Report to: Development Services Committee                                                 October 13, 2009

 

 

SUBJECT:                          Draft York Region Official Plan

PREPARED BY:               Policy & Research Division Staff

                                            Planning & Urban Design Department

 

 

RECOMMENDATION:

1)                  That the report to Development Services Committee entitled “Draft York Region Official Plan”, be received;

 

2)                  And that the comments outlined in this report and detailed comments attached as “Appendix A” be forwarded to the Region as Markham’s preliminary response to the Region’s request for input on the draft Regional Official Plan;

 

3)                  And that further comments be provided to the Region as Markham Council provides further direction with respect to the Town’s Growth Management Strategy;

 

4)                  And that Staff be authorized and directed to do all things to give effect to this resolution.

 

EXECUTIVE SUMMARY:

On June 17, 2009, the Region of York released a draft York Region Official Plan (ROP) for public review and comment.  Staff has reviewed the draft ROP in the context of the Provincial Growth Plan and Markham’s Growth Management Strategy and associated background studies currently underway.  The draft ROP is the culmination of 3 years work by regional staff and council.  There has been extensive public consultation and involvement of municipal staff.  The draft ROP represents leading edge policy, grounded in the three pillars of sustainability.  Staff commends the Region for their efforts to ensure a consultative and educational process and the resulting comprehensive policy regime contained in the draft ROP.

 

The comments contained in this report and Appendix are offered only to improve the direction and clarity of the ROP.  Technical Staff comments and suggestions are included in Appendix ‘A’ [attached] to this Report.  This report outlines high level comments in the broad theme areas of:

  • Policies
  • Study Requirements, Phasing Mechanisms, and Implementation
  • Definitions and Mapping.

 

Staff met with Regional Planning staff to discuss and review comments and concerns.  Regional staff committed to continue working with staff to address a number of technical requests. This report also highlights a few matters that Council may wish to specifically review and comment upon.

 

Committee will recall from the presentation on September 15th by Regional Staff, that the draft ROP contemplates expansion of the current urban area in northern Markham. It is anticipated that the final ROP submitted to Regional Council for adoption (targeted for November 2009) will identify an extended urban area boundary. If, at that time Markham Council has not reached a decision regarding any possible extension of the current urban area, Council may wish to request a deferral of the ROP policies and mapping until it has reached a decision.

 

PURPOSE:

The purpose of this report is to provide Markham’s preliminary comments on the draft York Region Official Plan currently out for public consultation.  The Region should be advised that further comments may be provided once Markham Council provides further direction with respect to the Town’s Growth Management Strategy.

 

BACKGROUND:

Since 2005, York Region (the Region) has been proceeding with a growth management undertaking entitled ‘Planning for Tomorrow’.  Planning for Tomorrow and related studies set the stage for a ‘new’ York Region Official Plan.  Through the Planning for Tomorrow process, and the update of servicing and transportation Master Plans, the Region incorporated an extensive consultation program.  The draft ROP also incorporates policies to achieve conformity with the new Provincial planning context which includes the Greenbelt Plan, Source Water Protection, and Places to Grow Plan, the Regional Transportation Plan (The Big Move) prepared by Metrolinx, and the Lake Simcoe Protection Plan.

 

Provincial legislation requires the Region to conform to and implement the Growth Plan for the Greater Golden Horseshoe, through the new Regional Official Plan.  In turn, Markham is also required to conform to both the provincial plan and the new Regional Official Plan through our conformity exercise, leading to a new Markham Official Plan. It should be noted that, the Region is the approval authority for Markham’s new Official Plan.  Our Official Plan conformity exercise, leading to a new Official Plan will be initiated following a Council decision on a prefered growth option.

 

On June 17, 2009, the Region released a draft ROP for public review and comment.  Regional staff provided a presentation on the draft ROP to Development Services Committee on September 15, 2009.  The Region has held public information meetings at various locations across the Region (September 16, 2009 in the Town of Markham), and a Statutory Open House on September 29, 2009, and will be concluding with the Statutory Public Meeting on October 7, 2009. 

 

The Region’s staff report dated June 17, 2009, recommends reporting back to Regional Planning and Economic Development Committee on November 4, 2009 with the comments received from the consultation program and any recommended changes to the draft ROP document at that time.  It is anticipated that this timing would enable Regional Council to adopt the draft ROP before year end.  The approval authority for the new Regional Official Plan is the Province of Ontario.

Town Staff from the Planning and Urban Design and Engineering Departments and the Office of Sustainability met with Regional Planning staff and discussed the items outlined in this report.  Regional Staff continues to work with Town Staff to address a number of technical requests.

 

OPTIONS/ DISCUSSION:

Specific and detailed comments on the draft ROP are attached in Appendix ‘A’.  This report outlines the broader themes and comments discussed with the Regional planning staff.

 

Policies

Environment

The Regional Official Plan confirms that 69% of the total regional land base is protected for agriculture and environment in the Oak Ridges Moraine and the Greenbelt.  Future development lands (“white belt”) identified in the Provincial Growth Plan represent 4% of the total regional land area.  The Region has identified that only 1.6% of the total regional land area will be required for new community development, prior to 2031.

 

In June 2009, the Town adopted in principle a proposed Greenway System through the Town’s Environmental Policy Review and Consolidation Study (EPRC).  The Region’s proposed Greenlands System is generally consistent with the Town’s Greenway System reflecting all the river corridors, woodlots, wetlands and Greenbelt boundary.  The Region identifies a ‘Greenlands System Vision’ through a conceptual arrow on Map 2 which extends through the urban area of Whichchurch-Stouffville through the Federal lands in north Markham and eventually connecting to the Little Rouge Creek corridor – Rouge Park.  Recognizing that this ‘vision’ is conceptual, Staff still feels that the Greenway System vision should extend along the Greenbelt protected corridor of the Little Rouge Creek connecting to Bruce’s Mill Conservation Area to take advantage of the natural heritage opportunity rather than through settlement lands and agricultural lands.   The Little Rouge Creek corridor in Markham is identified to support the contiguous Rouge Park connection to the Oak Ridges Moraine. 

 

A number of other comments have been provided on the Sustainable Natural Environment policies and are contained in Appendix ‘A’.  Of particular note, the Region should ensure that the data sources and definitions of the component layers in the Greenlands System are clearly identified so that these layers can be replicated at the local level and understood by landowners and developers.  This is particularly important since similar features (woodlands) can be defined differently by involved agencies (Province, TRCA, Town).   It is also important that where the Regional Greenlands System is to be delineated to a finer level of detail in support of new development, the policy should also support and acknowledge that the Regional system can be enhanced through a local greenway system, should the local system include additional lands.

Staff recommends the inclusion of additional environmental policies.  It would be appropriate to include a specific Rouge Park policy since this park will have an enhanced multi-purpose park function within both the Greenlands and Agricultural System.  Town Staff also suggests that a policy could be included to allow new wetlands to be created on public lands to be recognized in the Regional Official Plan without the need for a formal amendment to support the wetlands enhancement initiatives in the Rouge Park

 

The recommended policy approach with respect to significant woodlands in Markham is that these features are to be protected.  The Region’s policy Section (2.2.38.b) provides flexibility for the development and site alteration of significant woodlands in the ‘new community areas’ (future growth areas).  At this time, this policy is not consistent with the recommendations of the Town’s Environmental Policy Review and Consolidation Study. 

 

These matters were discussed with Regional Staff, who will be working with Town Staff to address them.

 

Growth Forecasts, Land Budget and Settlement Area Boundary

The draft ROP incorporates growth forecasts for Markham that have been used as the basis for determining the required land budgets to accommodate growth.  Staff has previously reported to the Committee on the forecasts and land budgets.  Work towards the development of a growth management strategy for Markham including the Intensification Study, the Housing Stock Analysis, and the Employment Lands Strategy (Phase 1) has confirmed that Markham can meet, and if the market responds, exceed the residential intensification target established by the Region.  Second, the work has confirmed that the residential land requirement outside the current settlement area       (+/- 600 ha) identified by the Region is valid and should be used to accommodate new housing, ensuring that Markham achieves a long term housing mix consistent with market needs.  Third, the work has confirmed that the requirement for additional employment land outside the current settlement area can be reduced (to +/- 300 ha), if the land contingency is excluded and no separate land requirement for major retail development is provided.  Finally, the locations for new communities and employment land proposed by the Region are consistent with the Provincial Growth Plan and Markham’s completed work and Staff’s preferred growth scenario.

 

The draft ROP incorporates a reduction of approximately 8,000 jobs within Markham over the previous 2031 forecast.  Details of the breakdown of the new employment forecast are not yet available.  Once the detailed information is available, staff will review the implications for land budget estimates.  In light of the minor nature of the overall reduction, and the focus on employment growth within the current settlement area, no significant change in the land budget is anticipated.

 

Staff is comfortable with the draft ROP’s policies relating to growth forecasts and land budget and it is expected that the final draft of the ROP will identify additional lands to be added to the Urban Area on Map 1 [in the general location of the conceptual asterisks shown in the current draft].  In the event that the Region does identify a specific new urban boundary for Markham in the Regional Official Plan, and Council has not reached a decision regarding possible expansion of the urban area, Council will need to consider advising the Region, by resolution, that it has not reached a decision and request a deferral of policies and mapping related to urban expansion in Markham, pending a Town decision.

 

Employment

Markham’s Employment Lands Strategy (Phase 1) Study addresses the employment forecasts to 2031 in the draft ROP.  The Strategy assumed that all vacant lands within the current settlement area, designated for employment, would be available to accommodate employment, in order to reinforce current policy and minimize the need for additional land outside the current settlement area.  In this regard, all employment lands, designated and proposed, are considered “strategic”, in meeting the intent of the draft ROP to accommodate employment growth.

 

The inclusion of policies in the draft ROP suggesting that only some employment lands are strategic is confusing and could undermine Town policies aimed at the preservation of all employment lands required to accommodate the forecast employment growth.   It would be preferable for the draft ROP to confirm the strategic importance of all employment lands needed to accommodate existing and future employment.  Staff supports the Region in conceptually identifying the location of lands to be protected for employment purposes after 2031 to ensure that future employment is strategically located, and that consideration of future employment development can be taken account of during the planning period to 2031.

 

Additional detailed comments with respect to policy interpretation, clarification requirements, definition requirements, and additional policy suggestions are contained in Appendix A.

 

Buttonville Airport

The draft ROP policy with respect to the Buttonville Airport is “That should airport operations at the Toronto Buttonville Municipal Airport cease, the subject lands shall be retained as employment lands.”  Staff concurs with the draft ROP policy and direction relating to the Buttonville Airport.  Markham’s policy is that the airport lands have an INDUSTRIAL designation in Markham’s Official Plan (in addition to a Transportation and Utilities designation for the current airport use) and that:

“…... In the event that the Buttonville Airport ceases to operate, it is expected that the lands …will be developed for uses consistent with the Business Park Area category of INDUSTRIAL designation”

Consistent with the Town’s Official Plan, the Employment Lands Strategy (Phase 1) assumed that if the airport were to cease to operate, the lands would be available for future Business Park employment, and prepared land budget estimates on this basis.

 

If the Region and the Town were to be requested by the landowner to change the current Official Plan designation, this could only happen in the context of a comprehensive review by the Town of its employment land requirements and overall policies for land use and development.

 

Major Retail Uses

The significance of the policies addressing ‘Major Retail’ in the draft ROP is heightened by the absence of a definition of the term. Staff concurs with the draft ROP policy direction of not permitting ‘Major Retail’ on designated or strategically located employment lands.  However, by leaving it to individual local municipalities to define ‘Major Retail’, the draft ROP permits possible inconsistencies in the interpretation and implementation of the Region’s policies through the various conformity exercises and development review by local municipalities.  Potentially, the absence of a definition could also leave interpretation to the Ontario Municipal Board.  A definition in the draft ROP would ‘level the playing field’ for all municipalities, using the same criteria to define ‘major retail’.  This is especially critical with respect to implementing the draft ROP policies dealing with ‘conversion’ of employment land to ‘Major Retail’.  The draft ROP does contain a policy requiring a Regional Impact Analysis for new retail facilities in excess of 30,000 square metres of gross leasable area.  The Region needs to clarify whether this floor area is what is meant by ‘Major Retail’ and over what property configuration the area measurement is applied. 

 

Other more specific policy suggestions related to Major Retail are contained in Appendix A.  Staff has reviewed these matters with Regional staff and will be working with them on a satisfactory resolution.

 

Sustainable Cities/Communities

The draft ROP was developed using a Sustainability lens and incorporates what is commonly known as Triple Bottom Line objectives to achieve sustainability goals.  Several policies in the draft ROP use the LEED® rating system to realize this goal.   Staff supports the objectives of these policies and applauds the Region for this bold initiative.  We note that LEED® is emerging as one of the more identifiable rating systems within the development industry.  It influences the market by distinguishing LEED® certified projects within the market in an effort to "accelerate global adoption of sustainable green building and development practices through the creation and implementation of universally understood and accepted tools and performance criteria."  However, the Region (in its September 2009 report) acknowledges that policies dependent upon the LEED® rating systems identified in the draft ROP, in certain circumstances, exceed Ontario Building Code (OBC) requirements.  Consequently the ROP recognizes the possible advantages of application of equivalent evaluation systems.   In addition to this work, the Region should encourage the Province to improve sustainable building design legislation and requirements through the Ontario Building Code. Markham continues to support the Region’s efforts in applying LEED®, or an equivalent evaluation system, and will join efforts to press the Province for appropriate amendments to the OBC.

 

The Town’s Sustainability office also suggests that the draft ROP include policy provisions to recognize the need for wildlife and regional or local trail crossings of arterial roads at appropriate locations that do not compromise good urban design.

 

Several other sustainability policy items have been identified in Appendix A and have been discussed with Regional staff. 

 

Agricultural and Rural Areas Policies

The policy approach taken in the draft ROP is generally consistent with the direction underway in the Town through the Agricultural Assessment Study.  The majority of the agricultural lands in the Town are identified as ‘prime’ agricultural lands, which has been determined through a recent Regional Land Evaluation Area Review (LEAR) study.  A very small pocket of ‘rural area’ lands are identified in the northwest corner of the Town contiguous with rural lands in Whitchurch-Stouffville.  The only major issue identified by staff is clarity and interpretation of the Agricultural and Rural Area designation, policies and mapping.  The designation shown on Map 8 does not address other designations such as Hamlets and the Regional Greenlands System.  In order to avoid direct conflicts, policies should be included to clarify the interpretation of the boundary or the mapping should be adjusted to reflect other regional designations. 

 

Additional technical and minor comments are provided in Appendix ‘A’ to this report.  Staff has discussed these items with Regional staff and are working together to address the policies.

 

Affordable Housing

Section 3.5 includes policies that establish targets for new affordable housing units across the Region (minimum 25% region wide and 35% in Regional Centres and Corridors), and distributed within each municipality.  The Region’s definition of affordable is based on the Provincial Policy Statement definition of affordable, with low and moderate-income households further defined as households with incomes in the lowest 60% of the income distribution for the regional market area.  It would be helpful to further define the level of affordability by identifying the percentile range for both low and moderate income households.  

 

Staff supports the provision of affordable housing in the Region and in Markham and the broad objectives contained in the draft ROP.  However, application of the affordable housing targets may present some challenges to Markham.  Markham land values and the rising cost of construction continue to challenge market affordability for both ground related housing and housing in intensification areas.  While the market may be able to provide affordable housing for moderate income households in Markham, provision of housing for lower income households will remain challenging.  For low income households, given the location and cost of construction, new affordable housing units will likely continue to be limited to social housing units reliant on funding or tax expenditures from senior levels of government.

 

Having regard for these challenges in providing market affordable and social housing units, Markham will endeavour to support the Region’s objective, from a policy perspective, to promote a mix and range of market responsive housing to meet the needs of our residents and workers.  However, in order to implement the Region’s affordable housing policies, the Town will require a commitment from the Region to provide an update to its region wide housing requirements study and housing supply strategy, and to develop a comprehensive and innovative affordable housing implementation and incentives framework.  In particular, Markham will be looking to the Region to provide guidance on the implementation of its housing policies and targets, including identifying any additional planning policies, strategic actions or funding mechanisms the Region, the Town and/or other levels of government could employ to encourage the private sector and other stakeholders to develop market affordable and social housing units. This information will assist the Town in developing a new affordable and housing strategy which will identify what policies will need to be included in the Town’s growth management strategy and new official plan to enable Markham to contribute its share of the targeted new affordable housing units across York Region. 

 

Secondary Suites

The draft ROP contains policies that require local zoning by-laws to permit a mix and range of housing types, lot sizes, unit sizes, functions, tenures and levels of affordability within each community.  In particular, there is a requirement for “as-of-right” secondary suite zoning on a municipal wide basis.  Although Markham currently has Official Plan policies permitting second suites, Council has not supported “as-of-right” secondary suite zoning on a municipal wide basis. The recent policy direction of Markham Council (May 2009) is to enforce current Town zoning by-laws prohibiting second suites.

 

Cultural Heritage Conservation

The Town feels that the draft ROP policies relating to cultural heritage could be stronger.  Staff has detailed comments and suggestions regarding the policies in the draft ROP in Appendix A.

 

The suggested feedback proposes modification to existing wording so as to better clarify current policies and offers a few new policies.  The new policies suggested are to identify specific tools provided in the Heritage Act that can be used by local municipalities, and to identify the opportunity for regional partnership in local financial cultural heritage programs. 

 

Town staff has discussed these policy items with Regional staff.

 

Water, Wastewater and Transportation

Staff has completed a comprehensive review of the Region’s Water & Wastewater Master Plan Update, along with the Region’s Transportation Master Plan Update while reviewing related policies in the draft ROP.  Specific comments on the Master Plan Updates will be forwarded to the Region under separate cover.  Staff is generally satisfied that there is consistency with these documents and the Town’s emerging Growth Management Strategy and related documents.  There will need to be however, some coordination in order to reconcile the differences in the land use projections, used by the Region with those used by the Town for its background studies to support Markham’s Growth Management Strategy. 

 

With respect to Transportation policies, Staff has the following major comments:

  • It is recognized that road capacity will be limited in Markham and priorities should be given to transit, commercial vehicles, and high occupancy vehicles.  Staff does not support the notion in the Master Plan Update of restricting delivery by heavy trucks to certain time of the day as this indirectly implies private vehicles have priority over commercial vehicles.
  • The Master Plan Update also identifies a number of commuter parking and carpool lots.  Staff feels that these large parking facilities should not be located within high density urban areas and should be relocated further away to the periphery of the urban area and along highway or arterial corridors.  This will encourage higher transit use to the transit nodes.
  • The current lack of transit fare integration is a major deterrent to transit use between York Region and neighbouring municipalities.  A greater emphasis and stronger polices are required in the ROP.
  • In order to promote alternative modes of transportation, Staff suggests that an additional policy be included to require Regional staff to work with local municipalities to develop alternative Regional street design parameters to encourage walkability and active transportation in nodes and along corridors.  These parameters would include lane width, intersection spacing, daylight triangle dimensions, boulevard widths, amongst others.
  • It should be noted that Markham Council has indicated their preference for dedicated bike lanes on Regional roads to be physically separated from cars.  As well, staff urge the Region to review a variety of cycling lane/path options and support integration with the local cycling systems.

 

Climate Change has been identified as an important force of change component that needs to be considered in the draft ROP document. The document has identified the need to mitigate the impacts of climate change. It would be helpful if the Region could elaborate on what protocols or strategies are being considered in the planning and designing of the water and wastewater infrastructure to consider the potential impacts from climate change.  Specifically a Strategy for Adapting to Climate Change in Water and Wastewater design standards and criteria needs to be developed.

 

Staff agrees that the Town and the Region need to coordinate the provision of water and waste water infrastructure for future development.  However, the Town seeks clarification around the future implementation of these polices.

 

Staff has identified a number of technical mapping changes in Appendix A relating to draft ROP Transportation and Transit maps.  For example the transit priority roads should be extended on Map 11 into the new communities, and the East Markham Mobility Hub in the Highway 7 and Don Cousens Parkway, Havelock Line, Highway 407 area should be shown as a study area which Markham Council has directed Staff to investigate. Staff has also identified to Regional staff that some of the mid-block crossings shown on Map 12 in Markham are not supported by Markham Council.

 

With respect to road widening projects, Staff will participate in a project evaluation committee to determine where Regional Arterial road projects can be supported.

 

Additional specific comments on water, wastewater, transportation and transit policy items are listed in Appendix A.  Staff identified these items with Regional staff and will be working together on them.

 

Study Requirements, Phasing Mechanisms and Implementation

Study Requirements

There are a significant number of plans and studies required in the draft ROP (eg. Mobility Plans, Community Energy Plans, Economic/Fiscal Impact Analysis, etc.).  The completion and review of Studies and or Plans will impact on Town resources and processes on a go forward basis. 

 

Several study requirements in the draft ROP need clarification.  The Region needs to identify who is responsible to carry out the studies, when the studies need to be done, what the specific trigger or mechanism to require the study is, who is responsible to review the study and/or approve it.  Staff believes it would be beneficial and user-friendly to introduce a new table in the draft ROP which summarizes all the studies identified in the Regional Official Plan, at what point in the development approval process they are required, and who reviews and approves them.  This would facilitate consistent implementation of the ROP across the municipality.  This table could also address consolidated studies where the Region and local municipality require a similar study to reduce duplication.

 

Appendix ‘A’ identifies when staff believes clarification is required with specific studies.  Town and Regional Staff discussed these issues and the Region committed to working together on a satisfactory solution.

 

Phasing Mechanisms

The Provincial Policy Statement requires that sufficient land be designated to meet the projected growth needs for a maximum time horizon of 20 years.  The PPS also requires planning authorities to establish and implement phasing policies to ensure specified targets for intensification and redevelopment are achieved prior to, and concurrent with new development within designated growth areas.  The draft ROP includes such a policy applying to new community areas but does not similarly address phasing in intensification areas.   It would be helpful if the Region could identify or provide a specific policy that would support Markham’s efforts to phase in development permissions for intensification and redevelopment.

 

Additional comments with respect to phasing and or sequencing plans are located in Appendix A.

 

Financial Management

The draft ROP’s financial management components are very similar to the Town’s financial  management components contemplated for inclusion in the Town’s emerging Growth Management Strategy.  Staff would, however, recommend to the Region an additional clause under Policy 14  that  considers not just the impact on operating budgets, but examines the alignment of capital expenditures to growth-related assessment revenues from a timing perspective. The timing of the capital expenditure should give consideration to the timing of new assessment revenues, in order to cover operating costs that result.  If the alignment is not close (e.g. a road is built but the comparable assessment growth that requires the road to be constructed doesn’t happen as quickly as expected), existing residents are then required to increase the amount of taxes they pay to cover the operating costs associated with the new infrastructure, in advance of the increase in growth-related assessment revenues.

 

Staff has brought this to Regional Staff’s attention.

 

Implementation

There are several specific comments and suggestions in the chart in Appendix ‘A’ which relate to the implementation of the draft ROP.  A consistent theme throughout relates to improved clarity, which will in turn facilitate consistent implementation as well as conformity by local municipalities.  Staff discussed these with Regional Staff and are working together on addressing the items of concern.

 

Definitions and Mapping

There is a need for additional definitions and/or more specificity in definitions provided to ensure proper implementation.  There are also various specific mapping corrections and clarification items have also been noted in Appendix ‘A’.  These items have been brought to Regional staff attention and they will be working with Town Staff to address them.

 

Conclusion

Staff has reviewed the draft ROP in the context and direction of the Provincial Growth Plan and the Town’s emerging Growth Management Strategy and associated background studies.  Staff is generally supportive of the policies and directions contained in the draft ROP.  This report highlights some of the Staff comments and suggestions [included in Appendix ‘A’ - attached] related to improving clarity of the draft ROP.  This report also highlights a few matters that Council may wish to specifically review and comment upon, in particular the urban boundaries which may be identified in the new ROP.

 

The Staff met with Regional Planning staff to discuss and review comments and concerns.  Regional staff committed to continue working with staff to address a number of technical requests.

 

FINANCIAL CONSIDERATIONS AND TEMPLATE:

Not Applicable.

 

 

HUMAN RESOURCES CONSIDERATIONS

Not Applicable.

ALIGNMENT WITH STRATEGIC PRIORITIES:

Aligns with Growth Management, Transportation and environment components of the Building Markham’s Future Together process.

 

 

BUSINESS UNITS CONSULTED AND AFFECTED:

Many departments across the Town reviewed the draft ROP and provided comments.

 

 

RECOMMENDED BY:  

 

 

 

 

 

 

________________________                        ________________________

Valerie Shuttleworth M.C.I.P., R.P.P                Jim Baird M.C.I.P., R.P.P.

Director of Planning and Urban Design              Commissioner of Development Services

 

ATTACHMENTS:

Appendix ‘A’ – Specific Staff Comments and Suggestions on the York Region Official Plan

 

Q:\Development\Planning\MISC\MI 528 Regional Official Plan\rop comments sept 24.doc