Kevin Eby, RPP Eby Growth Management Planning Services
February 2019
EXECUTIVE SUMMARY
2017 Growth Plan Policy 2.2.7.6 (a) requires that any alternative Designated Greenfield Area (DGA) density target “maintain or improve on the minimum density target in the official plan that is approved and in effect as of July 1, 2017; …”
Direct comparisons of the DGA density requirements between the 2006 Growth Plan and the 2017 Growth Plan are not appropriate without adjustments first being made to equate the two policy requirements as noted in this report. The Envisioning Brantford document attempts to directly equate the 50 residents and jobs combined DGA density contained in the 2006 Growth Plan, and reflected in Brantford Official Plan Policy 15.4.2, with the DGA density target provided for in the 2017 Growth Plan. This is a good example of comparing apples and oranges. They may both be fruit – or in this case densities – but they are completely different things.
The 2006 DGA density was a blend of densities applicable to both residential and employment areas. Municipalities could plan for less than the minimum density in portions of the DGA, but any shortfalls in densities in one area were required to be compensated for in others. The 2017 DGA density only applies to what are primarily residential areas – and associated commercial and institutional land uses – and is based on the exclusion of a much broader range of environmental features, infrastructure and land uses than the 2006 Growth Plan DGA.
After compensating for a reduced employment area DGA density as required under the provisions of the 2006 Growth Plan and Brantford Official Plan Policy 15.4.2, and then adjusting the density to make it comparable to the 2017 Growth Plan requirements, the required density for residential DGA in Brantford is 71.4 residents and jobs combined per hectare. The Envisioning Brantford document proposes a density applicable to the same lands of 52 residents and jobs combined per hectare based on the 2017 Growth Plan exclusions.
Applying a 52 residents and jobs combined per hectare density to lands that are currently subject to a directly comparable required density of 71.4 residents and jobs combined per hectare does not conform with the requirement to “maintain or improve on the minimum density target in the official plan that is approved and in effect as of July 1, 2017” as required by 2017 Growth Plan Policy 2.2.7.6 (a).
Implementing a minimum average residential DGA density of 71.4 over the entirety of the DGA in Brantford as required to conform to the provisions of Growth Plan Policy 2.2.7.6 (a) is not practical, but is required by policy in a conform with policy environment.
The Province has recently proposed Amendment No. 1 to the 2017 Growth Plan. As part of this amendment, the Province is proposing changes that would directly impact the required densities in Brantford’s DGA. It is the recommendation of this report that the completion of the Envisioning Brantford process be deferred until such time as Amendment No. 1 is in force and effect. This would allow the City and members of the public to participate fully in the processing of Amendment No. 1 to ensure appropriate DGA density requirements for Brantford are established through that process. It may also provide the opportunity to incorporate any changes arising from the upcoming update to the population forecasts mandated by 2017 Growth Plan Policy 5.2.4.6.
REPORT
1.0 Scope of the Assignment
Eby GMPS was retained by Ella Haley to perform a scoped review of the “Envisioning Brantford – Municipal Comprehensive Review Part 1: Employment Strategy, Intensification Strategy, Housing Strategy and Land Needs “(Envisioning Brantford document). This assignment was restricted to a review of whether the alternative Designated Greenfield Area (DGA) density recommended in the Envisioning Brantford document conforms to 2017 Growth Plan Policy 2.2.7.6 (a). Policy 2.2.7.6 (a) states:
“For upper- and single-tier municipalities in the outer ring, council may request an alternative to the target established in policy 2.2.7.2 through a municipal comprehensive review where it is demonstrated that the target cannot be achieved and that the alternative target: a) will maintain or improve on the minimum density target in the official plan that is approved and in effect as of July 1, 2017; ...“
2.0 Comparing the 2006 and 2017 Growth Plan Minimum DGA Density Targets
2.1 2006 Growth Plan DGA Density
The 2006 Growth Plan DGA density of 50 residents and jobs combined per hectare applies to all areas outside the built boundary, except for the following environmental features, which are excluded from the calculation:
“wetlands, coastal wetlands, woodlands, valley lands, areas of natural and scientific interest, habitat of endangered species and threatened species, wildlife habitat, and fish habitat”
The list of exclusions from the DGA density calculations in the 2006 Growth Plan was definitive: they were all environmental features. As a result, the density calculations undertaken in accordance with the 2006 Growth Plan had to include lands such as roadways, utility corridors, golf courses and cemeteries, as well as any environmental features not contained in the list above. This would include buffers, linkages and floodplains not part of valley lands or other features listed.
The 2006 DGA density was a blend of densities applicable to both residential and employment areas. Municipalities could plan for less than the minimum density in portions of the DGA, but any shortfalls in densities in one area were required to be compensated for in others.
2.2 2017 Growth Plan DGA Density
The 2017 Growth Plan DGA density applies to all areas outside the built boundary, except for the exclusions permitted under the 2006 Growth Plan, and the following:
- employment areas
- rights-of-ways for electricity transmission lines and energy transmission
- pipelines freeways and railways
- cemeteries
- floodplains, environmental linkages, and potentially key hydrological areas, sand barrens, savannahs, tall grass prairies, alvars, federal and provincial parks, conservation reserves, lands that have been restored or have the potential to be restored to a natural state, associated areas that support hydrological functions, and working landscapes that enable ecological functions to continue
In the City of Brantford, the required DGA density as required by the 2017 Growth Plan is 80 residents and jobs per hectare. The 2017 DGA density only applies to what are primarily residential areas – and associated commercial and institutional land uses – and is based on the exclusion of a much broader range of environmental features, infrastructure and land uses than the 2006 Growth Plan DGA. An alternative DGA density may be approved by the Province, subject to the provisions of 2017 Growth Plan Policy 2.2.7.6.
2.3 Use of the Term “Residential DGA” in this Analysis
The Envisioning Brantford document interchangeably uses “DGA Developable Areas”, “Existing DGA” and “Community Areas” when referring to existing DGA currently within the settlement area boundary in the Brantford Official Plan. These areas are the functional equivalent of the term “residential DGA” used in the 2006 Growth Plan analysis to differentiate between residential and employment area DGA, and as such, will be referred to as “residential DGA” consistently throughout the remainder of the analysis. Residential DGA includes all lands typically associated with residential areas, including associated small scale commercial and institutional uses such as schools, recreational facilities, cemeteries and places of Worship. Where necessary, the residential DGA in this analysis will be specifically identified as having been calculated based on the 2006 or 2017 Growth Plan exclusions.
3.0 Brantford Minimum DGA Density Targets (in effect on July 1, 2017)
Policy 15.4.2 of the Brantford Official Plan provides policy direction related to the DGA density requirements. Policy 15.4.2 states:
“It is the intent of this plan to achieve a minimum gross density target of 50 residents and jobs combined per hectare in the Greenfield Areas. The density target is measured over the entire designated Greenfield Areas, excluding natural heritage features identified in provincial plans and this Plan that prohibit development: wetlands, woodlands, valley lands, areas of natural and scientific interest, habitat of endangered and threatened species, wildlife habitat, and fish habitat.”
This policy was adopted and approved under the provisions of the 2006 Growth Plan. It is important to note that like the DGA density target provided for in the 2006 Growth Plan, the density target in the Brantford Official Plan is a blended target for residential and employment uses. As a result, any reduction in the densities applicable to one type of land use need to be compensated for with corresponding increases in the other.
3.1 Existing Employment Area DGA Densities – 2006 Growth Plan Exclusion-Based Calculation
The Envisioning Brantford document assumes an average density of 25 jobs per hectare (page 73) on the 390.4 hectares of existing employment area DGA (Table 9.1). This would result in a total of 9,760 jobs within the existing employment area DGA upon full build-out.
It is important to note, however, that the 390.4 hectares of existing employment area DGA identified in Table 9.1 is net of exclusions permitted by the 2017 Growth Plan and needs to be adjusted to permit comparisons to the 2006 DGA density. Table 9.1 also identifies 76 hectares of major infrastructure that appears, based on Figure 9, to be located directly adjacent to or running through employment area DGA. This infrastructure was not permitted to be excluded as part of the DGA density calculations under the 2006 Growth Plan. Combining the infrastructure (76 hectares) with the 390.4 hectares of employment area DGA from Table 9.1 results in a total of 466.4 hectares of employment area DGA based on the 2006 Growth Plan exclusions. Recalculating the employment area DGA density using this combined total, as would have been required by the 2006 Growth Plan, results in an average DGA density for employment areas of 20.9 jobs per hectare.
This is consistent with the proposed 20 jobs per hectare employment area DGA density originally recommended in the 2016 Draft Brantford Official Plan as noted in the Envisioning Brantford document (page 72) that would have been based on the 2006 Growth Plan exclusions.
3.2 Existing Residential DGA Densities – 2006 Growth Plan Exclusion-Based Calculation
3.2.1 Calculating the Compensation Resulting from the Employment Area DGA as Required to Conform to the 2006 Growth Plan and Brantford Official Plan Policy 15.4.2
In order to achieve the average 50 residents and jobs combined per hectare as required by the 2006 Growth Plan and Brantford Official Plan Policy 15.4.2, any shortfall in density resulting from the 20.9 jobs per hectare density applicable to the employment area DGA needs to be compensated for within residential DGA. This compensation would be calculated as follows:
Required Compensation for Shortfall in Density Target on Employment Area DGA Required to be Applied to the Residential DGA = (466.4 hectares of employment DGA based on 2006 Growth Plan exclusions x 50 residents and jobs combined per hectare as required by Brantford Official Plan Policy 15.4.2) - (9,760 jobs in employment areas within the existing DGA upon full build-out) = 13,560 combined residents and jobs
3.2.2 Calculating the Residents and Jobs Combined Required on the Existing Residential DGA to Conform to the 2006 Growth Plan and Brantford Official Plan Policy 15.4.2
There are 664 hectares of residential DGA identified on Table 9.1 based on exclusions permitted by the 2017 Growth Plan. Table 9.1 identifies another 12.7 hectares of cemetery that appears, based on Figure 9, to be surrounded by residential DGA. This cemetery was not permitted to be excluded as part of the DGA density calculations under the 2006 Growth Plan. Combining the cemetery lands (12.7 hectares) and the 664 hectares of residential DGA from Table 9.1 results in a total of 676.7 hectares of residential DGA based on the 2006 Growth Plan exclusions. This is the area to which the DGA density requirements under both the 2006 Growth Plan and Brantford Official Plan Policy 15.4.2 would apply.
The number of residents and jobs that would need to be located on the above noted 676.7 hectares to comply with the 2006 Growth Plan and Brantford Official Plan Policy 15.4.2 would be calculated as follows:
Residents and Jobs Combined Required to be Accommodated within the Existing Residential DGA to comply with the 2006 Growth Plan and Brantford Official Plan Policy 15.4.2 = (676.7 hectares of residential DGA based on 2006 Growth Plan exclusions x the Policy 15.4.2 DGA density target of 50 residents and jobs combined per hectare) + the 13,560 residents and jobs required as compensation for the shortfall in the density target on employment area DGA = 47,395 residents and jobs
3.2.3 Calculating the Residential DGA Density Required to conform to the 2006 Growth Plan and Brantford Official Plan Policy 15.4.2
Dividing the required 47,395 residents and jobs by the 676.7 hectares of residential DGA calculated using the 2006 Growth Plan exclusions, results in a required residential DGA density of 70 residents and jobs combined per hectare. This is the residential DGA density that Brantford had to be planning for to conform with the requirements of Brantford Official Plan Policy 15.4.2 and the 2006 Growth Plan.
3.2.4 Adjusting the Residential Density to Permit Direct Comparison with the Requirements of the 2017 Growth Plan
To provide a direct comparison between the residential DGA density requirement of Brantford Official Plan Policy 15.4.2 and the density requirements of the 2017 Growth Plan, the 47,395 residents and jobs would be divided by the 664 hectares of DGA using exclusions from the 2017 Growth Plan (removing the 12.7 hectare cemetery from the calculation). This results in a residential DGA density of 71.4 residents and jobs combined per hectare.
4.0 Anticipated Growth on Existing Residential DGA
Based on the Envisioning Brantford document (Table 10.18), the proposed 2041 residential DGA density on the existing residential DGA lands using the 2017 Growth Plan exclusions is 47.2 residents and jobs combined per hectare.
5.0 Proposed Alternative Density
The Envisioning Brantford document proposes a settlement area expansion of 460 hectares for residential DGA purposes and provides for a density of 60 residents and jobs combined per hectare on these lands. This would result in an overall density for the proposed residential DGA following expansion of the settlement area of 52 residents and jobs combined per hectare. This is the alternative density proposed by the Envisioning Brantford document.
6.0 Conformity of the Proposed Alternative Density Target to 2017 Growth Plan Policy 2.2.7.6 (a)
Policy 2.2.7.6 (a) of the 2017 Growth Plan states that alternative densities will maintain or improve on the minimum density target in the official plan that is approved and in effect as of July 1, 2017. In responding to this requirement, the Envisioning Brantford document states:
“The minimum density target in effect in the City’s current Official Plan is 50 residents and jobs combined per hectare. However, it is not reflected in what has been built to date in the DGA, largely due to the addition of Tutela Heights, but it is being achieved in current registered and draft approved plans of subdivision. The in-effect density will increase as the remaining vacant lands in the current Settlement Area boundary (i.e. the Existing DGA) are planned to achieve a higher density of 55 residents and jobs combined per hectare. In addition, the density on new Community Area DGA lands (i.e. the New DGA) will be planned achieve 60 residents and jobs combined per hectare, which also improves the in- effect density target. (emphasis added)”
The Envisioning Brantford document directly equates the 50 residents and jobs combined DGA density contained in the 2006 Growth Plan, and reflected in Brantford Official Plan
Policy 15.4.2, with the DGA density target provided for in the 2017 Growth Plan. This is a good example of comparing apples and oranges. They may both be fruit – or in this case densities – but they are completely different things.
After compensating for the reduced employment area DGA density as required under the provisions of the 2006 Growth Plan and Brantford Official Plan Policy 15.4.2, and then adjusting the density to make it comparable to the 2017 Growth Plan requirements, the required density for residential DGA in Brantford is 71.4 residents and jobs combined per hectare. The Envisioning Brantford document proposes a density applicable to the same lands of 52 residents and jobs combined per hectare based on the 2017 Growth Plan exclusions. Applying a 52 residents and jobs combined per hectare density to lands that are currently subject to a directly comparable required density of 71.4 residents and jobs combined per hectare does not conform with the requirement to “maintain or improve on the minimum density target in the official plan that is approved and in effect as of July 1, 2017” as required by 2017 Growth Plan Policy 2.2.7.6 (a).
7.0 Population Projections
2017 Growth Plan Policy 5.2.4.7 requires the Province to review the Growth Plan population forecasts every five years. The last update to the forecasts was in 2013, so an update should be underway at this time or in the immediate future.
In reviewing the most recent population projections by the Ministry of Finance (Spring 2018), it is noted that the 2041 population projection for the Brant Census Division – which includes Brant County and the City of Brantford – is 185,100. This compares to a corresponding Growth Plan 2041 population forecast – attained by combining the City Brantford and the County of Brant forecasts in Schedule 3 – of 220,000. This 34,900 projected population difference to 2041 between the Spring 2018 Ministry of Finance projections and the Growth Plan forecasts prepared in 2013 is of serious concern as it can affect both the amount of land required to accommodate growth and the corresponding development related revenues generated to pay for infrastructure, usually required in advance, to provide for such growth. As noted in the document “A Review of the Residential Land Needs Assessment Process Associated with Implementation of the Growth Plan for the Greater Golden Horseshoe” released by the Friends of the Greenbelt Foundation in July 2016:
.”The annual Ministry of Finance population projections are trends-based extrapolations of demographic, immigration, and migration data available at the time they are prepared. They do not reflect policy-based assumptions or preferences for the distribution of growth. The Growth Plan population forecasts reflect the same basic demographic, immigration, and migration assumptions as the MOF projections for the Greater Golden Horseshoe as a whole, but the population is distributed across the Greater Golden Horseshoe based on the policy objectives of the Growth Plan, aligned where possible with the growth aspirations of individual municipalities.”
In the background document “Greater Golden Horseshoe – Growth Forecasts to 2041, Technical Report (November 2012) Addendum” prepared by Hemson Consulting Ltd. as justification for the most recent update to the Growth Plan population forecasts, the reference scenario – the scenario used in the Growth Plan – projected a 2016 population for the City of Brantford of 104,000. The 2016 Census population, including assumed undercount, for the equivalent area – prior to the boundary adjustment – as reported in the Envisioning Brantford document (page 9) was 100,525. This represents a shortfall in the Growth Plan population forecast of 3,475 or 43 percent of the growth projected by Hemson Consulting Ltd. for the City of Brantford in just the first five years of the forecast (2011 to 2016). It would appear based on these early findings that the population for the City of Brantford may be trending closer to the Ministry of Finance projection than the Growth Plan forecast. It is unclear what policy levers either the Province or the City of Brantford has available to it to ensure the Growth Plan forecasts are achieved.
8.0 Conclusions / Recommendation
Direct comparisons of the DGA density requirements between the 2006 and 2017 Growth Plans are not appropriate without adjustments first being made to equate the two policy requirements as noted in this report. The authors of the Envisioning Brantford document have failed to properly apply Policy 2.2.7.6 (a) of the 2017 Growth Plan. The alternative density of 52 residents and jobs combined per hectare as proposed by the Envisioning Brantford document does not conform to 2017 Growth Plan Policy 2.2.7.6 (a).
Using the minimum required density of 71.4 residents and jobs combined per hectare resulting from the application of Policy 15.4.2 in the Brantford Official Plan as required by 2017 Growth Plan Policy 2.2.7.6 (a), an expansion of only 161 hectares for residential DGA can be justified, as opposed to the 460 hectares proposed by the Envisioning Brantford document. The permitted expansion is calculated as follows:
(58,916 residents and jobs combined required to be accommodated in the residential DGA - 47,395 residents and jobs required to be accommodated in the existing residential DGA at a density of 71.4 residents and jobs combined per hectare) / 71.4 residents and jobs combined per hectare = 161 hectares
Implementing a minimum average residential DGA density of 71.4 over the entirety of the DGA in Brantford as required to conform to the provisions of Growth Plan Policy 2.2.7.6 (a) is not practical, but is required by policy in a conform with policy environment.
The Province has recently proposed Amendment No. 1 to the 2017 Growth Plan. As part of this amendment, the Province is proposing changes that would directly impact the required densities in Brantford’s DGA.
It is the recommendation of this report that the completion of the Envisioning Brantford process be deferred until such time as Amendment No. 1 is in force and effect. This would allow the City and members of the public to participate fully in the processing of Amendment No. 1 to ensure appropriate DGA density requirements for Brantford are established in the Growth Plan through that process. It may also provide the opportunity to incorporate any changes arising from the upcoming update to the population forecasts mandated by 2017 Growth Plan Policy 5.2.4.6.