Special Post

Planning - Spam, Sham, or Scam?



On April 21 the Prince Albert District Planning Commission sponsored an open house at City Hall (from 5 PM to 9 PM). The advertised purpose was to explain the policy document prepared by Crosby Hanna & Associates, a Saskatoon planning firm. This document was available by sending an e-mail request to the Commission(padpc@sasktel.net).

As might be expected, my reading of the document gave rise to numerous questions. At the open house, I directed a handful of these to a Hanna Crosby associate. There were so many people in the foyer that he only gave me a few minutes of his time.

[I was told by another observer of the sorry state of PA planning that most of the crowd were residents of the two RMs adjacent to the city - their keen interest piqued solely by the prospect of acquiring advance knowledge of developments that would either positively or negatively affect the value of their property; "planning policies" of any sort were only germane insofar as they affected future personal finances. Considering that residents of the City of Prince Albert are also directly affected by PADPC policy, and they outnumber the RMs' residents five to one, their noticeable absence was unusual.]

My submitted comments on the document are reproduced below. Unfortunately, it is not yet available at http://rmprincealbert.ca/planning.htm


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Page 2:
- "2.2 (2) To strengthen the economic base of the member municipalities by creating a positive environment for sustainable business development."
The problem with this "goal" is that most businesses in the three municipalities are NOT sustainable; sustaining the opportunity for business development is not in doubt. The problem with the goal is that it is extremely confusing. The purpose of planning, moreover, is to accommodate differing interests. "Business" is only one of those - and if the goal of a physical planning process is to sustain business, other interests (social, political, spiritual, artistic, and recreational, to name a few) necessarily suffer. The statement should probably read, "To strengthen the economic foundation of the three member municipalities by creating a physical environment that supports the development of sustainable businesses."

Page 3:
- "The presence of streams and rivers in the R.M. of Buckland is ecologically important, from the perspective of habitat values . . . ."
Why are streams and rivers in the RM of PA and the City of Prince Albert omitted from this sentence?
- "(3) Responses to the community survey indicate that residents strongly support protection of the environment."
Where are the community survey description and results?
- "Policy is required to help ensure that development is consistent with the protection of significant natural resource values in the Planning District."
Where is the definition of "significant natural resource values"? (These cannot be left up to politicians to interpret on the fly. . . .)
- "(3) The Soil Survey report for the R.M. of Buckland indicates that a total of 17,400 ha (42,996 acres) of land is rated as Class 1 and 2 considered [sic] to be of high capability for dry land agricultural production."
Repetition of "3" may be a simple typo, but there is no excuse for failing to indicate WHERE that class 1 and 2 land is. "Map 1," the only inclusion in Appendix A, simply delineates the different policy areas. Since "policy is required to protect prime farm land (class 1 and 2) from being unnecessarily taken out of production for residential or other non-agricultural use" [although this concept has never inhibited local lawmakers before . . .] people reading this document should be able to see (now) where that land is. Of course, there must also be a map showing class 1 and 2 land in the RM of PA.

Page 4:
- "(8) Responses to the community survey indicate that residents strongly support protection of theenvironment."
This finding "(8)" is the same as the first finding (3) on the previous page. Neglecting the obvious cut-and-paste duplication error, was there something else about the (missing) survey that was noteworthy?
- "Proposed Objectives"
None of these directly addresses compatible land uses; number 8, while referring to development not compromising cultural and heritage resources, is too limited, and only alludes to land use compatibility. "Compatible land uses" should be clearly spelled out as an objective.

Page 5:
- "(3) Developments which ensure that water bodies, waterways, shore lands, groundwater and riparian systems are protected and sustained will be encouraged."
The word "encouraged" is effectively useless: change it to "required."
- "(4) The rural municipalities may employ site-specific planning programs, either alone or in cooperation with other agencies, organisations or governments, to protect water bodies, waterways and shorelands. . . Site-specific plans may result in limiting or prohibiting development in these areas."
To the best of my knowledge, developments in the RMs of Buckland and PA have NEVER been limited or prohibited. Perhaps the 'ideal situation' described in the policy should be reinforced - otherwise, this (standard) rhetoric is an empty shell.
- "(3) The member municipalities shall work in partnership with the Saskatchewan Watershed Authority to maintain and conserve the South Saskatchewan Watershed and its source water resources."
This is the second, of three proposed policy "(3)"s on this page. Obviously, there's some sloppy proofreading here - reinforced by the single reference to the SOUTH Saskatchewan River watershed: since the NORTH Saskatchewan River is the main watershed running through the area (it bisects the Planning District, rather than running along its southern boundary), it should be mentioned here.

Page 6:
- "(7) Development shall avoid land that is hazardous due to flooding, erosion, soil subsidence, slumping or slope instability. Map 2 - Potential Hazard Lands, identifies land in the Planning District that is potentially hazardous due to slope instability or flood susceptibility."
As was pointed out earlier, there is no Map 2 in this document - an omission that makes it impossible for people to assess and comment on "hazard lands."
- "(9) Development shall avoid land that is environmentally sensitive."
As was pointed out above, there needs to be a "definitions" section in this document. "Environmentally sensitive" needs clarification.

Page 7:
- "Responses to the community survey indicate that residents strongly support being able to recycle waste materials at a facility. The R.M. of Prince Albert currently does not operate a solid waste transfer station within its boundaries however, [sic] the City of Prince Albert owns and operates a solid waste transfer station located at the South 1/4 Section 19 and North 1/4 Section 18-49-26-W2. Ratepayers in the R.M. of Buckland can purchase a yearly dump pass for household waste. Policy is needed with respect to future management and disposal of solid waste and sewage generated in the Planning District."
The first sentence refers to recycling, but does not say WHERE recycling facilities are or should be. Strangely, the sentences that follow it are unrelated to the strong support for recycling manifest by RM property owners in the (unseen) survey. (Thus, we have a perfect example of a non sequitur). "Recycling" must be included somewhere in the final sentence - otherwise the policy is restricted solely to disposal of waste (which excludes recyclable materials).

Page 8:
- "(3) To ensure that development does not create any traffic safety issues."
Another restrictive concept is evident here: rather than just assuming that "development" must create additional traffic, "development" must, at some point, be asked to assume responsibility for reducing traffic, and making traffic flow more safely than before.
- "3.2.3 Proposed Policies(1) All developments shall provide for:"
Add "(d) water conservation" to this list. Water is a finite resource, and it will get more scarce in the time frame envisaged by this document.

Page 10:
- "(12) Transportation Policies"
This list appears written solely for private motor vehicles - not for buses, off-road vehicles, self-propelled movement (cyclists and walkers), and (heaven forbid, apparently) train traffic. It must take these other means of transportation into account. The reference to development not creating "potentially unsafe traffic conditions" neglects to consider that increases in traffic volumes are inherently unsafe - and must therefore be accurately studied, assessed, and mitigated. Refer also to my comment above (i.e., "development" must, at some point, be asked to assume responsibility for reducing traffic, and making traffic flow more safely than before.)

Page 12:
- "(3) Lands in proximity to the City of Prince Albert that have been identified by the City as having potential for future urban development are designated on Map 1 Future Land Use Concept as Urban Future Growth Area. Map 1 also indicates planned future use of this area. Map 1 also identifies an Urban Future Growth Area for the Village of Albertville."
The area southeast of the city (adjacent to Crescent Acres) is projected as future urban development in official City of PA planning documents (most recently revised in August 2008), but this is the first indication that a huge tract of land directly south of the city (extending past the junction of highways 2 and 11, and eastward to highway 3) is included in the "Urban Future Growth Boundary" on Map 1, relating to "approximately 20 years of future growth and development within the Planning District" (see page 1 of the document). This also deviates from the city plan's express intention to expand to the southwest (in the neighbourhood of the soccer centre). How does this difference between planning documents get "planned around"? Or is it simply ignored? The absence of Map 2 from this document also makes assessment of impacts on land adjacent to the city impossible (see policies (5)(a) and (5)(c) on page 13); there's also potential conflict here with objective (6) on page 15 - "To encourage agricultural and natural resource development which will improve the local economy."

Page 19:
- "(3) Agricultural Related Commercial and Industrial Uses:(a) The Zoning Bylaw will list principal agricultural related commercial and industrial uses asdiscretionary uses."
Again, definition is needed with respect to these "principal" uses.

Page 21:
- "(2) Limited residential and commercial growth in the form of infilling of existing vacant land shall be allowed in the hamlets."
Infill of vacant lots is logical, efficient, and easily-sustained development; limits on such development warrant justification and clarification.

Page 22:
- "(4) Land use policy is required to minimize the costs of country residential development to the municipality and to ensure that it is undertaken in an orderly, planned manner."
Using land use policies to guide development also means issuing "Requests for Proposals" to ensure "orderly, planned" development (in particular, by the City of Prince Albert). The City also incurs costs when "country residential" lots are developed in the two RMs - especially with regard to traffic issues and water service.
- "(1) To ensure that country residential land uses do not jeopardize essential agricultural or other natural resource activities."
"Essential" agricultural and other activities need to be defined - in relation to class 1 and 2 farm land (see page 3 comment above).

Page 23:
- "(3) To minimize the economic costs of country residential development for the rural municipalities.
(4) To ensure that new country residential development is created at a scale and density to discourage the formation of new organized hamlets within the Planning District."
There are economic costs to the City of Prince Albert from country residential development (see page 22 comment above), not just the two RMs.
What is the rationale for discouraging new organized hamlets? Such population centres make more sense than the usual 1-acre country residential lots being created all over the district.
- "(5) Residential building construction shall be regulated by rural municipal Building Bylaws."
Why is there no reference here to provincial and federal building codes, or the construction of resource-conserving buildings?

Page 24:
- ". . . minimum separation from industrial uses as provided in Section 3.7.3 (8) [page 32] of this document."
Country residential locational policies in the table referenced here are totally confusing: 300 metres is NOT equal to 0.5 mile; and 1 mile cannot be converted into both 800 meters and 1600 meters. The author clearly did not understand conversion factors (or proofread this table's content). The current minimum separation distance of a single residence from industrial land in the RM of Buckland is 500 meters. This was ignored in the recent approval of the Boyer Estates property development (across the highway from Red Wing), so it appears the proposed change to 300 meters is how the district will avoid similar dysfunctional situations in the future. In any case, there is no justification for the reduction in the minimum separation distance.

Page 25:
- "(a) The Zoning Bylaw will contain a series of country residential zoning districts toaccommodate multiple-lot country residential subdivisions."
WHERE will those zoning districts be? The scarcity of maps in this document is again problematic.

Page 27:
- "(ii) Multiple lot country residential subdivisions shall not be located: . . . In a linear fashion stretched along municipal roads.
- On land having more than 10% of its total area classified as having high capabilityfor dry land agricultural production."
Mindful that such subdivisions are regularly stretched "in a linear fashion," the main issue here is really the vague reference to "high capability" agricultural land - a definition of which must directly relate to the concepts of class 1 and class 2 farm land.
- "(e) Development and Design
(i) Phasing
A maximum of three multiple lot country residential subdivisions in developmental stages will be allowed at any point in time in either of the member rural municipalities. Multiple-lot country residential subdivisions with less than 75% of building lots with completed residential construction will be considered to be in a developmental stage. However, if 75% of available lots in one or moreof those three subdivisions are vacant but it appears that development is lagging because the developer/land owner is holding land vacant or is encountering difficulty with financing the development then that subdivision will be deemed tonot be in a developmental stage and the affected rural municipality may consider the approval of up to three additional subdivision proposals."
This convoluted phasing provision allows a total of six subdivision proposals to be in various stages of (in)completion "at any point in time" in each of the RM of Buckland and the RM of PA - surely more than the planning capacity (and, perhaps, the residents' patience) in the district is capable of sustaining. This also makes it possible for six developments to bar additional proposals from being considered for several years if the developers/landowners are merely holding land vacant. [The nine-year history of the still-vacant land on the south side of 28th St. West, at what would be 8th Avenue in the City of Prince Albert, is instructive in this regard.] I suggest re-thinking this whole idea, to simplify the acceptable number of developments underway at any one time, regardless of the "developmental stage."

Page 29:
- "The Zoning Bylaw will prescribe maximum and minimum lot sizes and other appropriate development standards for multiple lot country residential development, with the aim of preserving productive agricultural land and ensuring that such development does not resultin increased road hazards related to obstruction of sight lines, etc."
"Maximum and minimum" lot sizes are clearly specified on page 25 of this document, so this section's reference to the size issue is redundant. The definition of "productive agricultural land" is likely to conflict with "high capability" agricultural land (see page 27 comment above), and again requires clear reference to class 1 and class 2 farm land.

Page 31:
- "(6) Future commercial or industrial subdivisions or re-zoning for commercial or industrial development shall avoid conflict with existing land uses and development. Conflict with existing land uses and development will be demonstrated by, but such demonstration will not necessarilybe limited to, the following:
(a) anticipated levels of noise, odour, smoke, fumes, dust, night lighting, glare, vibration or other emissions emanating from the operation will be sufficient to affect the residentialcharacter of existing residential areas; or
(b) anticipated increased levels or types of vehicle traffic may create unsafe conditions or situations for vehicles, cyclists or pedestrians within or adjacent to existing residential areas."
It's interesting that 'business' development is recognized here as having potential adverse effects on vehicular, cycling, or pedestrian traffic. Why was this not a consideration in the residential land use and development section (III 3.6)?

Page 32:
- "Table 3-3
MINIMUM SEPARATION DISTANCES FROM INDUSTRIAL LAND USES
Land Use/Location Required Separation Distance
Single residence(1) 300 metres (0.5 miles)
Multiple lot/unit
residential subdivisions(2) 800 metres (1 mile)
Urban municipality(3) 1,600 metres (1 miles)
Resort commercial
development(4) 800 metres (0.5 miles)

Notes:
(1) Distances from individual residences are measured between industrial site and residential building. (2) Distances from multiple lot or multiple unit residential subdivisions are measured between industrial site and the nearest residential site.
(3) Distances from urban municipalities are measured between industrial site and the corporate limits of the urban municipality.
(4) Distances from resort commercial development are measured between industrial site and resort commercial development site."
This is the infamous table originally referred to on page 24 - replete with incorrect metric-to-English distance conversions. For the record: 300 meters is 0.186 of a mile; 800 meters is just under 0.5 of a mile; and 1600 meters is just under one mile.

Page 33:
- "(11) If it appears that a proposed commercial or industrial development requires large volumes of water, the affected rural municipality may require the applicant to demonstrate that the water supply is sufficient for the development and the supply for neighbouring developments will not be adverselyaffected by the proposed operation."
A nuclear power plant would be such a development. The affected rural municipality MUST require such a development to demonstrate that there will be no adverse effects on the supply to neighbouring developments (or downstream water users) - the word "may" is inappropriate and ineffectual.

Page 34:
"Table 3-4
MINIMUM SEPARATION DISTANCE FROM HAZARDOUS INDUSTRIAL USES
OTHER PRINCIPAL LAND USES DISTANCE
Single residence(1), tourist accommodation(2) - 1,600 metres (1 mile)
Multiple-lot country residential subdivision,
lakeshore residential subdivision orhamlet(3) - 2,400 metres (1.5 miles)
Urban Municipality(4) - 2,400 metres (1.5 miles)
Municipal Well(5) - 1,600 metres (1 mile)

Notes:
(1) Distances from individual residences are measured between hazardous industrial use sites and residential building development.
(2) Distances from tourist accommodations are measured between hazardous industrial use sites and the tourist accommodation site.
(3) Distances from multiple-lot country residential subdivisions, lakeshore residential subdivisions and hamlets are measured between hazardous industrial use sites and the residential or hamlet sites.
(4) Distances from urban municipalities are measured between hazardous industrial use sites and the corporate limits of the urban municipalities.
(5) Distances from municipal wells are measured between hazardous industrial use sites and the well head"
Table 3-4 needs to be revised in light of a potential nuclear power plant in the district. There is also no rationale for having two different distances in this chart; a uniform separation distanced of 2400 meters is probably a better choice than 1600 meters.

Page 38:
- "(3) The rural municipalities will not approve requests for the rezoning of land to Hamlet District to accommodate the subdivision and development of new hamlets.
(4) Where applications for multiple lot country residential subdivisions and development are made in the Residential Policy Area, Council will consider such applications favourably and make required amendments to the Zoning Bylaw to accommodate such developments where it is demonstrated that:
(a) site conditions are suitable for multiple parcel country or development;
(b) negative environmental impacts of such development are avoided or suitably mitigated; and,
(c) the development conforms to all other relevant provisions of the Official Community Plan and Zoning Bylaw."
No justification has been provided for the prohibition on new hamlets. In addition, the prohibition here conflicts with page 23 (see comment above), where the document wants to merely "discourage" the formation of new hamlets. Item (4) here, in its reference to "Council will consider such applications favourably," grants automatic approval to country residential subdivisions - hardly the stuff of democratically- or community-controlled development processes. To correct the mis-direction, "Council will consider such applications favourably" should appear AFTER the three provisos, not before them. The "Residential Policy Area" is also not on a map contained in this document.

Page 39:
- "(3) Where applications for commercial or industrial development or subdivisions are made in the Highway Corridor Policy Area, Council will consider such applications favourably and make required amendments to the Zoning Bylaw to accommodate such development where it is demonstrated that:
(a) site conditions are suitable for commercial or industrial development;
(b) negative environmental impacts of such development are avoided or suitably mitigated; and
(c) the development conforms to all other relevant provisions of the Official Community Plan and Zoning Bylaw."
Another unfortunate result of 'cut-and-paste.' The same comment as for (4) on page 38, with respect to automatic approval, applies: "Council will consider such applications favourably" should appear AFTER the three provisos, not before them. In addition, the "Highway Corridor Policy Area" is also not on a map contained in this document.

Appendix B - Country Residential Evaluation Workbook
Overall comments:
There needs to be a clearly-indicated 'marking scheme' for every one of the questions on these nine pages ("Yes/No" categorization is insufficient). And where are the commercial activity considerations?

Page 1:
"1.2 How many residential sites are proposed by the subdivision?
Total number of sites:
Range of site size (smallest site – largest site):"
The requirement should be to specify the number of lots of EVERY size. Sustainability is also relevant to this consideration - see the Federation of Canadian Municipalities web site for guidance here (that ultimately creates eligibility for federal infrastructure funding).

Page 3:
- "1.6 Energy efficiency of proposed structures and/or subdivision layout (e.g., building location responding to daily sun/shade patterns, north-south orientation of residential sites, high performance envelopes, passive solar gain, solar shading, natural ventilation, ground heating/cooling)."
Water conservation also needs to be promoted. Include this concept here.
- "1.7 What proportion (%) of residential sites in the subdivision have a north-south orientation appropriate for taking maximum advantage of passive solar energy?"
Go the next step: refer to the roof slope (38 to 54 degrees) required to easily facilitate active solar energy (hot water, thermal, and photovoltaic) systems in this district.

Page 5:
- "1.13 How is the layout of the streets designed (e.g. grid, curvilinear)?
Street layout can influence maintenance costs as well as connectivity with surrounding development. Intersections and sight lines related to streets can influence public safety.
Describe:"
The item should also ask if the street layout is conducive to safe use by cyclists and pedestrians.

Page 8:
- "3.2 Does the subdivision have any features that will reduce the long-term costs to the municipality of operating and maintaining public services and infrastructure (e.g. reduce roads and pipes for servicing that will have to be maintained by the R.M.)?
Yes/No
Describe:"
Long-term costs to the City of PA need to be considered (see page 22 comment above).

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In summary, there is a traditional planning "box" firmly embedded in this document - one from which the authors need to extricate themselves in order to provide long-term, thoughtful planning policies for the City of Prince Albert and the two RMs. As currently written, this document merely serves to reinforce the district's failure to guide development in anything but a seat-of-the-pants, ad hoc manner.