Parkland Dedication. Policies, Practices, Procedures and Bylaw Review and Update. City of Guelph. March 2018

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1 City of Guelph Parkland Dedication Policies, Practices, Procedures and Bylaw Review and Update Background Report March 2018 McCarthy Tetrault N. Barry Lyon Consultants SW Irvine & Associates

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4 CITY OF GUELPH Update of Parkland Dedication Procedures and By-law Table of Contents 1.0 INTRODUCTION 1.1 Background 1.2 Purpose VALUE OF THE PARKS & OPEN SPACE NETWORK 2.1 Quality of Place / Quality of Life PLANNING OVERVIEW 3.1 The Planning Act 3.2 The City of Guelph Official Plan 3.3 Parkland Dedication Practices 3.4 Area Specific Parkland Policy TRENDS AFFECTING PARKS & RECREATION PLANNING 4.1 Trends in Planning & Policy 4.2 Urbanization & Intensification POLICY & PARKLAND BENCHMARKING Ontario Municipal Policy Comparison INNOVATIVE PARKLAND TOOLS & POLICIES An Innovative Policy Approach Strata Parks and POPS N. Barry Lyon Consultants McCarthy Tetrault SW Irvine & Associates

5 CITY OF GUELPH Update of Parkland Dedication Procedures and By-law 7.0 STAKEHOLDER CONSULTATION The Engagement Process First Phase of Consultation Second Phase of Consultation Next Phase of Consultation SUMMARY & NEXT STEPS 8.1 Summary 8.2 Next Steps APPENDIX A: APPENDIX B: BENCHMARKING COMPARISON TABLE AND INTERVIEWS REFERENCES N. Barry Lyon Consultants McCarthy Tetrault SW Irvine & Associates

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8 INTRODUCTION

9 1.0 INTRODUCTION 1.1 Background Policy and planning trends throughout Ontario are changing the way that municipalities plan for growth. Guelph, like all municipalities in the Greater Golden Horseshoe area are required to meet growth and density targets established by the Growth Plan. This reality is leading to more compact and intensified development patterns within municipalities, which impact land values, development potentials, and parkland planning, among other aspects of urban development. Guelph s current Parkland Dedication Bylaw was first drafted in 1989 with amendments in 1990 and Guelph has changed substantially over the last three decades, as has planning and development in Ontario generally. Changes to the Planning Act in 2016 combined with Guelph s population growth projections mean that new approaches to parkland planning are needed. In addition to the beautiful greenspaces that already exist throughout Guelph, new types of parks with more urban qualities and of various sizes will need to be planned and acquired, particularly in the Downtown and other growth areas of the city. The City is currently planning two new neighbourhoods, in what represents some of the last greenfield land in Guelph. Clair- Maltby and the Guelph Innovation District will require particular attention to ensure that these new communities are provided with the same high quality park system as the rest of the city. The public parks system is not only an essential component in the development of a complete community, the conveyance of parkland, as articulated under the Planning Act, is also an important instrument in the way municipalities can influence development. Guelph has a number of legal mechanisms available to maintain and enhance the parkland system, established through the Planning Act. As the city grows and densifies, there is a concern that the current parkland dedication policy regime and its associated implementation procedures will not reflect the changing municipal growth patterns, including new and denser housing types, socioeconomic trends, and equitable parkland provision levels. The Official Plan five-year review (Official Plan Amendment 48) has introduced a number of revisions to parks and open space policies for the City to address some of these emerging trends, however the bylaw and other practices, procedures and protocols have not yet been revised. In this context, the City now needs to review procedures that help generate the public parks system in a form appropriate for its evolving context. The City therefore wishes to revisit its current Parkland Dedication practices, procedures and bylaw, and align them with the policy direction identified in the Official Plan. Further, it is the City s objective that the review and update of these policies is carried out through a process that is transparent, recognizes the inherent differences in land values across the City and that does not undermine growth and development objectives. This approach is intended to balance the continued provision of a substantial and successful parkland system with the requisite growth requirements. INTRODUCTION Background Report - March 2018 // City of Guelph 1

10 1.2 Purpose INTRODUCTION To ensure that the growing population of Guelph is well-served by its public parks system, and that the nature of the parkland generated reflects the evolving higher density built form, the City must review its parkland dedication and payment-in-lieu powers, policies and procedures. This review is critical to ensure that the City is empowered through fair and appropriate policies to continue to provide a diverse and thriving park system today and into the future. To achieve this objective, the purpose of this project is to: Implement the policies of the Official Plan by updating the parkland dedication bylaw. Deliver increased certainty, predictability and transparency, in the parkland dedication and collection process for all stakeholder. Develop an efficient process to value lands for payment-in-lieu of land conveyance that recognizes the existing and changing nature of land values within Guelph in response to the evolving urban structure of the city. Streamline staff procedures and protocols for executing parkland dedication agreements and negotiations. Draft Guidelines and a Framework for parkland dedication and payment-inlieu to form the basis of a new parkland dedication bylaw, that will:»» Be consistent with Planning Act provisions and other applicable legislation.»» Ensure that parkland provision throughout Guelph meets or exceeds provision standards into the future.»» Consider exemptions and credits for parkland dedication, wherever deemed appropriate.»» Address various forms and densities of residential development, as well as other development types including mixed use, commercial, industrial and institutional, and accounting for the City s vision for the various areas of Guelph.»» Address feedback from all stakeholders throughout the project. The objectives of the Background Report are to articulate the results of the rigourous research conducted to describe the true value of parkland, understand trends impacting parkland planning and provision, account for relevant policy and parkland acquisition tools, compare and contrast a number of municipal policies and parkland systems, and to review the multiple stages of stakeholder engagement completed to-date. The analysis in this report will begin the process of identifying strategies and directives for the development of the draft framework and guidelines for the new bylaw and ultimately for recommendations for updates to the parkland dedication, practices and procedures. This project and each of the reports and other deliverables represent a collaborative effort between the members of the project consulting team and staff from various departments within the City of Guelph. 2 The Planning Partnership

11 INTRODUCTION Background Report - March 2018 // City of Guelph 3

12 VALUE OF PARKS

13 2.0 VALUE OF THE PARKS AND OPEN SPACE NETWORK 2.1 Quality of Place/Quality of Life The public realm network, and the park spaces that it incorporates, are crucial to the functional attributes of a healthy and desirable urban area. What the research within this chapter broadly indicates is that a diversity of park types, sizes, programming and functions are essential to maximize the potential benefits of a parks and open space network. Many of the studies discussed also correlate positive health outcomes and other social community benefits associated with park use with neighbourhood access and proximity to the parks and open space system. Community Health A large body of recent research has consistently produced findings that correlate access to parks and open spaces with higher levels of physical activity, which can reduce the incidence of certain chronic illnesses associated with a sedentary lifestyle. Kaczynski et al. (2009) surveyed and catalogued physical activity of neighbourhood residents in a midsized Ontario city and found that the number and total area of parks within a 1 km radius of participants homes were significant predictors of physical activity that occurred in neighbourhoods and parks. In his work on Why America Needs More City Parks and Open Space (2003), Sherer similarly found that those who have access to parks exercise more, and that access to places for physical activity combined with informational outreach produced a 48.4% increase in frequency of physical activity. There is a similarly large catalogue of research connecting positive psychological benefits with access to a quality public realm network. Specifically, contact with the natural environment has been shown to improve both physical and psychological health (Sherer, 2003). Positive mental health outcomes are tangibly linked to increased physical activity, which may explain some of the positive psychological benefits of park use. However, it is also true that parks and open spaces are frequently used for passive recreation and relaxation, including walking, reading, meditating and socializing. Nutsford et al. found that higher proportions of surrounding green space in the broader neighbourhood and decreased distance to usable green space, were associated with lower levels of anxiety/ VALUE OF PARKS Exhibition Park, Guelph Credit: Earthscape Background Report - March 2018 // City of Guelph 5

14 VALUE OF PARKS mood disorder treatment (2013). Though the direct cause of these positive psychological impacts are not always clear, the results are well documented. Play is a central component to learning and development in small children, connected to muscle strength, coordination, cognition, and reasoning. As put by Sherer (2003), exercise has been shown to increase the brain s capacity for learning, and as such, creating recreational opportunities for children contributes to both their physical and psychological development. Social Outcomes Park spaces and an active public realm network contribute to healthy and safe neighbourhoods by creating a sense of community, reducing the incidence of crime, promoting physical activity, supporting psychological and social development, and improving environmental indicators. In their report released this year, titled Sparking Change, Park People (2017a) found that by providing an open, accessible venue that promotes social gathering, cultural exchange, and shared storytelling, parks are important in developing a sense of community, safety, and belonging. The report stresses that the community development and social inclusion benefits are especially true in under-served areas of cities that traditionally receive less investment in parks, the public realm, or transit than other areas. It is widely suggested that parks and the public realm are among the likeliest places where diverse groups can come together and learn about their community and the other cultures therein in a safe and open place (Galanakis references several examples in his 2013 paper, Intercultural Public Spaces in Multicultural Toronto). Sherer (2013) adds to this work, reporting that research shows that residents of neighbourhoods with greenery in common spaces are more likely to enjoy stronger social ties than those who live surrounded by barren concrete. Both perceived and real sense of safety contributes to a community s attractiveness and positive functioning, which can be impacted by the incidence of crime. In this regard Sherer (2003) reports that access to public parks and recreational facilities has been strongly linked to reductions in crime and in particular to juvenile delinquency by giving youth a safe environment in which to recreate, interact, and spend time. As such, research supports the widely held belief that community involvement in neighbourhood parks is correlated with lower levels of crime (Sherer, 2003). Parks are not simply green places of respite with grass and trees they are critical pieces of the social infrastructure of our cities. And we believe they have a role to play in creating more inclusive, equitable places that are shaped by and for the people living there. Park People, The Planning Partnership

15 Environmental Health The ecological benefits of parks and vegetated green spaces are well documented, including, surface water treatment and retention, flood mitigation, erosion control, air and water pollutant absorption, and reduction of urban heating effects through shading and cooling. A study looking at the dollar value of trees and shrubs in Allan Gardens in Toronto found that the ecological services equated to approximately $95 per tree per year (Millward & Sabir, 2011). This per tree value varies based on species and age of the trees, however when projected across a city s entire urban forest, the dollar value of healthy trees in parks and green spaces is quickly apparent. Parks also help to ensure that cities are able to withstand extreme weather events, which are occurring with increasing frequency due to climate change. In their report, Resilient Parks, Resilient City, Park People (2017b) discuss the manner in which parks act as critical pieces of stormwater infrastructure by soaking up heavy rainfalls and mitigating potential overloading of engineered stormwater infrastructure. The report describes additional design features, called green infrastructure, that can enhance a park s ecological value. Examples include, daylighted streams, rain gardens, and wetlands that filter pollutants and hold water or channel it to underground tanks. These tools do not need to come at the expense of beautiful, active, and pleasing park designs. Parks and urban green spaces support healthy wildlife populations, which lead to greater biodiversity and subsequently to healthy green spaces. Not only do parks provide much needed spaces for city residents and visitors to recreate, they provide the habitat for urban and migrating wildlife to survive and flourish. A healthy flourishing green space has the power to directly influence the sense of wonder and enjoyment experienced by park visitors. Great Egret Economic Value There has been considerable work done in the United States on measuring the economic value of park spaces in an urban setting. Much of this work has been spearheaded by the California-based Trust for Public Land (TPL). In the 2009 publication by Harnik and Welle, Measuring the Economic Value of a City Park System, an approach was developed that has since been used to assess the value of park space in several US cities, including Los Angeles, Philadelphia, Boston, San Diego and Washington DC. VALUE OF PARKS Sherbourne Common, Toronto The approach taken by TPL was to develop a methodology to quantify economic value Background Report - March 2018 // City of Guelph 7

16 VALUE OF PARKS according to seven distinct perspectives, as summarized in Figure 1, and discussed as follows: Increased property values which looks at the extent to which proximity to a park space adds value to the market and assessed value of residential and commercial properties; Increased tourist expenditure which assesses the number of visitors to a community who spend more time and money in the community than they otherwise would have, because they are participating in activities in parks, or simply enjoying being outdoors; Direct use value which measures the value that users place upon the availability of park spaces (i.e. how much they would be prepared to pay for the opportunity to enjoy parks if they were not freely available); Health value which measures the value of the savings in medical costs to individuals and society-at-large, by virtue of the fact that people who use parks (and the broader public realm) are healthier and less likely to incur medical expenses; Community cohesion value which measures the value to the community overall of participating in parks-related initiatives (i.e. individuals donating their time and/or money and working together on park-related projects), a concept very similar to what Jane Jacobs had identified as social capital in her 1961 work, The Life and Death of Great American Cities. Reduced storm water management costs which examines the value of park spaces in helping reduce runoff during periods of heavy rainfall, and enabling precipitation to filter and recharge groundwater the savings to the municipality in terms of fewer gallons of storm water that require treatment can be directly measured; and, Value of reduced air pollution which examines the effect of trees and vegetation acting as the lungs of the city and removing various toxins from the air, including nitrogen dioxide, sulphur dioxide, carbon monoxide, ozone, and certain particulates. The objective is to assess the extent to which park spaces in a given community have this effect based upon the ambient air quality of the city and then measures the value (cost) of removing these materials from the air through technological means. While this approach does provide a tangible way to quantify economic value, it should be understood that the benefits accrue to different parties in different ways. Overall, the information provided within this chapter provides research regarding the social, public health, environmental health, and economic impacts of a robust and diverse park system. It quickly becomes clear that parks not only aesthetic pieces of a city s urban fabric, but necessary public spaces in order to provide a truly livable, healthy and intriguing environment. Green space seems to be more than just a luxury and consequently the development of green space should be allocated a more central position in spatial planning policy Maas et al., The Planning Partnership

17 Aspect of Economic Value Measured Increased property values Beneficiaries Some Metrics and Examples Individual property-owners Municipalities (through additional taxes) Evidence based upon a large sample of parks shows that location of a residence within 500 ft. of a park will increase market and assessed value by, on average, 5.0% - and for really excellent parks this added value can be as high as 15.0% Increased tourist expenditure Businesses in the community Municipalities (through continuing taxes from businesses supported) Parks in San Diego were found to increase expenditures on the part of out-of-town tourists by $114 million, which resulted in $8.7 million in tax revenue going directly to the City (2007 study) Direct use value Society generally : households who do not need to pay directly for access to parks (although they pay indirectly through taxes) A 2006 study estimated the value of parks in Boston in this regard as being equivalent to $354 million Health value Individuals and higher levels of government, through reduced health care costs In Sacramento, in 2007, a study of the value of health benefits estimated that park participation saved the local health care system just under $20 million VALUE OF PARKS Community cohesion value Society generally and communities: households who do not need to pay directly for access to parks (although they pay indirectly through taxes) A 2006 study of the value of social capital attributable to participation in parksrelated initiatives and projects estimated an economic value of $8.6 million in contributions and volunteer time Reduced storm water management costs Municipalities (through reduced costs for storm water management) Park runoff reduction savings in a 2007 study in Philadelphia estimated savings of $5.9 million to the City Value of reduced air pollution Individuals and higher levels of government, through reduced environmental remediation costs, better health outcomes A 2005 study in Washington estimated the costs of removing pollutants from the air (had not the park system done this for free ) as $19.9 million Figure 1: Multiple Perspectives Approach to Measuring the Economic Value of Park Spaces Background Report - March 2018 // City of Guelph 9

18 PLANNING OVERVIEW

19 3.0 PLANNING OVERVIEW 3.1 The Planning Act Legislative tools within the Planning Act provide municipalities with some tools to acquire parkland through development, much in the same manner as development charges are collected through development to service growth. These tools were originally developed primarily to address lower density subdivision style development and can have broad impacts on the viability of developing higher density residential structures when the maximum permitted parkland dedication is required by municipalities. Though the Planning Act has been updated over the course of its life, the negative financial implication of higher density development is still exacerbated as density increases. The issue is created by the Planning Act formula relating dedication to dwelling units, which does not account for the dramatic range of residents generated by various forms and density of housing. Mitigating measures may include relating parkland dedication rates to the number of people or jobs generated by a given development or reducing the dedication rate from the maximum for higher density developments. These approaches would ensure greater consistency of the parkland per person ratio between higher density and lower density developments and areas of the City. Parkland conveyance authority is established in the Planning Act, Section 42, which pertains to parkland conveyances associated with development and redevelopment, and sections 51.1 and 53, which pertain to parkland requirements as a condition of plan of subdivision approval and consent, respectively. Section 37 of the Planning Act also enables municipalities to acquire certain benefits in exchange for additional density and/or height above the permitted zoning for development and redevelopment (Government of Ontario, 2015). These benefits can include improvements and additions to the public realm and park system, however they also include a myriad of other potential benefits that are determined by the municipality at the time of development. It should be noted that these benefits are difficult to plan for as the increase in density and/or height can only be initiated by the developer; as such section 37 contributions cannot be relied upon to consistently plan for the parks system and sections 42, 51.1 and 53 are the focus of this project. PLANNING OVERVIEW In late 2016, a number of amendments to the Planning Act were implemented that impact the parkland conveyance policies. These updates are included in the description of the Planning Act policies below, and are discussed in greater detail in subsequent chapters of this report. Summit Ridge Park, Guelph The Planning Act establishes the following provisions for parkland conveyances: Background Report - March 2018 // City of Guelph 11

20 PLANNING OVERVIEW Land Conveyance The Planning Act establishes parameters for conveyances for park or other recreational purposes, as follows: Not exceeding 2% of land area in the case of commercial or industrial development. Not exceeding 5% of land area in the case of all other types of development. For residential purposes, the Act permits municipalities to utilize an alternative rate of conveyance for park or other public recreational purposes based on a maximum rate of 1 hectare for every 300 dwelling units, subject to enabling policies within the approved local Official Plan. These three separate conveyance rates are identified as the maximum rate for each scenario within the Planning Act. Payment-in-Lieu and Land Valuation Municipalities may also accept payment-inlieu of parkland conveyance. This payment can be made in the form cash or other reasonable alternative as the municipality deems appropriate; in either case the payment must represent the value of the land that would otherwise have been conveyed. The Planning Act policies that establish parameters for payment-in-lieu and land valuation are: If the alternative requirement for residential development is used (1 ha/300 units), when the municipality accepts payment-inlieu of land a maximum rate of 1 hectare for each 500 units will instead be used. All cash accepted as payment-in-lieu must be deposited into a special account and used only for the acquisition of land to be used for park or other recreational purposes, including the erection, improvement or repair of building and the acquisition of machinery for park or other public recreational purposes. Regarding land development and redevelopment, payment is to be determined based on the value of the land as of the day before the issuance of the first building permit. Regarding subdivision development and consents, respectively, payment is to be determined based on the value of the land as of the day before the approval of the draft plan of subdivision or provisional consent, as the case may be. Reductions for Sustainability As per section 42 (6.2 and 6.3), a municipality may establish policies to permit a reduction in payment-in-lieu where a redevelopment project meets certain sustainability criteria as set out in the Official Plan and where no land is available to be conveyed for park or other public recreational purposes. This is a relatively new provision under the Planning Act and based on a scan of other municipalities, it is yet to be tested or implemented. Implementation of Conveyance Policies Historically, the Planning Act provided some inherent flexibility in the way municipalities implement conveyance policies, primarily by what the Act remained silent on. With recent amendments to the Act, however, municipalities are now required to justify conveyance policies if the alternative requirement for residential conveyance is implemented. The following are relevant policies and notes regarding implementation: 12 The Planning Partnership

21 The Act does not prescribe which method (or rate up to the maximum) is to be applied in any situation. The Act does not indicate if, where or when the municipality may require less than the maximums identified in either approach. The Act now specifies that prior to a municipality implementing official plan policies to implement the alternative requirement (rate) for residential development, the municipality must produce a parks plan that examines the need for parkland in the municipality. This requirement does not apply to official plan policies that were approved prior to the effective date of the Planning Act amendment (December 2015). The Act now also specifies that municipalities must submit, yearly, a financial statement detailing the deposits and expenditures of the special paymentin-lieu fund. This provides additional municipal accountability in accounting and expenditure of these monies appropriately. 3.2 City of Guelph Official Plan The City of Guelph adopted Official Plan Amendment 48 - Five-year Review (Official Plan) in 2012, which substantially updated the City s parks and open space policies. The Official Plan has recently been approved by the Ontario Municipal Board and is now in effect with site specific exceptions. Section 7.3 of the Official Plan establishes the policy framework with respect to the City s Open Space System: Trails and Parks. Provision targets for parkland by park type are established, as follows: Neighbourhood Parks: 0.7 hectares per 1,000 people Community Parks: 1.3 hectares per 1,000 people Regional Parks: 1.3 hectares per 1,000 people It is important to note that the total amount of parkland required as identified in the Official Plan is 3.3 hectares per 1,000 residents. However, the City limits themselves, as does the Planning Act, to a maximum of 1 hectare per 300 dwelling units or approximately 1 hectare per 1,000 residents, plus the contribution to the parkland supply from non-residential developments. Urban Squares are also identified within the Park Hierarchy to address passive recreation needs within intensification areas of the city. There is no provision target for Urban Squares and are thus not included in the park targets. For residential development, the Official Plan establishes that either 5% of the land area for development or the alternative rate of 1 hectare for each 300 dwelling units are to be used. There is no further policy that indicates when or where each rate should apply, however policy does describe that Council may pass and update a bylaw that outlines the rates of parkland dedication, enabling the City to establish alternative rates below the maximums or to more clearly delineate scenarios where specific rates are appropriate, in accordance with Planning Act provisions. The Official Plan also establishes the Planning Act rates for all other development types, including 2% of the land area for commercial and industrial and 5% of the land area for PLANNING OVERVIEW Background Report - March 2018 // City of Guelph 13

22 PLANNING OVERVIEW all other land types. Rates for mixed-use development are not established. Finally, the Official Plan establishes policy that prohibits urban squares and parks held in private ownership, as well as natural heritage features and natural hazard lands, from being accepted as parkland dedication by the City. Policies also provide guidance on physical condition and eligibility criteria for parkland conveyance, and on the acceptance and use of payment-in-lieu monies. Of note, the Official Plan does not currently recognize the recent Planning Act amendment that capped the maximum payment-in-lieu conveyance when the alternative rate is employed to 1 hectare for every 500 dwelling units developed. This cap to payment-in-lieu is not required within an official plan and can be established in the implementing bylaw. 3.3 Parkland Dedication Practices In-Force Bylaws Enabled by the Planning Act and the City s Official Plan, the City has three in-force parkland conveyance bylaws (By-Laws , , and ) that authorize the City to obtain land for parks through development. The two key bylaws that establish conveyance authority were passed in 1989 and 1990 (the 2007 bylaw was limited and only removed a provision to charge a conversion to a group home or lodging house). Given the age of these bylaws, there are a number of inconsistencies with both the Official Plan policies and with modern parkland planning principles. For residential development, the bylaws establish the following conveyance rates: 5% of the land area for any residential development within the Downtown area. 5% of the land area for all residential development with densities under 50 units/ hectare. 7.5% of the land area for residential development with densities between 50 and 100 units/hectare. 10% of the land area for residential development with densities greater than 100 units/hectare. When payment-in-lieu is required, the bylaws establish residential land values as follows: single and semi-detached units based on zoning designation: R.1A = $1,800/dwelling unit R.1B = $1,500/dwelling unit R.1C = $1,200/dwelling unit R.1D = $1,125/dwelling unit R.2 = $1,125/dwelling unit $1,000/unit for each additional unit in developments with 5 units or less. and determined by a qualified real estate appraiser in all other cases. A number of missed opportunities are present in the current bylaws regarding residential parkland conveyance, including, not employing alternative conveyance rates, outdated land values for payment-inlieu conveyance, and capped conveyance rates for the Downtown and higher density developments. Combined, these factors represent substantial opportunities to collect parkland through residential development that the City is entitled to. 14 The Planning Partnership

23 For commercial and industrial development, the bylaws establish a conveyance rate of 2% of the land area, but only if one or more of the following criteria apply: development lands include river bank lands that are designated for park use in the Recreation, Parks and Culture Plan or the Official Plan; a portion of the land is required to provide access to a park or recreation facility; and/or a portion of the land is required to complete the development of a park or recreation facility. The criteria required for commercial and industrial conveyance render much of the development of this type within the City ineligible for parkland conveyance, and in a sense it could be judged that the City is missing out on the opportunity to acquire parkland. Generally, it is well understood by the City of Guelph that the in-force bylaws are outdated, in need of amendment, and not in accordance with the latest updates established in the Official Plan. These realities are the basis for the update and review of Guelph s parks and open space policies and bylaws. Payment-in-Lieu Policies Presently, the City operates two separate payment-in-lieu accounts, a downtown fund and a general fund for the rest of the city. The downtown fund can only collect and spend funds within the boundaries of the Downtown Secondary Plan. These funds currently hold a small balance, largely due to the difficulties in enforcing parkland conveyance policies throughout the city and the existing caps in the Downtown area. Funds are currently used on a generally asneeded basis as the City currently lacks a cohesive policy or protocol for the use of payment-in-lieu funds. When these monies are used, they are typically used for parkland purchases and are on occasion used for capital expenditures, including the maintenance of recreational structures and machinery. City staff recognize that in the absence of protocols for spending payment-in-lieu monies, the collected conveyance is not being used to its maximum potential. Once monies are collected, the economic uplift of the money that sits unused in the account is outpaced by land value appreciation, leading to the City chasing land values and often missing out on opportunities to add parkland to the system. There is very little land remaining in the municipality to purchase and redevelop as parkland, particularly of the same size and type that Guelph has historically been accustomed to. This reality increases the imperative for the City to develop a targeted strategy to utilize payment-in-lieu funds in a planned and effective manner. 3.4 Area Specific Parkland Policy The City currently has three area specific Secondary Plans in-force or in development: the Downtown, the Guelph Innovation District, and Clair-Maltby. Within Secondary Plans municipalities typically delineate the general location of new parkland, the quantity of parkland, and may describe how the parkland is to be acquired. The Clair-Matlby Secondary Plan is still in development and is not available for review at this time. As such, only the Downtown Secondary Plan and the PLANNING OVERVIEW Background Report - March 2018 // City of Guelph 15

24 City of Guelph Secondary Plan Areas Downtown PLANNING OVERVIEW Guelph Innovation District Clair-Maltby Figure 2: Guelph s Secondary Plan Areas 16 The Planning Partnership

25 Guelph Innovation District Secondary Plan are discussed in this section. Figure 2 shows the location of the three Secondary Plan areas in the city. Downtown Secondary Plan As Guelph continues to grow and meet its designated growth targets, particularly intensification targets, downtown residential and mixed use development become imperative. In order to plan for this growth the City developed a new Downtown Secondary Plan in As part of this plan, the City identified a number of future park spaces, as well as mid block pedestrian mews and future urban squares that will add to the existing downtown open space system. The future parks primarily straddle the Speed River and connect existing riverfront parks and trails, fulfilling one of the Secondary Plan guiding principles to Reconnect with the River. To develop these parks, the City has established that within the Downtown, a minimum ratio of public open space of one hectare for every 1,000 residents will be maintained, which will be dedicated or acquired through the provisions of the Official Plan. PLANNING OVERVIEW Downtown Secondary Plan, Guelph Background Report - March 2018 // City of Guelph 17

26 TRENDS IN PARKLAND POLICY

27 4.0 TRENDS AFFECTING PARKS & RECREATION PLANNING 4.1 Trends in Planning & Policy General Policies Municipalities recognize that parks are being used differently by different groups of people. This is a positive trend on its own, but the development of policies, programs and services will need to be more flexible as parks will need to evolve with changing trends. There is a need to embrace unprogrammed space that can be used without a field permit. Policies and regulations can be slow to respond to public desires and more flexible and fluid spaces that can be programmed by the community are a thoughtful response. Bill 73 The Ontario Ministry of Municipal Affairs and Housing drafted the Smart Growth for Our Communities Act (Bill 73) in early It proposed a number of amendments to Ontario s Planning Act and Development Charges Act in order to address concerns from both the public and private sectors regarding the ever-changing and complex landscape of land use planning and development in Ontario. Bill 73 received Royal Assent in December of 2015 and consequently the Development Charges Act and the Planning Act were amended in January and July of 2016, respectively. The amendments mandated by Bill 73, in the words of the Province, intend to: Increase municipalities capacity to fund growth; Provide more opportunities for residents to engage; Protect and promote greenspaces; Increase transparency and accountability in the development charges system; Make the planning and appeals process, and the development charges system more predictable; and Provide municipalities with greater independence and latitude. Issues with Parkland Policies A number of concerns are typically raised by the development community and land use lawyers in the GTA regarding parkland dedication policies as they relate to highdensity developments. The arguments can be summarized as follows: When utilizing the alternative rate of 1 hectare per 300 dwelling units (or less) there are instances where the resultant land and/or payment-in-lieu equals or exceeds that of the total land area and/ or total cost of the land being developed itself. Accordingly, this represents a severe disincentive to develop high density infill and is in opposition to provincial planning policies that mandate higher density developments. Figure 3 describes the development scenarios for a 1 hectare parcel of land that can give rise to this issue (Gillezeau, 2015). The Ontario Home Builders Association ( OHBA ) echoes this concern, stating that the alternative parkland dedication rate, specifically as it applies to payment-in-lieu of land, are negatively impacting housing affordability and contradicting provincial policy to support intensification. They also raise concerns about the accountability and transparency of municipal expenditures of monies collected in-lieu of land, indicating that much of the funds collected to purchase and improve parkland have not been spent (OHBA, 2015). A persistent issue with the alternative dedication rate, and more specifically the payment-in-lieu requirement at the alternative rate, is the use of land TRENDS & DEMOGRAPHICS Background Report - March 2018 // City of Guelph 19

28 TRENDS & DEMOGRAPHICS valuation of the development site as a key determinant in the amount of paymentin-lieu required. This is due to the value of land being directly proportional to the maximum density potential of the land. The argument is that the dedication rate being fixed to the land, specifically in high density areas, creates untenable scenarios for both developers and municipalities; developers incur parkland dedication costs that can be substantially greater than any other cost inputs, and municipalities are priced out of land purchases in the same areas in order to develop parks (Kussner, 2015). Single detached residential at 5% dedication rate 500 m 2 of parkland required Medium Density with 60 units at 1ha/300 unit rate 2,000 m 2 of parkland required High Density with 300 units at 1ha/300 unit rate Changes to Parkland Dedication Policies The Planning Act amendments to parkland dedication policies mandated under Bill 73 will have a significant impact on both municipalities and property developers. It appears that some of the concerns of the development community and land use lawyers have been taken into account. Significant changes to parkland dedication policies are summarized below: Prior to adopting alternative parkland dedication rates, the municipality shall prepare and make publicly available a parks plan that examines the need for parks. In preparing the parks plan, the municipality must consult with every school board that has jurisdiction in the municipality, and may consult with any others at the discretion of the municipality. This requirement only applies to official plans that were not in force prior to the effective date of the Planning Act amendment (December 2015). The maximum payment-in-lieu of parkland that a municipality can require when an alternative dedication policy applies is 1 hectare per 500 units. The municipality can still apply a lesser rate. The municipal Treasurer is required to provide council with annual financial statement related to payment-in-lieu of parkland monies that are available for public use, including transactions using these monies throughout the previous year. 10,000 m 2 of parkland required (total site area) Figure 3: Parkland Dedication Scenarios for 1 Hectare Site 1. Parks plan prior to adopting alternative dedication rates According to the Province, this change intends to better position municipalities to plan for parks to meet community needs and be prepared to purchase parkland when 20 The Planning Partnership

29 opportunities arise. The change is likely to impose initial costs to municipalities in the development of parks plans, however may yield long-term savings due to identifying targeted lands for purchase in advance, as opposed to a reactionary approach to land purchasing. The parks plans will help bring clarity and transparency to the municipal parks planning process while providing additional opportunities for School Boards and the public to impact the process. 2. Payment-in-lieu alternative rate capped at 1 hectare per 500 units This change was made to incent the acquisition of land for parks rather than collecting payment-in-lieu, which would provide parkland more quickly and address current needs for park provision in communities. The result of the amendment is that municipalities have less latitude to select a payment-in-lieu rate that they deem suitable to achieve their parks planning objectives and the overall amount of money that can be received through higher density developments for future parkland purchases by the municipality is reduced. Municipalities are in opposition to this change as it creates an arbitrary cap reducing parkland dedication payment-in-lieu that is not tied to local parkland needs and objectives, and that often taking land in higher-density areas results in smaller disjointed parks. The concern is that this cap may reduce the capacity of municipalities to adequately plan for and provide parkland in their communities, as well as incentivizes property developers to push for payment-in-lieu as opposed to dedicating land (Association of Municipalities of Ontario, 2016). 3. Special parkland fund financial reporting The additional financial reporting intends to increase transparency and accountability regarding the collection and use of parkland monies. This will result in some additional administrative and financial costs incurred by municipalities and provides additional opportunity for council, the public, and the private sector to review parkland account finances and expenditures. TRENDS & DEMOGRAPHICS Guelph Downtown Background Report - March 2018 // City of Guelph 21

30 4.2 Urbanization and Intensification TRENDS & DEMOGRAPHICS Urbanization Canadian cities continue to grow, with the vast majority of the population already living in cities, and new Canadians typically settling in urban areas. In Ontario, approximately 86% of all people live within population centres (urban areas of at least 1,000 people) and this number has been consistently increasing (Statistics Canada, 2017). Guelph s population has grown by 8.3% since 2011, or 1.7% annually (Statistics Canada, 2017). This growth continues to create a demand for access to parks and natural settings in urban areas that are increasingly difficult to acquire due to high land value and low availability in intensification areas. Growing densities and the movement toward complete communities will continue to increase the demand for a connected parks system of various park types and sizes to accommodate a range of recreational interests. Intensification A direct result of increasing urban populations and provincial growth policies is higher density urban development. This reality is borne out in Guelph s recent growth statistics, where the proportion of apartments and townhouses being constructed compared to single and semi-detached dwellings, since 2013, has been higher than any other time in Guelph s history. The highest rate was in 2015, with 67.5% of all building permits being apartment and townhouse units (City of Guelph, 2016). A more balanced city-wide housing stock is developing, with approximately 45.5% of housing in 2016 being apartment and townhouse units, an increase of 6.5% since 2006 (Statistics Canada, 2017). This trend is also reflected in the number of development permits issued in Guelph based on Growth Plan Area; Greenfield versus Builtup area (infill) development. Since 2012, the balance has flipped from predominantly Figure 4: Residential Permits by Growth Plan Area (City of Guelph, 2016) 22 The Planning Partnership

31 greenfield area permits to predominantly infill permits. The latest Growth Plan requires a minimum of 50% of all development occur within built-up areas until 2031, and 60% beyond Guelph appears to be on pace to meet and exceed these targets, meaning that denser development forms will continue well into the future and new approaches for acquiring, developing and designing public parks in this modern era of urban development are required. Figure 4 describes these trend. There is a rapidly dwindling supply of greenfield areas within Guelph s boundaries. As of the end of 2015, 756 of the remaining 2020 hectares of designated greenfield area have been committed, representing approximately 37%. In 2015, the density within Guelph s committed greenfield lands was approximately 52 people and jobs per hectare, exceeding the previous Growth Plan minimum target of 50. However as previously described, the new Growth Plan targets for greenfield areas is 80 people and jobs per hectare, requiring a much denser built form than is currently being achieved. This provides further impetus for the City to ensure that parks are adequately provided for, both in quantity and design, to accommodate this drastically different development reality moving forward. TRENDS & DEMOGRAPHICS These new urban realities are perhaps even more apparent in Guelph s Downtown, where the Growth Plan sets a minimum density target of 150 people and jobs per hectare, and presently, the Downtown is estimated to have a density of approximately 96 people and jobs per hectare. Infill density will largely be focused on the Downtown area in the coming years. Background Report - March 2018 // City of Guelph 23

32 BENCHMARKING

33 5.0 POLICY AND PARKLAND BENCHMARKING 5.1 Municipal Policy Comparison The following is a summary and discussion of the key findings from a review of parkland dedication policies and practices from other municipalities in Southern Ontario. This includes desktop research focused on the existing parkland dedication policies and bylaws of each municipality, as well as follow-up interviews with each municipality to gain a clearer understanding of how the policies and bylaws work in practice. In total, 11 municipalities were identified by the City of Guelph and the consultant team for this exercise, including: Barrie, Cambridge, Hamilton, Kitchener, London, Markham, Mississauga, Oakville, Richmond Hill, Vaughan and Waterloo. The City of Toronto was not included as one of the comparator municipalities for this exercise, however the desktop research provides a summary of Toronto s parkland dedication policies for additional information. This chapter discusses common themes and trends observed through discussions with municipal representatives and the comparison of policies and bylaws. The full municipal policy comparison table and interview summaries are included in Appendix A. The quality and depth of the interviews varied based on a number of factors, including the depth of knowledge of the municipal contact, willingness to share information, availability of respondents, and level of participation. Municipalities Facing Similar Realities Urbanization and intensification Southern Ontario continues to experience a tremendous growth spurt with the majority of population increases located within our urban environments. This urbanization is being planned for by the province through Growth Plan intensification policies that municipalities are required to implement. These trends have substantial impacts on land values and the capacity of local government to acquire and develop the requisite social and public spaces that will serve existing and future residents. Representatives from nearly every municipality recognized these complexities and noted that parkland acquisition (whether through land dedication or purchasing land through cash dedications) is very difficult in municipal areas that are largely already built out, particularly in intensification areas and downtown cores. BENCHMARKING This review provides valuable information regarding similar and dissimilar issues facing a number of Southern Ontario s municipalities with regard to parkland dedication. A number of lessons can be gleaned from the work of others, and the information presented herein will contribute to the development of Guelph s new parkland acquisition practices and bylaw. Intensification in Toronto Background Report - March 2018 // City of Guelph 25

34 BENCHMARKING Some municipalities are beginning to consider alternative land acquisition tools and park types to adapt to these new urban realities. Stratified title parkland (strata), Privately- Owned Pubic Spaces (POPS), credits for public realm improvements, and dedication credits for natural heritage and encumbered lands are all being contemplated. It is becoming clear that as municipalities in Southern Ontario evolve and greenfield land becomes increasingly scarce, parks planning for infill and intensification requires new tools, and non-traditional park spaces will play an increasingly important role in public open space and recreation systems. Updates to parkland dedication policies & bylaws In response to the ongoing Richmond Hill OMB hearing related to parkland acquisition, as well as the recent Planning Act updates, most municipalities are actively studying and updating their parkland policies and bylaws. Eight of the eleven municipalities noted that they have either very recently updated, or are in the process of reviewing and updating their acquisition policies and bylaws, as well as undertaking requisite park master plan studies to fulfill Planning Act requirements for employing alternative dedication rates within their bylaws. many municipalities is that very few greenfield opportunities remain. Traditional residential development patterns were dictated by large subdivision developments that enabled municipalities to acquire large planned park spaces through land dedications. This is seldom the reality today, where much of the planned development is required to be through intensification, and thus land at an affordable rate and desired size is hard to come by. Regarding the administration of parkland dedication for subdivisions, the majority of municipal respondents identified that subdivisions were included within their bylaws. The Planning Act does not specifically require that a by-law be passed in order for a municipality to require dedication of parkland or payment-in-lieu as a condition to the approval of plan of subdivision or consent. It was apparent through conversations with other municipalities that this topic was not well understood, was not a topic of concern, or that they have not experienced any issues in enforcing parkland dedication for subdivisions. Municipalities also have unique parkland concerns and interests that are being addressed in these updates and will be discussed in greater detail in this chapter. Subdivisions Respondents unanimously agreed that through plans of subdivision, the acquisition of land (as opposed to payment-in-lieu) is the primary goal. However, a key theme for Image Credit: Hapa Collaborative Market Lane, London 26 The Planning Partnership

35 Land Dedication When/where is land preferred? The common response to when land is preferred was as part of subdivisions and wherever secondary plans have determined the need. However, as previously discussed, some common trends influence the acquisition of land, including the small supply of remaining greenfield areas combined with mandated intensification targets and rising property values. The result is expensive land in downtowns and intensification areas where infill targets are scheduled to be accommodated, where sites are smaller than traditional low density developments, where developers are reluctant/unwilling to provide on-site space, and municipalities similarly don t always want to assume ownership of small public parks. Subsequently, land is primarily only being taken in new subdivisions, and there are much fewer subdivisions being developed. This common trend has resulted in the majority of non-subdivision development being charged payment-in-lieu and municipalities left chasing rising property values within the same neighbourhoods to purchase land for parks. As a response, municipalities are beginning to re-calibrate what constitutes a valuable public space/park and are viewing smaller urban parks and squares as a useful and necessary response to intensification. Vaughan described that small urban spaces will be taken for parkland dedication when the City deems the space valuable or high priority. Mississauga similarly indicated that they are beginning to acquire and build smaller parkettes and urban parks and that City Council, staff and the public are beginning to see the value of these smaller spaces. Markham and Vaughan are both receiving requests from developers to accept parks located above private infrastructure (typically parking garages at grade), known as strata parks, and are actively studying how to credit and manage these spaces. Some municipalities showed an interest in taking land off-site if it were available and within a reasonable distance (Mississauga), whereas others described that this process would be overly complicated within an already complicated issue (Kitchener). No municipalities reported that a land bank or land trades were used as part of a parkland acquisition strategy, citing either Planning Act language that land acquired through parkland dedication has to be used for parks only, or that administratively these tools would be very difficult to manage. What criteria should land meet? When land is conveyed, municipalities require certain conditions to be met, and respondents almost unanimously require tableland graded between 2% and 5%, unencumbered and programmable. These requirements are in-line with the type of land that can be expected from low-density development and subdivisions, however may require revision should municipalities begin to acquire more land in denser urban environments. Traditionally, many municipalities only accepted land greater than 2 acres (0.8 hectares), however all of Barrie, London, Markham, Mississauga, and Vaughan reported that they accept lands (or plan to) as small as 0.2 to 0.3 hectares in size, in accordance with Official Plan policies for smaller urban spaces. BENCHMARKING Background Report - March 2018 // City of Guelph 27

36 BENCHMARKING Other suitable lands for dedication Environmentally Sensitive Areas, hazard lands, buffer lands, surface water infrastructure, woodlots and wetlands are all commonly dedicated gratuitously to municipalities by developers as part of the development process. This is in recognition that these lands have little to no development potential to the landowner, whereas they are important environmental features and potentially valuable public recreation resources for the municipality. Questions are being asked by developers in some municipalities about whether the recreational value of these lands (particularly those with trails) should be eligible for a parkland dedication credit. While the vast majority of municipalities reported that they do not, and will not consider credits for these lands in any circumstance, some reported that under specific scenarios and if the encumbered lands were of significant value to the public realm, they would negotiate with the developer to acquire the land and provide a dedication credit. An example of this is in Oakville, where the Town and landowners/developers north of Dundas Street worked out an agreement for the Town to acquire 900 hectares of Natural Heritage Area in exchange for a capped parkland dedication of 64.5 hectares for all future development in the area. The administrative ease that this scenario provided combined with the environmental and recreational value of this large section of land in exchange for a lower potential traditional parkland quantity was seen as a worthwhile trade to the Town. London has taken the conversation a step further by quantifying credits for hazard lands and other open space or constrained lands (e.g. woodlots or wetlands) throughout the municipality. As per their bylaw, the City will credit dedicated hazard lands at a ratio of 27 hectares for every 1 hectare of table land required, and will credit open space lands at a ratio of 16 hectares for every 1 hectare of table land required. Guelph Radial Line Trail 28 The Planning Partnership

37 Conversely, Richmond Hill is inflexible when it comes to parkland dedication credits for trails and environmental lands. The Town took a position in a previous OMB hearing that these lands are unsuitable for parkland dedication, which they won. Given the ruling and the position taken by the Town, they do not spend payment-in-lieu monies on trail or recreation within environmental lands as it would be hypocritical to do so. The Town recognizes that trails are an important resource and recreational activity for its residents, however has consciously chosen to focus its parkland dedication resources on obtaining larger recreation facilities and fields, which they have identified as a local need. Each municipality has unique interests and existing resources at their disposal. Some, like Guelph, are blessed with substantial environmental features and trail networks, others exist in more urban settings and have acquired and designed more high quality parkettes and urban squares. Parkland dedication policies vary to suit the needs of the municipality and can be used flexibly to obtain the types of spaces that are highly valued. Strata parks and privately owned public spaces Strata parkland and POPS are alternative parkland acquisition tools that are typically suited to higher density developments and mixed-use areas. Strata parks are publiclyowned parks located above privately-owned infrastructure (typically a below-grade parking structure). This tool enables the municipality to own and program the park, while the developer is able utilize and maximize the space below ground. POPS are privately owned parks that are publicly accessible through agreements with the land owner/ developer. They can also be located above below-grade infrastructure, much in the same way as strata parks, however there is a single owner in a POPS scenario. While the ownership models of these spaces vary and each has its own inherent opportunities and issues, the result is similar; highly designed urban parks located on-site. These parkland types will be discussed further in the following chapter. BENCHMARKING Village of Yorkville Park, Toronto Background Report - March 2018 // City of Guelph 29

38 BENCHMARKING The majority of municipalities in this study have not yet experienced pressure from developers to consider strata parks. Only Markham and Vaughan have, to-date, provided credits to developers for strata parks, however they have done so on an ad hoc basis and do not have specific policies in-place to determine appropriate credits. Vaughan has previously provided a credit of 1/3 of the strata park area and is considering policies to implement this strategy based on the actual ownership model of the land (1/3 credit for below ground, 1/3 for at-grade, and 1/3 for air rights). Markham has negotiated on a case-by-base basis with each developer and has provided up to 100% credit for the strata parkland. Both municipalities report that a more cohesive and transparent strategy is required. Similarly, Oakville, Richmond Hill and Mississauga all recognize that strata parks are a new urban reality where parkland is required in high density and apartment developments. Oakville is actively planning for strata parkland development and has engaged with other municipalities (Markham and Vaughan) to begin studying implementation and policy mechanisms. Mississauga also noted that they are studying how to respond to strata requests. It is apparent that strata parks are only being discussed and planned in municipalities that are experiencing a particular type of development scenario; high density development that requires underground parking, where development sites are not large enough to dedicate a portion of land for an unencumbered table land park. Strata parks can be useful tools in this scenario, particularly where a municipality has determined that obtaining publicly owned urban parkland onsite is a high priority. POPS are more common than strata parks across the municipalities in this study. They are generally seen as a good deal for municipalities as the park augments the existing park system at no cost to the municipality; the park is held within private ownership, maintained privately, and all risk and liability lie with the property owner. POPS are typically developed through section 37 bonusing agreements or informally by developers. Only Kitchener and Oakville noted that a parkland dedication credit had been provided for the development of a POPS, however neither have a standard policy to credit POPS. Richmond Hill noted that, though they have not provided credits for POPS to-date, some credit may be appropriate for POPS if they are not developed through section 37 (however not at 100%). Kitchener noted that fiscal transparency with parkland funds is important, and that they would prefer to pursue a normal parkland dedication and then pay the developer to construct a POPS or for a lease/easement for public access to the POPS through payment-in-lieu funds. Strata parks and POPS are site and scenario specific tools that can provide a benefit to all stakeholders. They are tools that are likely only considered appropriate when land for parks is needed in intensifying areas and where available land is scarce or unaffordable for municipalities to purchase. In no circumstance would these spaces become the standard for all types of city parkland, however they may serve a particular need for smaller and diverse urban public spaces. Strata parks and POPS are part of an evolving conversation regarding the provision of public space in rapidly urbanizing environments. Additional examples of this evolution were provided by Vaughan who is studying the potential for indoor public park spaces, and by Barrie who has previously 30 The Planning Partnership

39 leased vacant land in strategic locations for temporary parks. At this time, Guelph s Official Plan does not consider privately held property (including POPS), however strata parks are not specifically identified as either appropriate or inappropriate. areas, municipalities competing on the open market for increasingly expensive land (and often being priced out), and increasing use of payment-in-lieu monies for park infrastructure upgrades as opposed to new land, as it is easier to plan for these types of expenditures as a municipality. Payment-in-Lieu of Land Dedication When/where is payment-in-lieu preferred? As discussed in the previous section, paymentin-lieu of land is taken for most infill and intensification projects, as well as for small modifications and redevelopment of existing uses. This is largely driven by a number of factors, including: infill and intensification development sites are not large enough to provide a traditional park through dedication, land dedications of individual development sites can create fragmented parks systems, urban squares and parks are more expensive for municipalities to operate and maintain, rising land values leading to developers maximizing the use of the site, and Planning Act policies that encourage developers to push for payment-in-lieu dedications (including the new 1 hectare/500 units payment-in-lieu policy). Given the Growth Plan requirements that 40% of all municipal growth will be achieved through intensification (rising to 50% at time of next municipal comprehensive review and 60% in 2031), and that there is a shrinking supply of greenfield land in general, there is every indication that payment-in-lieu of parkland will become the primary mechanism for parkland dedication in many of Southern Ontario s municipalities. This has resulted in a number of observed trends, namely: the lack of immediately available park space in rapidly intensifying Payment-in-lieu accounting and spending Recent Planning Act changes require more detailed accounting of payment-in-lieu funds received and spent. However municipalities have latitude to determine whether a single fund covering the entire municipality or multiple funds for specific areas are appropriate. Nearly all municipalities reported that a single payment-in-lieu fund was operated for their jurisdiction, meaning that monies collected anywhere can be spent anywhere within the municipality. Waterloo was the only municipality that operates multiple funds; one fund for a Community Improvement Plan area and one for the remainder of the city. Single funds are administratively efficient, although a number of respondents said that a more comprehensive strategy for paymentin-lieu expenditure is required. Vaughan also reported that developers are beginning to push back against a single fund, as the development that was required to dedicate payment-in-lieu may not be receiving the benefit of the dedication. In other words, parkland dedication resources can theoretically be collected at one end of a municipality and spent at the other end, not directly benefitting the residents of the original development. In absence of a clear parks strategy from municipalities, it is reasonable to expect that these concerns will continue to grow within the development community. BENCHMARKING Background Report - March 2018 // City of Guelph 31

40 BENCHMARKING When it comes to spending the funds, the Planning Act is less definitive, stating that payment-in-lieu monies can be spent only for the acquisition of land to be used for park or other public recreation purposes, including the erection, improvement or repair of buildings and the acquisition of machinery for park or other public recreational purposes. Municipalities have variously interpreted this wording, with the majority reporting that monies are used for both land acquisition and for infrastructure improvements (machinery, park renewal, recreation centres, trails, boardwalks). Only Hamilton, London and Vaughan reported that payment-in-lieu funds were used for land purchase only. Mississauga has an informal procedure where they spend 60% on land and 40% for constructing new recreation facilities. However they admit that the numbers are likely reversed as land acquisition opportunities are more difficult to plan whereas capital improvements on existing assets are more straightforward and easily accounted for in budgets. Standard unit rates versus individual appraisals When a municipality determines that paymentin-lieu will be required, the Planning Act requires that the value of that payment be equivalent to the value of the land that is otherwise required to be conveyed and the determination of the value is to be based on market rates as of the day before the issuance of the building permit or the day before the approval of the draft plan of subdivision. The question remaining is whether a municipality prefers to require new appraisals for every development and plan of subdivision or whether standard unit rates are used for the development type to determine the overall value of cash dedication required. Five of the municipalities identified that they require site-specific appraisals for all types of development. Of the five, Hamilton is planning to move away from this method, toward standard unit rates based on development type and location. Reasons cited for using sitespecific appraisals include: fluctuations in land values resulting in inaccuracies in established standard unit rates, the municipality is not maximizing their payment-in-lieu dedication with this method, and developers will appeal/ provide evidence for lower land values if the standard rate overvalues land, whereas higher value land can be undervalued by standard unit rates. Vaughan and Mississauga employ standard rates for higher density developments only, however Mississauga intends to move away from this approach toward new appraisals for all development types. Richmond Hill applies standard unit rates (or expected land conversion rate) for all development types except high density, for which they perform an in-house appraisal and then negotiate with the developer. Barrie employs standard unit rates for residential units based on development density after recently repealing their bylaw that prescribed $8,000/dwelling unit for the entire City regardless of development type or density. London also employs standard unit rates for residential dwellings based on unit types/ density. Kitchener was the only respondent that uses standard unit rates for all development types, including residential, commercial, industrial, and institutional. Kitchener is also updating their bylaw and intends to implement a Downtown Core land value average to address concerns of lost revenue due to current city-wide standard rates. The major reasons cited for the use of standard unit rates as opposed to site-specific appraisals at time 32 The Planning Partnership

41 of development are administrative ease for the municipality, and certainty for the developer. A key consideration in the use of standard unit rates is updating the rates to reflect market fluctuations in land value. In this regard, there is no universally correct frequency for updates, and the timing is likely set to reflect the fluidity of local land markets. Barrie proposes to conduct new appraisals every five years in association with development charges updates. Hamilton discussed indexing the land value once or twice a year and performing a full update every three years should they move to a standard rate approach. London conducts appraisals every two years, and are just now performing their first update to market values since inception of the original unit rates in An important distinction should be made between a fixed fee that does not consider residential development type or density and a standard unit rate that does. A fixed fee would dictate, for example, that an apartment unit should pay the same parkland dedication rate as a detached dwelling, which disregards the Planning Act requirement to perform an appraisal on the land at the market rate of that land. A standard unit rate approach respects the Planning Act requirements by performing appraisals that reflect the true value of the land by establishing market rates for various residential dwelling unit types, and updates these rates to reflect true market land values at a determined frequency. It is also important to note that any land appraisal value can be contested by the developer and brought to hearing at the OMB. time, municipalities have planned for their changing market contexts and updated policies to accommodate new goals and requirements. What forms of private sector capital improvements are acceptable as payment-in-lieu? The recent section 42 changes in the Planning Act recognize that payment-in-lieu of parkland does not necessarily mean payment of cash. The wording of the updated policy states the council may require a payment in lieu, to the value of the land otherwise required to be conveyed. The previous policy specifically stated the payment of money. This is recognition that municipalities have the flexibility to negotiate and acquire other forms of park or public recreation payment that they individually deem as valuable. A few municipalities reported that they have provided credits or reductions to cash payments in exchange for other forms of payment. Barrie provides parkland dedication credit for the development of associated/ supportive infrastructure for trails and other recreation facilities, such as parking lots and trail connections. Both Oakville and Kitchener BENCHMARKING It is apparent that no single method is the correct approach for all municipalities. Over Humber River Hospital, Toronto Background Report - March 2018 // City of Guelph 33

42 BENCHMARKING noted that they have previously provided parkland credits for the development of a POPS, and though it is not a standard policy, there are reasonable circumstances to do so. Oakville also reported that for some high density developments where payment-in-lieu is potentially prohibitive, they will often negotiate with the developer to mitigate concerns about cash payments in exchange for public realm improvements. Exemptions and Non-Parkland Credits Dedication caps Currently, there are two main questions to be addressed regarding capping parkland dedication, while also recognizing that parkland dedication fees are one of the few tools that municipalities have at their disposal to incent development in certain areas; (1) does the municipality want to incentivize development of a certain density within growth areas, and (2) is there a reasonable balance that needs to be struck that recognizes rapidly rising land values and the associated impacts on economic development goals? Similar to Guelph, a number of municipalities have employed parkland dedication caps (or exemptions in the case of Kitchener) to encourage development in their downtowns and/or to strike a balance between economic development goals, project viability, and parkland acquisition (as in the case of Waterloo). Kitchener described that they now want to revisit their downtown parkland dedication exemption as they likely no longer require this incentive. The City of Toronto employs a graduated cap based on land size, and where development sites are less than 1 hectare, parkland dedication is capped at 10% of the total land area regardless of density. Hamilton caps development within their Downtown Community Improvement Planning Area at 5%. Waterloo recently instituted a 15% cap for residential development exceeding 100 units per hectare within their Uptown Growth Centre. And as previously mentioned, Kitchener currently applies a full exemption in their downtown (subject to review). The majority of municipalities interviewed do not employ caps. There are no clear rules or equations broadly applied regarding caps. Each municipality determines their specific needs to incent development or acquire parkland. The key takeaway for Guelph is the need to determine whether caps on downtown development are necessary, and if so at what level. What should be exempt from parkland dedication requirements? Municipalities have the power to provide parkland dedication exemptions or reductions in order to encourage other public goals. These goals range from economic goals, such as downtown development, to social goals, such as affordable housing. No two municipalities have the same priorities and thus all apply different policies. It is important to note that the Council of any municipality also has the power to apply exemptions or reductions at their discretion. The following discussion focuses on trends or unique policies worthy of note. School boards do not often pay, themselves, for development or redevelopment of their sites, however a dedication is typically collected for school sites as part of an original plan of subdivision. Other institutional and 34 The Planning Partnership

43 government exemptions are provided in Kitchener, Richmond Hill and Vaughan, while Waterloo exempts University and College developments from parkland dedication. As discussed previously, caps or exemptions are provided by some municipalities for downtown development to encourage economic development within the core. Similarly, Hamilton, London and Waterloo exempt industrial developments to support employment and economic development priorities. Parkland dedication is one of the tools that municipalities use to acquire resources to provide public goods through development, and it can also be used to encourage particular types of development. As planning and development goals evolve, so do incentives strategies. Local municipal initiatives and goals, as well as provincial planning objectives, will dictate the appropriate types of reductions or exemptions for parkland dedication. Regarding housing, Barrie, Markham and Vaughan waive parkland dedication for secondary suites and other minor alterations to dwellings. Affordable and non-profit housing is exempted in Hamilton and Richmond Hill. BENCHMARKING Metalworks (Brownfield), Guelph Background Report - March 2018 // City of Guelph 35

44 INNOVATIVE TOOLS

45 6.0 INNOVATIVE PARKLAND TOOLS & POLICIES 6.1 An Innovative Policy Approach Planning for an urban parkland system requires nuanced policies that support the development of a high quality and diverse parkland system. Parkland conveyance policies should enable a variety of solutions for different contexts and locations, with built in flexibility and quality control mechanisms. Beyond parkland conveyance policies, flexibility and quality control considerations are also needed within supporting municipal policies and practices that dictate how parkland is integrated as an element of community design, and how parkland can be used. Community Design Integrating adjacent land uses can contribute to the success of parks. Parkland use can be optimized by ensuring edges are animated with active urban uses (often commercial uses), by integrating public facilities (such as public buildings, schools, daycare, libraries, etc.) with parkland, and by promoting the joint use of outdoor spaces. Flexibility There should be enough flexibility in the policy to take into account and respond to contextspecific priorities, such as the presence of natural features, opportunities to provide community-specific facilities or to improve the connectivity of the parks and trails network beyond the specific development site. Policies should also respond to changes to real estate values over time. INNOVATIVE TOOLS Quality Control Quality control mechanisms should be built into parkland conveyance policies and practices. To ensure the maximum public amenity is achieved, parkland conveyance needs to be addressed early on in the development approval process, and the City needs to have significant influence on the shape and location of new parks and squares. For example, it is essential that park spaces in major redevelopment areas are centrally located, and not relegated to less desirable, left over spaces. The use of payment-in-lieu is another opportunity to maximize the amenity provided by parkland, and it is important that the City combines its financial resources to create meaningful parks in targeted areas. Town Hall Square, Toronto (Strata above parking garage) Mist Garden, Toronto (POPS above private garage) Background Report - March 2018 // City of Guelph 37

46 6.2 Strata Parks and POPS INNOVATIVE TOOLS Alternative park acquisition strategies have emerged in response to growing intensification pressures and high-density development activity and should be considered in any innovative policy approach to urban park system provision. Two such tools are strata parkland and Privately Owned Public Spaces (POPS). These two park models are typically urban parks that serve both tenants of the development and the public at large. Strata parkland is a public park developed above private infrastructure, typically parking garages or storm water infrastructure (public or private). The park space is deeded to the municipality by the property developer, and is thus publicly owned (and typically publicly operated), whereas the underlying infrastructure is maintained within private ownership. This is not a new innovation or phenomenon, however there is a rise in the frequency that this arrangement is being requested by developers and accepted by municipalities in the GTA, and reflects the need for land efficiencies in higher density urban contexts where land values are elevated and available land supplies are constrained. POPS are privately owned spaces that are publicly accessible via legal agreements between the property owner and the municipality and are privately operated and maintained. Municipal programming and overall control of these spaces is more limited than traditional table land parks or strata parks. These alternative parkland models have unique characteristics that can improve the park system and secure needed parkland onsite. However, they can also add complexity and financial risk compared to traditional parkland dedication and payment-in-lieu models. These park ownership models are tools that the City can add to their park system toolbox and employ when required to address a complex development or parkland dedication scenario. A number of high quality and high profile examples of these types of parks exist across North America, including Millennium Park in Chicago, the High Line in New York, Nathan Phillips Square and Yonge- Dundas Square in Toronto. Legal Overview of Strata Title Stratified ownership of land, often simply called strata title, refers to fee simple ownership of land divided not just two dimensionally (parcels that are next to one another), but three dimensionally as well (parcels that are above and below one another). Normally, an owner of land conceptually owns all the land below the surface of the ground and all the air above it, often referred to as heaven to the centre-of-the-earth ownership. Strata title allows one owner to own above a certain height, while another owner owns below that height. Strata title is most often used, for example, in the creation of condominiums where fee simple ownership of a parcel of land is essentially divided into boxes in the air, to secure air rights above a certain height for a different owner than the owner of the land at ground level, or to create underground structures owned by one owner while the surface and above is owned by someone else, often the case for a parking garage or subway. Air rights are perhaps the best known application of strata title and the legal framework applicable to strata parks is identical. The only differences between strata parkland and air rights are practical ones: strata parkland is generally at or near 38 The Planning Partnership

47 grade level and air rights typically exist at some significant level above grade. Similar easements (in particular rights of support and servicing) are necessary to make effective use of any strata arrangement. Strata parcels of land are created through the same Planning Act mechanisms (i.e. Plan of Subdivision, Consent) that implement any other subdivision of land, usually with the assistance of a strata reference plan that uses a two dimensional reference plan to depict three dimensional parcels. A typical example of a strata parkland arrangement is the creation of two strata parcels, one beginning 1.2 metres below ground level and extending to heaven (the parkland parcel ), and the other beginning 1.2 metres below ground level and extending to the centre-of-the-earth (the parking garage parcel ). The parkland parcel would extend below the ground level far enough to allow for tree planting, soil, water lines, and other associated infrastructure to service the parkland. The parking garage parcel would be subject to a support easement, meaning that even if the garage were demolished, support for the park above would have to be maintained. The parkland parcel might also be subject to easements for services (i.e. utilities) to travel through the below-grade portion of the parkland parcel to reach the parking garage parcel and all infrastructure underlaying the parkland parcel. A reciprocal agreement between the two parcel owners that sets out how and when work that intrudes on the other parcel can be done, including provisions for emergency repairs, cost-sharing, etc. A reciprocal agreement may establish dispute resolution mechanisms, such as arbitration or mediation, but the enforcement of easement terms could also be pursued in the normal manner through the Superior Court of Justice. Unlike other real estate law concepts, the common law does not form the legal basis of strata title. A large volume of case law exists in Ontario concerning disputes that have arisen in the context of strata title between adjacent parcel owners, but most is very fact specific and typically relates to business disputes or oversights in the creation of the parcels or their appurtenant easements. The concept and application of strata title is well established and not by nature controversial. Best Practices and Alternative Parkland Agreements To date, no strata parkland agreements exist in Guelph, and it is understood that the City has not received requests to consider this parkland arrangement. It is however relevant to consider the number of other GTA municipalities who have accepted or are preparing to negotiate strata agreements for parkland. Nearly half of the municipalities contacted for the benchmarking exercise described in Chapter 5 have either already negotiated strata agreements (Markham and Vaughan) or have been approached by developers to negotiate strata and are actively studying how to incorporate strata parks into policies and park systems (Mississauga, Richmond Hill, Oakville). Given the nature of intensification required by municipalities within Growth Plan area regulations, strata parks are inevitably part of the future of urban parkland negotiations. INNOVATIVE TOOLS Background Report - March 2018 // City of Guelph 39

48 INNOVATIVE TOOLS Leases, licences and easements are other options that many GTA municipalities have utilized to create parkland in a manner similar to strata where non-stratified fee simple ownership of new parkland is not desired or possible. These legal agreements are the basis for establishing POPS. Leases and licences are essentially time-limited permission to use a portion of the subject lands (usually, in the case of parkland, the above-grade portion only) for certain specific parks purposes only. Licences can typically be revoked at the will of the owner, whereas leases can provide a greater level of security for a specified time frame. When parks licences or leases expire, there is generally no obligation for the owner to renew the lease or licence. Even if expropriation is then considered, the costs to the municipality to do so can be prohibitive. City when the City wants parkland, insists on owning that parkland, but the developer also needs the space to provide parking and can do so below-grade. Easements are often appropriate when the proposed parkland area is for a specific purpose that is suitable for an easement, such as a pathway that connects two public spaces where the intended use is primarily pedestrian ingress and egress, and the area will still be considered to be and maintained as if it is part of the park. Licences and leases can be the most appropriate if, for example, the proposed park includes special decorative elements, such as paving or a fountain, and the City wishes to ensure that the full obligation and costs to maintain those elements are with the developer, rather than the City who may not prefer to take on the additional cost or responsibility for maintenance. An easement is another mechanism that can be used to secure parkland in some circumstances, in particular if the parkland in question is a trail or path. An easement can be created in perpetuity but is limited to the uses described in the easement. In this context the terms of the easement would have to be worded in a careful and flexible manner to ensure that the fee simple owner could not object to increased or changing use of the parkland over time. Figure 5 provides a highlevel comparison of the various alternatives to secure parkland. Non-legal and site-specific considerations will usually dictate which of the above alternatives is the best approach in any particular circumstance. A strata parkland conveyance can be the best alternative to fee simple parkland for both the developer and the The value of these POPS can qualify as payment in lieu of fee simple parkland conveyance, as set out in s. 42(6) of the Planning Act. The value of these tools would be assessed on a case by case basis but would normally be a fraction of the fee simple value of the same area of land. A value of any obligations of the developer for ongoing maintenance to specified standards would also be quantified, if applicable. Parkland Credits for Strata and POPS Section 42 of the Planning Act permits the municipality to pass a bylaw requiring the conveyance of parkland, or cash paymentin-lieu thereof, as a condition of development or redevelopment of land. There is no legal impediment to the City s implementing bylaw allowing for the acceptance of strata parkland in satisfaction of that requirement. 40 The Planning Partnership

49 Length of Time Flexibility of Permitted Uses Park Use Subject to Interruption Termination Costs Non-stratified Fee Simple Park (typical City Park) Indefinite No limitation None (unless land is subject to easements by adjacent land owners) N/A City owned, maintenance of park only Yes (land is subject Strata Parkland Indefinite No limitation to easements and reciprocal agreement that may interfere with park use) N/A City owned, maintenance of park only Park Lease Park Licence Time limited typically less than 99 years. Time limited typically less than 21 years. Only uses specified in lease Only uses specified in licence Specified in lease (sometimes none, sometimes significant) Yes (at will of owner, or subject to terms of the licence) At end of term or upon occurrence of certain events as specified in lease May be terminated at any time Lease payments, typically maintained by owner Licence fees, typically maintained by land owner INNOVATIVE TOOLS City owned, Easement Time limited or indefinite Only uses specified in easement Yes (as set out in easement) Possibly trigger event or time specified in easement, if any typically maintained by land owner, or as specified in the easement Figure 5 : Comparison of Various Alternatives to Secure Parkland The Planning Act parkland dedication rates refer to fee simple heaven to centre-ofthe-earth ownership. Therefore, if the parkland dedication requirement for a proposed development is 5%, strata parkland that covered 5% of the surface area of the development would not fully satisfy the parkland dedication requirement. In that case the applicant would either be required to provide additional payment-in-lieu equivalent to the value of the strata parcels below the strata parkland to make up the difference, or to convey additional above-grade strata parkland of that value to make up the difference. Two examples are Markham and Vaughan. Markham has negotiated strata agreements on a site-specific basis and have provided up to 100% credit for the land area of the strata park and required the remainder of the dedication as payment-in-lieu. They Background Report - March 2018 // City of Guelph 41

50 INNOVATIVE TOOLS are currently studying what an appropriate dedication rate for strata parkland ought to be and believe that encumbered land should not be provided with a 100% conveyance credit moving forward. Vaughan has negotiated a credit of 1/3 of the land area dedicated as strata parkland, using the rationale that air rights, surface area, and below grade rights should be considered as equal thirds of the total fee simple land dedication. They are currently working to enshrine an approach in policy and practice. If some form of POPS is the site-specific parkland preference, section 42(6) of the Planning Act would allow the conveyance of the lease, easement or licence that creates the POPS to be conveyed as payment in lieu of the conveyance of fee simple land. The appropriate value of the POPS (certainly considerably less than the fee simple value of the same amount of land) would have to be determined at that time. Very few municipalities contacted provide parkland credits for POPS and often purchase or acquire public access to the space through section 37. In the case of Kitchener, they would consider using paymentin-lieu of parkland to then pay the developer for the lease/license of the POPS as opposed to accepting it directly as the payment-in-lieu in order to maintain fiscal transparency. Village of Yorkville Park, Toronto (above subway) There is currently no provincial policy that precludes a municipality from accepting strata parkland or POPS as a form of parkland dedication or payment-in-lieu. As previously discussed, all stratified parcels, including strata parkland, are created through the same Planning Act mechanisms. The eventual park, whether fee simple non-stratified park, strata parkland, or POPS, must meet the City s objectives for a public park, and ultimately the power to determine whether or not to pursue acquisition of alternative parkland agreements rests with the City. Guelph s Official Plan does not identify strata parkland as a tool, nor does any policies therein preclude the City from pursuing this type of parkland agreement. With respect to POPS, policy of the Official Plan establishes that parkland dedication credits will not be considered for parks or urban squares held in private ownership. This is clear policy language that would require alternative policy tools to enable the crediting of POPS, such as Kitchener s method wherein the parkland dedication is provided as payment-in-lieu and then the City uses that cash to purchase the lease/license for the POPS, or to use section 37. Strata Parkland Considerations Quality of Engineering and Construction Poor engineering and/or poor quality construction affect all aspects of a park s function and lifecycle, and they are both fundamental considerations in this discussion. For the most part, the lifecycle terms that are discussed in this report will be dramatically reduced where engineering and construction is of a sub-standard quality. There are best practices and higher quality materials available to ensure maximum longevity. The 42 The Planning Partnership

51 key is to find or develop appropriate standards from an engineering, design, construction and installation perspective, and require the use of high quality materials. Waterproofing Membrane Good quality membranes now claim a 30 to 40 year lifecycle. Experience has shown that membranes used in the past last approximately 20 years or less. The quality of the installation of the membrane, the quality of the membrane itself, the design of the park space, the maintenance protocols and the characteristics of the underlying infrastructure will all have an impact on how long a membrane will and should last. In a general sense, it is expected that a modern urban park built over structures/infrastructure will last as long as the membrane beneath it about 30 years. At which point maintenance on specific sections of the membrane or complete replacement of the membrane will be required. membrane, not necessarily the park itself. It is important to note that the costs for both traditional larger green parks and urban parks vary widely due to the design details of the park. Maintenance Protocols Park maintenance protocols that utilize salt, or other corrosive chemicals will affect (shorten) the lifecycle of the waterproofing membrane. Further, and in a general sense, urban park spaces require a much more robust maintenance protocol than a traditional larger green park space, regardless of whether or not it is built over top of a structure/infrastructure. Traditional parks need to be maintained between once or twice a week, depending on the level of use. Busy urban parks need to be maintained every day, and sometimes more than once per day, depending upon use. INNOVATIVE TOOLS Cost of Park Development A traditional larger open green park space, with landscape planting, trees, grass, sports fields and play structures cost between $25.00 and $95.00/per square metre, with an average cost of about $55.00/square metre. In comparison, a typical urban park, although usually much smaller, that includes hard surfaces, trees, landscape plantings and seating cost between $90.00 and $1,500.00/square metre, with an average of approximately $545.00/square metre. Urban parks built over structures/infrastructure tend to be very cost comparative to a typical urban park. The key additional cost element for an urban park built in a strata scenario is the cost of the roof structure and required With respect to ongoing maintenance there is a huge difference between a traditional park and a typical urban park. The difference between a typical urban park and an urban park built over a structure/infrastructure is not significant, and varies depending upon the level of park use, although care must be taken to ensure the lifecycle of the membrane. Lifecycle A traditional park includes some components that have a long, indefinite lifecycle, and while it is recognized that some components of a traditional park may need to be refreshed from time to time, there really is not a definitive lifecycle that is identifiable. A typical urban park has a defined lifecycle of about 30 years. That timeframe is defined Background Report - March 2018 // City of Guelph 43

52 partly due to its expected usage levels, and partly by the lifespan of trees within the urban context. That lifecycle depends upon soil depth, soil volumes, soil quality and maintenance protocols, and what we have learned from a lack of species diversity in our urban forest. Interestingly, the lifecycle of an urban park built over a structure/infrastructure is subject to the same tree-life constraint, and also the expected lifecycle of the membrane beneath it. This lifecycle is also similar for urban streetscape development. INNOVATIVE TOOLS Generally, an urban park, an urban park built over a structure/infrastructure and urban streetscapes need to be substantially rebuilt every 30 years or so. That lifecycle will be dramatically affected by the quality of the original engineering, construction and ongoing maintenance of the facilities. For urban and urban parks built over structure/ infrastructure, that lifecycle will also be affected by the quality of the membrane and the quality of its installation. The ultimate decision regarding which tools to include in a parkland acquisition toolbox lies with the City, however the contemporary urban realities facing most of the GTA will continue to progress in Guelph and the City ought to consider all available tools in order to ensure that the park systems continues to flourish and serve Guelph s existing and future residents. Future development in the City will require new approaches to providing a diverse and flexible parks system to accommodate the new densities of urban dwellers. Strata parks and POPS, in addition to policy tools such as section 37 are examples of these tools. 44 The Planning Partnership

53 Levinson Plaza, Boston (POPS) INNOVATIVE TOOLS Dr. Lillian McGregor Park, Toronto (Proposed Strata; Credit: City of Toronto) Background Report - March 2018 // City of Guelph 45