Re: Draft Performance Monitoring Framework and Draft Indicators for the Provincial Policy Statement, 2005

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1 June 19, 2009 Kyle MacIntyre Team Lead PPS Perfrmance Mnitring Framewrk Ministry f Municipal Affairs and Husing Prvincial Planning Plicy Branch 777 Bay Street, 14 th Flr Trnt, ON M5G 2E5 Re: Draft Perfrmance Mnitring Framewrk and Draft Indicatrs fr the Prvincial Plicy Statement, 2005 Dear Mr. MacIntyre: On behalf f the Ontari Prfessinal Planners Institute (OPPI), I wuld like t thank yu fr the pprtunity t cmment n the Draft Perfrmance Mnitring Framewrk and Draft Indicatrs Discussin Paper. We welcme and supprt better tls t measure and mnitr the effectiveness f Prvincial and municipal planning plicies. Established in 1986, OPPI is the recgnized vice f the Prvince s planning prfessin and prvides visin and leadership n key planning issues. The Institute s mre than 3,000 members wrk in gvernment, private practice, universities and nn-prfit agencies in the fields f urban and rural develpment, urban design, envirnmental planning, transprtatin, health and scial services, heritage cnservatin, husing, and ecnmic develpment. Our cmments n the Perfrmance Mnitring Framewrk and Draft Indicatrs are structured as respnses t the questins psed in the discussin paper. We wuld be pleased t cntinue t cmment and ffer ur prfessinal insight as key stakehlders as this prcess evlves. General cmments: There remains a plethra f challenges and details t be reslved related t scale f measurement, metrics, data surces and implementatin f the mnitring which in itself wuld be wrth seeking input and having cnsultatin n. In the absence f this detail, ur cmments n the relevance r success f the prpsed indicatrs are limited.

2 Reliance n census data is a gd first step. Hwever this reliance may limit ur ability t understand mre lcalized changes r reginally specific changes as the Census Metrplitan Area (CMA) gegraphies d nt always align with municipal bundaries. Over the lng term, municipalities shuld seek mre specific means fr data gathering and mnitring. Utilizing the measures set ut in the Grwth Plan (e.g. peple + jbs per hectare) will prvide fr demnstratin f hw these measures can be implemented and a cnsistency with stated plicy bjectives. Discussin Paper Questins: 1. Based n yur knwledge f the PPS, review the brad categries and subcategries prpsed fr mnitring. Hw can they be imprved? The recmmended brad categries appear t be cnsistent with the structure f the PPS. We als recmmend yu cnsider including a categry related t the achievement f the Part IV, PPS Visin. The subcategries seem t be missing reference t cmmunity facilities and cmmunity infrastructure beynd parks and pen spaces. This wuld mst apprpriately be fund under Categry 1. Categry 3 shuld be strengthened t address the wise use f land. Althugh this is addressed t a degree in the Categry 1 cmpact frm indicatrs, there may als be merit in measuring the rate f absrptin f Greenfield land and urban land expansin. Built frm change ccurs slwly, especially in established cmmunities and within the built up areas. Where change ccurs slwly brad measurements (such as census date) wn t detect much and are unlikely t be effective indicatrs. Under the tpic water, measuring the number f municipal fficial plans that identify sensitive surface and subsurface water supplies measures where the designatins were created thrugh legislative prcesses utside the Planning Act, needs mre thught. As stated, the prpsed indicatr measures enfrcement and nt the effectiveness f the prpsed designatin. Under the Clean Water Act, there will be apprval prcesses that address risks psed by develpment in these sensitive areas. The bjective t be mnitred is whether the designatins are effective in terms f addressing this risk. Incrprating the designatin desn t address whether the risk management is effective r nt. 2

3 2. Lking at the draft prpsed indicatrs fund in the appendix, d yu think they will likely prvide useful infrmatin t assist in measuring the effectiveness f the PPS? Sme will and sme wn t. If a plicy is t be effective, the manner in which it is applied in decisin-making needs t be assessed. The perfrmance t be measured is the applicatin f the plicy r the quality f the decisin-making. Case studies f selected applicatins that meet the standards sught need t be cmpared with actual decisin-making when the plicy is applied t determine whether the plicy is being met. With respect t fficial plans setting minimum husing targets, etc., mnitring these may bear n relatinship t what happens n the grund. It measures cnfrmity, nt the effectiveness f the plicy. 3. Can the indicatrs be imprved r refined t prvide mre useful infrmatin? Mnitring presumes we have sme sense f what is the preferred physical develpment f ur municipalities. That sense will vary depending upn where in Ontari that municipality is situated. We recmmend yu g back t Part IV, the Visin fr Ontari s Land Use Planning System and benchmark what that physical develpment visin wuld entail in Ontari s municipalities. Once set, the indicatrs can be related directly t elements f that visin, reginally adjusted. We als suggest using unit measures similar t ther prvincial plicy (e.g., persns per hectare, rather than persns per square km). We als suggest under Categry 1: Husing - that cmpact frm als be measured by change in average Greenfield density bth residential and emplyment; Energy and Air Quality - that measures f walkability be cnsidered e.g. percentage f ppulatin within 10 minutes f parks, r schl; Energy and air quality - recmmend additinal indicatr arund husing density nt just lt size; Energy and Air quality - recmmend the additin f hspital admissins during pr air quality and extreme heat events; and Indicatrs related t emplyment areas absrptin and densities will be imprtant t mnitr; als the number f jbs within centres and crridrs are imprtant t understand. Under Categry 2, we suggest: 3

4 Transprtatin and transit - mnitr the change in peple and jb density arund majr transit statins. Under Categry 3, we suggest: Natural Heritage - in additin t the number f Official Plans there shuld be a determinatin f hw many new hectares f natural heritage cme under this prtectin. 4. Are there any ther surces f data/infrmatin fr the draft indicatrs that yu believe culd be used t supprt their further develpment? Data needs t be generated that measure the effectiveness f the plicy applicatin in decisin making. Specifically cnsider this as part f the implementatin f Grwth Plan and Greenbelt Plan in ther wrds as plicy directins n 40% intensificatin, 50 peple and jbs per hectare n Greenfield, 200 peple and jbs per hectare in Urban Grwth Centres. 5. Wuld yu/yur rganizatin find the infrmatin frm the indicatr useful t yur wn perfrmance mnitring prgram(s)? See belw. 6. What are sme indicatrs that yu wuld suggest the gvernment use t mnitr the effectiveness f the PPS? Please identify what plicies f the PPS yur suggested indicatr is measuring. In terms f active healthy cmmunities, there are several web based tls and an emerging Leadership in Energy and Envirnmental Design - Neighburhd Develpment (LEED ND) standard which prvide measurements useful t assessing whether an existing cmmunity r prpsed develpment wuld be r cntribute t be an active cmmunity. Use sme f these standards as measures upn which t develp mnitring parameters t measure the effectiveness f the planning plicy and its applicatin. See abve fr additinal detailed cmment n metrics. 7. What data surces are currently available t supprt mnitring f yur prpsed indicatr(s)? We need t wrk mre clsely with ther prfessins (e.g. health), wh are generating data t use their infrmatin as indicatrs. Fr example: 4

5 Hspital admissins during pr air quality and extreme heat events are a sure indicatr as t the effects f pr air quality. Transit peratrs have detailed infrmatin n changes in ridership. Envirnmental master plans are being created t manage impact f brad settlement patterns. 8. Cnsidering the criteria fr a gd indicatr, what are sme f the key strengths and weaknesses f yur prpsed indicatr(s)? It is essential that the mnitring prgram be capable f measuring whether decisins achieve the visin f the statement. Unless that visin is articulated with mre clarity in the varius cntexts municipalities find themselves, the indicatrs wn t help much. 9. Wuld the prpsed new indicatrs be apprpriate t mnitr the identified bjectives prvince wide? Or are the prpsed indicatrs mre reginally based? This is a large Prvince with widely varying cnditins thrughut. While deriving a Prvince-wide benchmark culd be prvided relatively easily t create a baseline, Prvince wide indicatrs alne may nt be an effective way t prceed. Reginal municipality based indicatrs wuld allw fr reginal cntext and patterns and wuld be cnsistent with many f the bjectives and mnitring that will be required fr cnfrmity t the Greenbelt and Grwth Plans. T schedule a meeting r fr further infrmatin, please have yur staff cntact Lretta Ryan, MCIP, RPP, Manager, Plicy and Cmmunicatins at (416) r by at [email protected] Sincerely, Wayne Caldwell, MCIP, RPP President, Ontari Prfessinal Planners Institute 5