H350 Comments on the Engagement Plan

Submitted by Don McLean

Direction 1:
Plan for climate change mitigation and adaptation, and reduce greenhouse gas emissions.

This is out of date. We must eliminate greenhouse gas emissions, not just reduce them. The city has already committed to a detailed plan to reach net zero emissions by 2050, so allowing any additional greenhouse gas (GHG) emissions is counter-productive and will require future measures to eliminate them, probably paid for from the public purse.

Calculations must include not just the “end result of development” on newly urbanized lands but also take account of any construction activity related to these lands. And it should also include the carbon footprint of building materials. It is unclear what “reduce” means in this principle. Logic requires identifying the comparator. Reduce from what? For farmland, natural areas, and other rural lands, the minimum requirement is that whatever land uses replace these must result in less emissions than are currently coming from those lands. The calculation must include any loss of carbon sinks (wetlands, trees, etc.) If actual reduction of GHG emissions is deemed impossible, the land use change is likely inappropriate. Or compensatory measures are required such as funding GHG reductions in other parts of Hamilton.

Direction 2:
Encourage a compatible mix of uses in neighbourhoods, including a range of housing types and affordabilities, that provide opportunities to live, work, learn, shop and play, promoting a healthy, safe and complete community.

Not “encourage” but require, and not just a “compatible mix” and range of affordability, but at minimum accommodates the actual financial abilities of Hamiltonians. It should not make things worse. So if a third of our population can only afford to be tenants, then at least a third of the new housing should be rental and at a price that can be afforded. New development should not increase the percentage of Hamiltonians who are unhoused; it should do the opposite and actually reduce the percentage who are unhoused.

Direction 3:
Concentrate new development and infrastructure within existing built-up areas and within the urban boundary through intensification and adaptive re-use.

Yes, but also give priority to this objective over new development and infrastructure outside of existing built-up areas.

Direction 4:
Protect rural areas for a viable rural economy, agricultural resources, environmentally sensitive recreation and the enjoyment of the rural landscape.

Protection and enhancement of biodiversity should be part of this objective not just “recreation and enjoyment of the rural landscape”.

Direction 5:
Design neighbourhoods to improve access to community life for all, regardless of age, ethnicity, race, gender, ability, income and spirituality.

Direction 6:
Retain and intensify existing employment land, attract jobs in Hamilton’s strength areas and targeted new sectors, and support access to education and training for all residents.

The separation of “employment land” from residential and other uses is out of date and imposes unreasonable transportation requirements including associated infrastructure. “Complete” neighbourhoods should include employment.

Direction 7:
Expand transportation options through the development of complete streets that encourage travel by foot, bike and transit, and enhance efficient inter-regional transportation connections.

Yes, for existing neighbourhoods, but for new development there need to be specific objectives such as transit-supportive densities (at least 80 residents or jobs per hectare); and protected pedestrian and cycling on all streets; plus effective connections to existing and planned transit, cycling and walking routes.

Direction 8:
Maximize the use of existing buildings, infrastructure, and vacant or abandoned land.

This is open to mis-interpretation. What is “vacant”? Historically, we have followed the foolish objective of “highest and best use” defined generally as maximizing tax revenues. That’s why building housing on prime agricultural land was considered a good thing. It wasn’t and isn’t.

Direction 9:
Protect ecological systems and the natural environment, reduce waste, improve air, land and water quality, and encourage the use of green infrastructure.

Protect and enhance ecological systems and the natural environment. We have a severe biodiversity crisis already and that wording aligns with “improve air, land and water quality”. Instead of “reduce waste” it should be “avoid waste”. Require green infrastructure wherever possible to minimize climatic impacts.

Direction 10:
Maintain and create attractive public and private spaces and respect the unique character of existing buildings, neighbourhoods and communities, protect cultural heritage resources, and support arts and culture as an important part of community identity.

Other comments

First priority for growth must be within the existing urbanized area. Flood plain mapping must be updated, and a science-based estimation of how that might change under expected climatic changes. In the past, we have relied on historical experience of climatic events including maximum recorded stream flows, and expected flows during various storm events. This is helpful, but no longer sufficient, because it assumes limited climatic change and that is no longer reasonable. So we need to both recognize the changes in climate extremes that have already occurred in southern Ontario, and also extrapolate to potential/anticipated storm events under likely increased storm events. We construct buildings to last well over 100 years so we need to ensure they are protected from flooding and other extreme climate events that may occur over at least 100 years into the future. This needs a holistic approach. It is not sufficient to just examine flooding potential on the lands within the secondary plan area. We also need to consider the downstream impact of land use changes such as increased impervious surfaces, loss of wetland and/or riparian areas.

A specific “climate change scenarios” study needs to now be included in technical studies to fully inform the other technical studies.

What is the impact of Bill 23 on the role of Conservation Authorities that have been restricted from advising municipalities? If they are restricted, how will their expertise be replaced and by whom?

Ensure policies that minimize GHG emissions such as bans on fossil fuel hookups for new buildings, requirements for minimizing energy consumption by buildings (including commercial and institutional), in transportation, and other sources.

Proposed “balanced” approach to transportation is misguided and not forward looking. Our master plans already preference walking and cycling over motorized vehicles, rather than seeking a “balance” that has historically meant cars first and anything else if it fits into car dominance.

How will the city identify and evaluate wetlands and other natural features on ‘private’ property? With a climate emergency in place, it is critical that we have this information. Special steps should be taken to overcome any ‘privacy’ objections to gathering this information. I understand that Twenty Road West developers group are proposing replacing a provincially significant wetland with a stormwater facility. This type of degradation should not be permitted.

The planner’s “interpretation” of the climate change principle was very inadequate. Climate change affects everything, not just flooding potential. It sharply affects biodiversity. Emissions reduction is no longer sufficient. We need zero emissions as promised in the city’s climate strategy. That’s particularly required in new developments. We can’t keep patching up mistakes when we know how to avoid them in the first place. Vegetation cover, especially trees, are recognized by everyone as reducing heat island effects. There must be no net loss of landscape cooling effects. The city has policies in place to expand the urban canopy. Therefore there can not be any loss of tree cover, and instead the minimum requirement for new development should be at least a 40 per cent canopy cover as quickly as possible.

The “consultation” requirements with Indigenous peoples must respect United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) and the recommendations of the Truth and Reconciliation Commission (TRC). All these lands are treaty lands and therefore are the joint responsibility of Indigenous Nations and Settler regimes such as the city of Hamilton. This principle has long been ignored and abused but we are now clear that is not acceptable. The Haudenosaunee Confederacy Council moratorium on development in the Haldimand Tract lands serves as clear guidance for all treaty lands. There needs to be full, free and informed consent for developments that affect the treaty rights of Indigenous Nations such as hunting, fishing, gathering of medicinal plants, etc. Where landowners have ignored and damaged these rights, we should require at least that restoration is acknowledged as an appropriate part of any land use changes.

Ecological studies required for the secondary planning must encompass at least four field seasons of observations and data gathering. Many of the expansion lands have been severely modified by agricultural and other activities. These impacts cannot be simply ignored. Proposed land use changes need to rectify and restore ecological features. We can’t begin with accepting that agriculture-related modifications are an acceptable starting point for urban uses. The needs and impacts of these different uses are substantial, and accurate natural heritage protection should begin as much as possible with an understanding of the pre-agricultural situation. For example, the drainage modifications that may have worked for farming don’t change the underlying natural patterns, stream flows, wetland locations. Failing to recognize these will likely result in unfortunate post development results.

The full ecological impacts of landscape changes (for example to wetlands and riparian areas) need to be identified in advance of development and steps taken to ensure at minimum that ecological communities are not sacrificed or damaged. In many cases restoration of habitats and key ecological linkages should be the preferred solution.