O N t O c �,'C c •C ca L � 'LE +� ° .ca) c L 0)7 0 E ° 1 t .- v) Q ° - a i. O cn N () o ca 92 ° L U a) O - c� a) 'U 0 m oEaa)i -0oo) 0 >' as a) o ° c .c .° Q'co . c (13 .6 arc ,- oc m -E 03 M o a) C ° � 'E o ° E N E N 0 O +.• L a) (6 a) O N +- co E N -c •O E N = 4- E a) a) L C a) C0a) �o � cv ° a) o -0 NCOE0) cno oEEa) ° •L +. 0 coc ° pa) NEE +' C o � Ea) '- ' ++ ° Cnti'_ a) � a) th t0 'La°) - � NO � � C aO � � � aXi +, � ocnQL ° a (� '1 ° Q O• 'U N (Q 1-1:1 C .c (NI f6 "= �- f0 CO = Ce N a) t c 7 (E4 Ccs N p >' E c O N a) N '(n tB to N O 0 E O p o .L O t� p� O O Q- ' iz N rn • +., pti cC) cnU) 2O ' -a� ° ~ C (LS � EC3 � +. C � cnc3 U) a 0 c 0 -6 To .° >‘ o a) v°) = oin ° o-a a°) o 0. MM3 E- � a�) � a) a) - '° '° U L- ° �- •cn N L E - . a) . N - o O .- ;V L CO � c C C 5 > 'aE 'o .- •a -0 a) E a>i E ° > U) `n E -0 C coD a E EZ0 Cl a0_ Z = o 2 a.cA � 0Z cOV E o 0 CD N- N N N N 136 riAC �t�ME,`r 2 TO �;� :f',Lij��iii=f�f REPORT °• ON 03.45 . o Co E }, .c O a) a) A c a)• 73 = O 0 a) Q Ca > o • as To coaa) .. oaCo _c CZ t o E a) -c C c •-> 0) c o — u� Loc� � � � �)� sz cn 2 'O (O D D sz (1) Cz > .>,- o a) . • • C. _O ..c +r co a) Q (a u) Co Q o. � o � �uo ,- - - . ; a) o o � CO COCa4 -c 'ECoca) c < 0cI •E) .0 , oL- c a) .o a) co > = > • � � � oECn ) r26D C a a -04--.5Qo-c > � - � ` 'a a - ° -c a) aS� > � _c aa) cam . a) E cn Y > a) L � 0) O D c CD c o ° c � a) Otu o '6 u) -c) moo ° o � Y O a) C o) c O L U a) co — Co .� O 'Cno � � cCa u) a) N � d U -a 4_ a) c c BC Cn4- D 4) 0.. 0) CD a) -0 — a ca 'E •c O O O (a -STD •V co Cr) 7 c +' Q- c 0 ' aa) � a) C � c a) 0 .- ca (aN oE � _c—co CoCa «) _c a- `) a) ' OCa ~ E > = 0. U .N 0 2 a) Co. a) aj a) 4�> CoE0_ a) O co c .cA 0Ca2 co N 0 CD a) Y d Q E co. ut _� O L O L N Q O c Cl) E a_ a 2 c - C a) . Q' *-, ._ . c o N O a) L L Q. • • Co o w _c 5 Cs cc 0 co .� -c co :a Cu O >Q O a H ' g • 137