Two Submission to City Council on 180 Gordon Street Application

Attached are my submission to Council and comments on the planning analysis for 180 Gordon Street, in case you have any time to look at them .

As noted I think there are three main points that Council Members should address.

(1) Since the OP Amendment is new, never seen by Council or commented on by the public before, the Planning Act requires that it be heard at a Statutory Meeting with adequate time be given to anyone present who wishes to comment. Further it is standard Guelph practice not to make a decision at the Public Meeting when an OPA is first presented. Council should follow their own rules and leave a decision to a later council meeting.

(2) The OP Amendment directly contradicts the commitment in the OP to complete the 30 m buffer along Speed River whenever an opportunity arises through planning approval to remove a deficiency. The Speed River Corridor has been recognized by the city as an important Environmental corridor, possibly the most important in the city. The protection of the corridor, and a commitment to naturalize and improve the corridor, were core componenets of the environmental system put into the OP in 1995. It is clear from the Official Plan that this Environmental Corridor is very important. It is the singled out in the OP for specific attention. Section 3.6.18.3 promotes the improvement of riverfront lands with the retention or restoration of natural heritage qualities. Section 6.9.2 recognizes the riverine systems of the Speed and Eramosa Rivers as significant environmental corridors, and Section 6.9.5 promotes the naturalization and environmental enhancement of the Speed and Eramosa river valleys. These goals and objectives of the OP are implemented through the requirement, with no exceptions, that development is to be set back from the edge of the Speed and Eramosa Environmental Corridor by 30 m. (6.9.1.2; 6.9.5 1a; 6.9.5 1 b).

In preparation of OPA 42 the OP requirement for a 30 m buffer was reviewed and the study confirmed that the 30 m buffer should be kept inviolate. [Development of 180 Gordon Street is not at all prevented by the retention of the 30 m buffer, which results in a small traingle of P1 zoning in the upstream north corner of the property. This corner was never built on when the property was a gas station and is disturbed now because of the remediation work - it is easy to restore this corner ready for naturalization as part of the remediation process]. Completing the 30 m setback should be treated in exactly the same way as a road-widening provision is treated – it is well-established city procedure, specifically called for in the OP, and does not need further justification – the decision to complete the buffer has been made and has been confirmed by the OPA 42.

There is no transfer of property involved, just a zoning of the corner triangle as P1 and a requirement for it to be restored to the natural land contour and vegetated. The City has recently illustrated how this works, and works well, in the planning approval given to a project at 1291 Gordon Street. For this property the city required a 30 m buffer for the Hanlon Creek wetland; the entire 30 m buffer is, and remains, within the 1291 Gordon property. The 30 m buffer portion of 1291 Gordon is zoned P1 and the EIR for the property requires the buffer to be a “no-touch” zone with absolutely no disturbance of the surface during construction or anytime after. In addition the city added the further requirement that no building could be closer than 7.5 m to the 30 m buffer boundary. This is the standard city policy at work and is to applied to 180 Gordon as the OP directs.

(3) The current proposal is slearly too intensive for this unique sensitively situated property. The proposed zoning has large variations from the maximum/minimum provisions of the zoning by-law for almost every aspect of the project – density, setback, angular plane, facade length, oiutside amenity area. This project is clearly a long way outside the boundaries of compatibility – both compabibility with the park and compatibility with the residential neighbourhood. Every problem would be overcome by reducing the number of units to that given as the maximum in the zoning by-law.

A five or six unit high-class townhouse development suits the limitations imposed on the site and fully meets all provincial requirements, including Places To Grow. Guelph has a very good programme underway to meet the 40 % target for growth within the built-up areas. There are four types of sectors within the built-up-area category. Most of the intensification is slated to be within the first three areas specifically identified for intensification. 180 Gordon is within the “residual” built up area that is to accomodate only a small proportion of the intensification. The difference of 6 units between the proposal (11 units) and what the site can accomodate (5 units) has no significance in terms of meeting PTG. The important issue is what is the maximum density is possible without damaging Marianne’s Park. The answer if 5 or 6 and this number is a fully satisfactory contribution toward PTG.HW