Comments Received Regarding The London Plan - …...22,2014 First Draft version of The London Plan. While every attempt has been made to reflect all comments received, and to provide

Comments Received Regarding The London Plan - 1st Draft

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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur City 1 Did You Know?

infographicsSuggests reviewing the Post Carbon Institute's research and forecasts of growth and including these as additional infographics under "Did You Know" section.

Modified - incorporated infograhic relating to greenhouse gas emissions

Our City 1 Whole Part Integrate these mobility actions throughout the document. For example, in the Our City chapter, page 5, Policy 11 – add data on cycling and pedestrian use in addition to transit data

No change - data not available at this time.

Our City 1 Whole Part Where are healthy communities included in the Plan. How can the MLHU advocate for better? Modified - Green City chapter renamed Green and Healthy City and helathy city concepts integrated throughout the chapter

Our City 1 Whole Part Support for this Policy as an accessible plan and for Big Idea 12. Modified - Big Ideas deletedOur City 1 Whole Part Support for updating every 5 years. Speaks to the idea of adaptive management, evaluation of

new data, experiences and ongoing situation on the ground.No change - indicates support for the Plan.

Our City 1 Whole Part Consider re-naming London to "Forest City" No change - not within scope of Official Plan review. Though, given London's brand, the chapter on Urban Forest is an integral component of the City Building Policies in The London Plan.

General 1 Whole Plan The Plan uses different language relying on other supporting plans such as the Transportation Master Plan for specific targets and standards for cycling transportation modes. There is a greater emphasis on cycling as a mode of transportation with 100 specific references to cycling, biking, bikes, and related words which is four times as man in the current Plan. While there is emphasis on public transit there is limited Policy to integrate transit and cycling. There is no continuous defined east-west and north-south cycling routes through the City. It is unclear how emerging modes of transport such as scooters, electric bikes or segways are part of the transportation system.

Modified - revised to add a Policy to active transportation section under the Mobility Chapter.

General 1 Whole Plan Please provide M.I.T. Group Inc. with notices of all future meetings and documentation concerning the proposed new Official Plan, File No. O-7938. Thank You.

No change - noted.

General Comment 1 Whole Plan After much deliberation and conversation with our Board of Directors and senior staff here at LMHC, I am pleased to advise all concerned that LMHC is in full support of “The London Plan”. On behalf of LMHC I would like to personaly thank you, Heather, Sean and Gregg for your willingness to meet, explain, guide and assist LMHC in our understanding of this plan.

No change - indicates support for the plan

The purpose of this table is to assist those who submitted comments regarding The London Plan, to assess what changes were, or were not, made to the Plan by Staff between the 1st and 2nd Draft. This Table includes comments received for the 1st Draft (May 22, 2014) version of The London Plan, and provides a short description of how the issue or concern was addressed in the Second Draft (June, 2015). Comments that were submitted that did not include a request for change toThe London Plan may not been included in this Table. This Table includes comments received before January 31, 2015. All policy number references in this table refer to the May 22,2014 First Draft version of The London Plan. While every attempt has been made to reflect all comments received, and to provide a high-level summary of the action that was takent to edit the Plan, due to the exceedingly large number of comments received and number of edits to the Plan, there may be some omissions and errors. This table should only be used as a referebce tool. Only a full and detailed review of The London Plan can be relied upon to establish the policies that are included in the 2nd Draft of The Plan and to confidently identify where these policies differ from the first draft of The Plan.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanGeneral Comment 1 Whole Plan As London’s largest Social Housing Provider it is important that we remain strongly engaged in

all initiatives related to the plan, secondary or sub plans that may effect our properties and or our tenants. We, (LMHC) also respectfully submitt that any future versions of the Plan or sub plan(s) give consideration to the unique position of Public Housing (LMHC) in respect to our land holdings and our ability to regenerate or redevelope a community outside the normal restrictions assigned to a place type. We, (LMHC) may need to redevelop on existing land, changing building type to accommodate emerging needs in public housing and embed within the community certain support services to assist our tenants. We do not want to simply, when the opportunity emerges, be forced under a plan to rebuild as is. Even outside of any regeneration, LMHC may need to embed support services in a community for our tenants and we hope that we can do so without the need for re-zoning applications.


General Comment 1 Whole Plan We are also pleased to see the Plan notes the importance of supporting institutions through collaboration, funding for research and the allocation of other strategic resources.


General Comment 1 Whole Plan Western plays a strong role in the City’s goal to create economic opportunity by elevating London’s profile as a regional culture centre. Western supports the Plan’s emphasis on the importance of strong neighbourhoods as well as the corresponding improvements to mass transit.


General Comment 1 Whole Plan we have an overarching concern about how the policies will be applied in the immediate future. We note that “Transitional” (Clause 879) policies have been proposed for specificareas along Wellington Road, Warncliffe Road and Dundas St. that recognize that time will be requiredbefore the full weight of the Corridor policies is brought to bear on new development or redevelopment.It is our opinion that these policies should be broadly expanded to include much more of Wellington Road and other areas of the city.

No change - applies to lands where transition will take time and where large single use commercial buildings currently exist. Did remove pressure preserve policy for portion of Wellington Street

General Comment 1 Whole Plan The process of intensification is largely market driven and new multi-storey mixed use residential/commercial/retail development cannot adapt to an urban form until such time as external conditions such as the public realm are also transitioned and transit improved. While we are aware of the transit plans we have yet to see consideration being given to such vital matters as road width and on-street parking. It has been our experience that the type of pedestrian friendly development envisioned by the London Plan is not marketable or viable in suburban or transitional locations (General Urban Transect) without similar investment in the public realm. Is it not incongruous to be establishing urban Policy and urban forms of development for the same streets that you are also proposing to increase the width of the right-of-way?

No change - Environmental Assessment for rapid transit is underway. Plan sets context for public sector investment. Complete streets project will address.

General Comment 1 Whole Plan Furthermore, we would also suggest that the depth of the Corridors seems to reflect built form and doesnot allow for intensification much beyond the current commercial ribbon. The failure to provide thepotential for an adequate market to support the extent of the Corridors proposed only delays any opportunity in the near to medium term. Has any study been conducted to determine if the amount of mixed use development proposed is required or sustainable?

No change - spatial analysis indicates there is sufficient room for intensification along corridors


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanGeneral Comment 1 Whole Plan Adelaide Shoppers - 1104-1118 Adelaide St N. Questions:

g) Will Shopping Centres be permitted in the new OP (Urban Corridor place type)?h) Are department stores now defined within the retail use definition?i) Are Supermarkets/grocery stores now defined within the retail use definition?j) Are restaurants considered a service use?k) What will be the status of existing Secondary Plans?l) Has the gross floor area maximum restriction been removed? As the site is designated with the Urban Corridor Place Type and is located in the Near Campus Neighbourhood Area, are there any policies that apply to the site?

No change - Urban Corridor Place type permits commercial-residential uses

General Comment 1 Whole Plan BASELINE MEDICAL CENTRE – 746 Baseline Road East - Questions:e) Are drive-throughs permitted in the Institutional place type?f) What is the amount of retail space permitted on site? Does this include service uses?g) Are restaurants a permitted use?

No change - refer to place type polcies for permitted land uses

General Comment 1 Whole Plan Byron Village Plaza - 1240-1260 Commissioners Road W Questions:e) Will shopping centres be permitted in the Main Street Place Type?f) Are department stores permitted in the Main Street Place Type?g) Are grocery stores permitted in the Main Street Place Type?h) What types of residential uses are permitted?i) Are any Gross Floor Area restrictions being established for any of the place types?j) Are restaurants a permitted use?k) Has the Gross Floor Area maximum restriction been removed?


General Comment 1 Whole Plan HYDE PARK PLAZA – 1180 Oxford Street West Comments:a) Minimum and maximum height restrictions have been established. The minimum height is 1storey.b) Above-ground parking structures are permitted but shall not be allowed to have parking uses fronting onto streets at grade. Upper levels must have architectural treatments or other uses atthe street.c) Gross Floor Area maximum restriction for office uses has been added.d) Gross Floor Area restriction for typical commercial development has been removed.e) Drive-throughs are permitted but must be located away from the primary pedestrian oriented areas of the site


General Comment 1 Whole Plan STONEYBROOK PLAZA – 1593-1595 Adelaide Street North & 608 Fanshawe Park Road - Questions:f) Are department stores included in the retail use definition?g) Are home improvement stores included in the retail use definition?h) Are supermarkets/grocery stores included in the retail use definition?i) Are restaurants a permitted use?j) What types of residential uses are permitted? All?k) Has the Gross Floor Area maximum restriction been removed?l) If the Road allowance has changed between plans and is now of a greater range, does that mean more land is eventually going to be required?



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanGeneral Comment 1 Whole Plan SUNNINGDALE VILLAGE – 595-615 Fanshawe Park Road - Questions:

f) Are department stores included in the retail use definition?g) Are home improvement stores included in the retail use definition?h) Are supermarkets/grocery stores included in the retail use definition?i) Are restaurants a permitted use?j) What types of residential uses are permitted? All?k) Has the Gross Floor Area maximum restriction been removed?l) If the Road allowance has changed between plans and is now of a greater range, does that mean more land is eventually going to be required?


General Comment 1 Whole Plan WELLINGTON CORNERS – 631, 645, 673 Commissioners Road East - Questions:g) Will grocery stores/food stores, department stores, restaurants and Day Care be permitted in the Rapid Transit Corridor place type?h) Would the site (631 Commissioners – Residential Place Type) receive any secondary permitted uses as it is part of an existing commercial plaza which fronts onto Wellington Road South,which is identified as a Rapid Transit Boulevard (Table 13 does not identify any Secondary Permitted uses for the Rapid Transit Boulevard place type)?i) Would retail, service and office uses be permitted as the site is located on a Civic Boulevard which in turn does not permit retail, service and office uses.j) Would Medical/dental offices and clinics be permitted uses on the site (631 Commissioners – Residential Place Type)?k) What would the range of permitted heights be as the site fronts on a civic boulevard but is integrated within a commercial centre which fronts on both a Civic Boulevard and a Rapid Transit Boulevard?


General Comment 1 Whole Plan WESTMINISTER CENTRE – 332-352 Wellington Road South - Questions:f) Will grocery stores/food stores, department stores, restaurants be permitted in the Rapid TransitCorridor place type?g) What types of residential uses are permitted? Mid-rise, high-rise?


General Comment 1 Whole Plan how will amendments to the plan affect numbers in rest of plan? Modified - section numbers addedGeneral Comment 1 Whole Plan Subsequent re-write of policies - show the nature of change. Table format to show record of

change between draft and final version of the Plan.No change - not applicable to policies

General Comment 1 Whole Plan Affordability & Inventory of SFD lots and how that would be affected by intensification or trends how quickly can SFD be accommodated if there is a change in growth & propensity?

No change - a balanced approach and GMIS will dictate infrastructure expansion

General Comment 1 Whole Plan Trends of the future – affordable housing (90% sfd, etc.) as we direct development into other areas where the Plan is placing these uses

No change - commentary on proposed policy.

General Comment 1 Whole Plan People moving out b/c not much opportunity for a variety of SFD, like estate lot residential. No change - plan provides for variety of choice in housing (urban, suburban, rural settlement)

General Comment - Cover/icons and slogan.

1 Whole Plan 3 of 5 symbols are suggested for change. 1. Change the up arrow to arrows in a circle, speaks to cycles/ecology. 2. Change the Rapid Transit symbol to a person on bicycle. 3. Add a wind turbine/windmill to the symbol of the city's buildings. Change slogan from "Exciting. Exceptional. Connected." to "Resilient. Healthy. Prosperous."

No change - vision approved by council, symbols result of Rethink process.

Whole Plan 1 Whole Plan Recommendation #2a: The London Plan be amended to include reference and adherence to: Accessibility for Ontarians with Disabilities Act 2005 (AODA), The City of London’s Accessibility Plan, ‘Age Friendly London’ plan

Modified - City Design and Parks and Recreation chapters revised to esnure universal accessibility.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanWhole Plan 1 Whole Plan The London Plan, while extremely lengthy and broad falls significantly short of addressing the

needs of persons with disabilities and how the anticipated increased demand for accommodation and accessibility will be met within London over the next 20 years.

Modified - City Design and Parks and Recreation chapters revised to esnure universal accessibility.

Whole Plan 1 Whole Plan Recommendation #1: When accessible features or accessibility are referenced in terms of broader, general direction, the concept of universal design and access should be referenced. These design principles ensure general levels of accessibility are incorporated as standards within development.

Modified - revised direction #8, which over arches all of the planning that we do

Whole Plan 1 Whole Plan Recommendation #3: The following sections of the plan include a statement encouraging accessibility be included whenever possible, whereby the accommodation does not significantly alter the heritage/environmental site: Our Strategy (Direction 3 & 4), City Building Policies (Urban Forest, Parks and Recreation, Cultural Heritage), Urban London Place Types (Neighbourhoods - particularly in reference to trails and parks mentioned in Policy 921, Open Space, Environmental Review)

Modified - revised to address comment, added to direction #8

Whole Plan 1 Whole Plan Recommendation #2b: Specific mention be made that all City owned/leased development adhere to the Facility Accessibility Design Standards (FADS), in addition to those listed in recommendation 2a.

Modified - revised to require conformity with AODA Act

Whole Plan 1 Whole Plan Recommendation #4b: ACCAC further encourages the concepts of Universal Design and “Visitability” be incorporated in new developments. Visitability is an international movement to change home construction practices so that virtually all new homes, whether or not designated for residents who currently have mobility disabilities. Visitability ensure all units have 1) at least one barrier free entrance on an accessible path of travel (e.g. level path from parking to front door); 2) widened doors throughout the main level; and 3) an accessible half or full bathroom on the main level.

No change - meet requirements of the Building Code and AODA Act.

Whole Plan 1 Whole Plan Recommendation #4a: The London Plan should be amended to establish a minimum number of accessible units in new development. It is recommended that civic administration be directed to undertake a review of available information and statistics, as well as anticipated changes in population dynamics, to establish this percentage standard. ACCAC notes Canadian Mortgage and Housing Corporation and Statistics Canada may prove valuable in this review. [It should be noted the City currently has a definition of accessible units which could be applied here].

No change - accessible housing included in Homelessness Prevention and Housing chapter

Whole Plan 1 Whole Plan Recommendation #5: ACCAC encourages Council that, in collaboration with the adoption of this plan, it ensure sufficient financial and human resources are in place to mitigate the increase demands while simultaneously improving current conditions.

No change - Issue addressed through budget processes

Whole Plan 1 Whole Plan Mention of Pollinators can also be placed within other sections of the London Plan, such as in Urban Forest, Parks and Recreation, The Food System, and Urban Regeneration.

Modified - added reference for pollinators to Green and Healthy City, Urban Forest, and Parks and Recreation chapters.

Whole Plan 1 Whole Plan Include explicit language throughout the London Plan that reference the importance of creating suitable habitat for pollinators on private and public lands as well as reducing pesticide pressures.

Modified - added reference for pollinators to Green and Healthy City, Urban Forest, and Parks and Recreation chapters.

Whole Plan 1 Whole Plan Reference mobility options in the same priority order throughout The London Plan. Change p68, Policy 177_3, p70, Policy 192 and p352, Policy 1293 which have a different order. Use the order of pedestrian, cycling and transit to emphasize walkability and to align with numerous other references in the document. Reword p35, Policy 69 on the city’s street network mobility corridors to emphasize pedestrians first also recognizing the importance of flow of goods and services.

No change - order does not indicate priority

Whole Plan 1 Whole Plan ACE asks that a Complete Streets Policy be put into place in the near future. No change - complete streets project to be completed in near future


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanWhole Plan 1 Whole Plan Public transit carries approximately 12% of Londoners and active transportation (walking and

cycling) represents a further 9% at this time. The potential is there for more. ACE recommends an emphasis on improvements such as segregated bike lanes to make trips more enjoyable and safer and a Complete Streets Policy design approach to slow down traffic and improve our air. These approaches are not prominently referenced in The London Plan.

No change - complete streets Policy to be completed in near future.

Whole Plan 1 Whole Plan ACE cannot overly emphasize the value of a coordinated approach to street design standards to support pedestrian, cycling and transit priorities within neighbourhoods as highlighted on p57, Policy 144_8 and p67, Policy 172 which emphasizes mobility options.

No change - indicates support for the Plan.

Whole Plan 1 Whole Plan The London Plan is a professionally written document from city staff covering all city-subjects comprehensively. The document is excellent in both production and presentation terms.


Whole Plan 1 Whole Plan There is limited Policy to integrate transit and cycling, Modified - revised mobility policies to reflect commentWhole Plan 1 Whole Plan Keep the Policy approach simple for Council, staff and the public to understand and commit.

Cycling facilities should be focused in the core, where most cyclists are active vs cycling facilities in the suburbs where they do not cycle. The Plan needs to include an introduction that states the pedestrian cycling and public transit emphasis.

No change - emphasis is strong within mobility chapter

Whole Plan 1 Whole Plan support increased focus on cycling, No change - indicates support for the planWhole Plan 1 Whole Plan The Plan is lacking a directional statement for cycling No change - to be addressed in Cycling Master PlanWhole Plan 1 Whole Plan There is no continuous defined east-west and north-south cycling routes through the City, No change - to be addressed in Cycling Master Plan

Whole Plan 1 Whole Plan It is unclear how emerging modes of transport such as scooters, electric bikes or Segways are for specific targets and standards for cycling transportation modes.

No change - various modes addressed in Cycling Mater Plan.

Whole Plan 1 Whole Plan Need to establish consistent wording for NHS. Currently there are 28 terms/spellings used in LP Modified - revised plan for consistency

Whole PLan 1 Whole Plan needs to be consistency in terms wirth regards to open space, parks, natural heritage, and woodlands. Should distinguish between natural heritage areas and recreational park areas.

Modified - revised plan for consistency

Whole Plan 1 Whole Plan How does LMHC best support the LP? No change - does not address policyWhole Plan 1 Whole Plan where does the LP have opportunities or challenges for affordable housing No change - Housing and homelessness policies address

challengesWhole Plan 1 Whole Plan What are the best practices related to planning tools to support public housing regeneration?

What have other municipalities done?No change - housing development corporation is a leading edge concept.

Whole Plan 1 Whole Plan how does the LP include public housing, not just social housing in new developments? No change - housing programs support objectives of planWhole Plan 1 Whole Plan if LMHC is locked to their existing sites, would there be an ability to intensify development? No change - intensification may be permitted, based on applicable

place type and other policies in the planWhole Plan 1 Whole Plan how do planning tools reduce redevelopment pressure on social housing? No change - issue addressed in Homelessness prevention and

housing chapterWhole Plan 1 Whole Plan what are the next steps in the planning process related to the approval of the official plan? How

does LMHC stay involved as a stakeholder? What secondary plans should they participate in? what are the timelines?

Modified - added monitoring program policies in Our Strategy

Whole Plan 1 Whole Plan there have been issues under the current op/zoning with service delivery to a broader communities. What exceptions can be permitted in the plan to accommodate these needs

no change - new plan provides policies for future development

Whole Plan 1 Whole Plan what mechanisms exist for LMHC to pursue lands in high density areas such as transit villages or rapid transit corridors?

No change - operational issue, not addressed in plan


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanWhole Plan 1 Whole Plan If LMHC requires additional lands in the future, how could they ensure they are afforded fair

opportunity to aquire lands?No change - operational issue, not appropriate for official plan policy

Whole Plan 1 Whole Plan What optons are available to support mixed uses No change - plan supports mixed use devleopment in a variety of place types

Whole Plan 1 Whole Plan what exemptions can and should be in place to ensure LMHC can redevelop existing communities at higher densities and mixed use?

No change - policies of London Plan set appropriate development guidelines, bonusing may be applied where approrpaite per the policies of the plan

Whole Plan 1 Whole Plan how does this impact existing affordable housing? Their needs and existing land use plans? No change - policies support new affordable housing units

Whole Plan 1 Whole Plan Where would interested parties look for land designated for affordable housing, noting that if lands are designated for as hubs or corridors the market value may change.

No change - zoning to be updated after approval of London Plan

Whole Plan 1 Whole Plan Will future zoning requirements restrict community-situated services such as small-scale retail outlets, service-type enterprises, community services, and full-service site offices? It is not currently permitted to deliver on-site services.

No change - zoning to be updated after approval of London Plan, plan allows community facilities in neighbourhoods

Whole Plan 1 Whole Plan TLP provides Policy support for several programs and services that MLHU delivers to the London-Middlesex community including but not limited to environmental health, chronic disease and injury prevention and family health promotion. Many of the policies contained within TLP align with and enhance public health’s mandate.


Whole Plan 1 Whole Plan Since the completion of the Draft London Plan, please note that there have been a number of changes to the names of the Provincial Ministries. When referencing the names of a particular ministry in the new Official Plan, the proper reference should be made. Also, we note that the new Provincial Policy Statement 2014, came in to effect shortly before your release of “The London Plan” draft.

Modified - appropriate names incorporated, wording revised for consistency with PPS

Whole Plan 1 Whole Plan The London Plan represents a drastic change from the look and feel of the previous Official Plan and Official Plan documents in general across the Province. Through Policy 1307, it states that the document is more than a set of individual policies and that it should be read in its entirety and that a decision maker should read all of the relevant policies as if they are specifically cross-referenced with each other. While MAH is in agreement that the document should be read in its entirety to fully understand the relationship between policies, etc., the nature of the document and the length makes this very difficult. Many sections of the Plan also appear to be repetitions and/or lacking clear linkages to other policies in the Plan that would assist the reader in making the appropriate references to other sections/policies.

Modified - expanded "how to use this plan" (under policies 30 to 38) and incorporated policies that point to other relevant policies in the Plan throughout

Whole Plan 1 Whole Plan The broader concerns stated above could potentially be addressed through some formatting and structure changes to the Plan. We have worked with the Provincial Policy Branch of our ministry regarding these concerns and would suggest some further discussions with the City to determine what could be done to alleviate these concerns. As the document currently stands, there could be some issues with the implementation of the policies and may create an increased workload for City Staff in assisting the public in making the linkages between policies.

Modified - expanded "how to use this plan" (under policies 30 to 38) and incorporate policies that point to other relevant policies in the Plan.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanWhole Plan 1 Whole Plan Through consultation with the City of London on the London Plan, it is understood that much of

the terminology that is typically used in land use planning documents has been distilled to create a more “plain language” document. While this may assist the reader in understanding the general concepts of the Plan, this can create confusion with respect to ensuring consistency with the PPS. Some of the general comments from the Provincial Ministries reflect this as there are defined terms within the PPS that the Ministries would like to see transferred to the London Plan. This is not to say that plain language cannot be used within the document but instead that the policies within the document that ensure the protection of Provincial interests should have language that is consistent with the PPS.

Modified - incorporate PPS language, as required, while balancing it with plain language to assist the general public with understanding the intent and purpose of the given Policy

Whole Plan 1 Whole Plan Clarify what we mean by Neighbourhood - for example, define more clearly what is intended between planning districts and complete neighbourhoods.

Modified - revised to improve clarity

Whole Plan 1 Whole Plan City should expropriate or otherwise require lands for community uses based on clear and transparent plans.

No change - acquisition policies addressed in Our Tools.

Whole Plan 1 Whole Plan City should seek opportunities for partnership with landowners to attract new businesses to the City.

No change - consistent with Direction No. 1_6 (Plan Strategically for a Prosperous City)

Whole Plan 1 Whole Plan City should wait for industrial land strategy (ILDS) to be completed before finalizing london plan No change - ILDS to implement The London Plan. Policies and growth boundary expansion consistent with ILDS

Whole Plan 1 Whole Plan City should respect provisions of the previous Town of Westminster plan policies. No change - matter addressed as part of Vision '96 review process/OPA 88.

Whole Plan 1 Whole Plan City should meet with affected groups whose lands are adversely impacted by the plan No change - public notice and consultation has been completed in accordance with Planning Act .

Whole Plan 1 Whole Plan Plan should provide details on costs, implementation timing and strategy. No change - strategic directions outline overall directions. The London Plan has a 20 year time horizon.

Whole Plan 1 Whole Plan How is the City going to deal with future engagement for neighbourhoods, specifically for applications going forward?

No change - Our Tools & Urban Regeneration policies address public engagement.

Whole Plan 1 Whole Plan Additional glossary definitions should be added. Modified - glossary to be expanded to include additional termsWhole Plan 1 Whole Plan need to be consistent in terminology for parks, open spaces, environmentally sensitive areas,

etc. this includes when terms are capitalized.Modified - revised plan for consistency

Whole plan 1 Whole Plan consider including linkage polices such as those provided from the Hamilton Official Plan. Modified - revised to address comment

Whole plan 1 Whole Plan Include flexibility in distance requirements for an EIS - it includes language that allows an EIS to be required even if outside the established minimum separation. Samples policies provided from Elgin County and City of Kingston.

No change - policy consistent with Natural Heritage Resource Manual

Whole Plan 1 Whole Plan Add section to encourage and support community and neighbourhood associations. No change - not an Official Plan issueWhole Plan 1 Whole Plan Include policies that prohibit roadblocks from the City that prevent access to services and

amenities, to avoid situations similar to the Stoney Creek North Area Community No change - operational issue not for Official Plan policies

Whole Plan 1 Whole Plan on The No-Growth Imperitive (book) - this may be a minority position among planners at present, but the writing is on the wall. Hopefuly this will be commonplace by the next update

No change - does not address policy

Whole Plan 1 Whole Plan Terminology to be Clarified• Fit• Built Area Boundary versus Urban Growth Boundary• Mobility - Notes with asterisks within the tables to be clarified• Mobility – Terminology in the Legend for the tables need to be changed

Modified - glossary to be expanded to include additional terms. Some terms defined in context


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanWhole Plan 1 Whole Plan consider making public a copy of the "where did I go" Policy from the current plan to the London

Plan - comparison evaluation.No change - does not address policy, for consideration as part of implementation & monitoring phase of The London Plan.

Whole Plan 1 Whole Plan Wording around natural heritage is too weak - too much us of 'may' instead of 'will'. Modified - chapter revised to allow flexibility where appropriateWhole Plan 1 Whole Plan Street and intersection designs should create an environment of zero automotive fatalities. This

can be achieved with design tools available to engineers.No change - design standards issue

Whole Plan 1 Whole Plan increase consultation with surroundng municipalities to ensure a colaborative regional approach to planning. Need to reach out to londoners who have not participated in process.

No change - London plan includes policies to encourage such collaboration

Whole Plan 1 Whole Plan LAPC believes that an Official Plan should not have to be amended as often as the existing Official Plan. LAPC understands that the City Staff have a similar goal. Do we know THE BASIC REASONS WHY SO MANY AMENDMENTS HAVE OCCURRED?

No change - London plan provides a range of uses and flexibility to reduce the need for amendments

Whole Plan 1 Whole Plan Some “dollar costing” of the London Plan needs to be calculated. Specifically, many studies and guidelines are identified and exist but there are more to be prepared and these should be listed and “costed”. For example, neighbourhood design guideline (144), a parking master plan (224), bicycle master plan (213), Transportation Master Plan updates (190), urban regeneration program ( 162) etc. At the same time should we ask the question, “do we need these guidelines?” or “are the policies in the OP sufficient”?

No change - these studies will be funded and prepared over the course of the plan and within budget allowances determined by the Council of the day and their budget priorities.

Whole Plan 1 Whole Plan Include cost estimates of the effects on taxpayer dollars, housing prices, tax revenue, and servicing or maintenance costs that will result from new policies. Eg - there is a higher maintenance cost for single-loaded roads that abut open space as compared to a double-loaded road.

No change - Issue addressed in background discussion papers

Whole Plan 1 Whole Plan lack of transit to industrial areas is an issue - especially for shift work schedules. Language regarding provision of transit should be stronger.

Modified - revised to address comment

Whole Plan 1 Whole Plan Why does the LP not have a section dedicated to employment in response to the importance the PPS puts on the following directives? (strong and competitive economy for the long term.”, healthy, liveable and safe communities are sustained in part by employment and facilitating economic growth.”, discourage “development and land use patterns that would prevent the efficient expansion of settlement areas in those areas which are adjacent or close to settlement areas.”, and shall be the focus of growth and development and their vitality and regeneration shallbe promoted.”)

Modified - prosperity policies revised to increase emphasis on economic considerations. Prosperity is direction #1

Whole Plan 1 Whole Plan Reorganize Plan to be divided into chapters based on first 3 years, etc. over life of 20 year Plan.

No change - plan to be implemented through other plans, initiatives, strategies, budgets, etc.

Whole Plan 1 Whole Plan Wonderland Road and 401/402 - London has an opportunity with the planned improvements to interchanges at VMP, Wonderland Road, and Talbot. The City should link the general comments on economic health to Highways 401/402. This would improve the employment base and competitiveness to attract industrial uses.

No change -suggestions inconsistent with Industrial Land Study and Urban Growth Boundary expansion adopted by Council

Whole Plan 1 Whole Plan Wonderland Road and 401/402- The 401/402 corridor should play a more prominent role in the layout and structure of the London Plan. Lands adjacent to the corridor should be reserved for industrial uses. Currently there are lands not included, which will just have to go through the industrial area expansion process at the next OP review in 5 years.

No change - policies consistent with vision of plan

Whole Plan 1 Whole Plan Adelaide and Richmon Street rail crossings - does plan deal with it? No change - too specific for Official Plan policies, may be addressed in environmental assessment

Whole Plan 1 Whole Plan Minimize the prescriptive language within the Policy framework and provide additional direction for undefined terms and concepts

Modified - plan revised to increase flexibility where appropriate


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanWhole Plan 1 Whole Plan The term “daycare” is also now considered a negative term in our “child care” system. In places

that refer specifically to daycare for children if we could change the language to reference “child care” instead it would be appreciated. We understand that the term daycare now includes adults so it may be difficult to change this as it now has a specific definition in the zoning.

No change - intent is to avoid age-specific reference as daycare can be for adults and seionrs as well as children.

Whole Plan 1 Whole Plan Please include consistent terminology referencing SWM 'facilities' as opposed to ponds No change - both terms used in PlanWhole Plan 1 Whole Plan Modify the way that corporate wide asset management is dealt with and how this new program

will be imbedded in future planning initiatives. Modified - revised throughout plan

Whole Plan 1 Whole Plan In responding to ReThink London Discussion Papers, CCAC is focusing on the broader perspective of:• “What are the key elements of a child friendly city, today and 10-20 years from now?”• How can “children” be made visible in the city plan and be used as a reference point for planning and decision making?In responding to ReThink London Discussion Papers, CCAC is focusing on the broader perspective of:• “What are the key elements of a child friendly city, today and 10-20 years from now?”• How can “children” be made visible in the city plan and be used as a reference point for planning and decision making?


Whole Plan 1 Whole Plan Overall the CCAC is very pleased with the Vision and Directions and congratulates ReThink London on the successful community collaboration that has taken place. Licensed, community based early learning and child care in London has a history of strong community collaboration and supporting initiatives that benefit children and families.


Whole Plan 1 Whole Plan MAH also questions whether more fulsome policies should be developed regarding First Nations consultation. There appears to only be one Policy within the entire document that speaks to First Nations interests and the Policy only indicates that the City will “liaise” with First Nations in the area on land use planning documents that it feels they have mutual interest and/or concern. Our comments to the City of London on December 12, 2011 recognized First Nations consultation and recommending “that the city consider engaging with First Nations communities at this stage to ensure that the appropriate dialogue can occur to ensure that meaningful consultation occurs prior to adoption of the official plan update”. MAH staff would be happy to meet and discuss this process with City staff and provide examples of policies that have been developed by other municipalities through their Official Plan reviews.

Modified - revised to include policies on First Nations consultation through best practice review of other Ontarian municipalities.

Whole Plan 1 Whole Plan Within the Plan, there also appear to be a number of policies that speak to the creation of buffers and/or mitigation measures for residential, commercial, or institutional uses (i.e., group homes, correctional and supervised residences, methadone clinics and methadone pharmacies). It would be appreciated if MAH could obtain some additional background information on the land use planning rational for including these policies.

No change - Methadone clinics and pharmacy policies were addressed in a recent study, public process and OMB Hearing. The policies are carried over from the current Official Plan, adopted in a recent amendment to the current Plan

Whole Plan - pictures 1 Whole Plan Likes most pictures. Page 49 & 50, should replace "prison-like subdivision with no trees"; replace p. 84, need better picture for natural heritage. P. 157 picture is awful, sterile SWM. Page 190 better picture needed for sustainability, please. page 236 awful picture for main street place type.


Our City 1 Paragraph 1: Responding to question "How should we grow?": More important question of "how can we prosper?" and "Will I raise family in healthy/safe environment?" This is OUR plan as citizens, not planners' or developers' guide to growth, so should start with question average citizen would ask.



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanWhole Plan 1 Many high rise buildings are used for antennae, be they satellite, cell phone and so forth. These

have the potential to interfere with the City radio system and the quality of radio transmissions possible in the building they are sited on. Prior to any such approvals it would be preferable if the possible impact on the radio system be considered.

Modified - revised Our Tools policies - to be considered in planning and development applications.

Whole Plan 1 The City radio system is used by London Police, London Fire and the Cities Engineering and Environmental Services Division. The system utilizes microwave signals to connect the various radio towers across the City. The waves travel in point to point form (direct from one tower to the next). Development that is built directly in the path of these could impact the quality of the radio system.

Modified - revised Our Tools policies - to be considered in planning and development applications.

Whole Plan 1 Large buildings, such as high rises, arenas, casinos and the materials used in their construction, can affect the quality of radio transmissions for emergency responders. Some Fire Departments have been able to have request, during the approval process, that developers supply and install radio repeaters in their buildings, in order to aid radio communications. If this request could be made of developers here too, it would greatly enhance the quality of radio communications in those buildings for both London Police and Fire

Modified - revised to include policy in Our Tools Part

Our City 2 Policy 2: change ending to capital 'W' and add quotation marks, so reads: … "What kind of city do we ant to live in 20 years from now?"

Address consistencies / close with quotation mark at end of sentence

Our City 3 Paragraph 3: add new last sentence: "As a result, this document records the evolving vision, concrete plans, needs and wants of all Londoners and not just certain sectors of society. It has been written with the ethos of reflecting that the Plan "belongs to" all Londoners and to instill a sense of ownership and personal stake in the implementation of the Plan."

No change - implied that everyone was involved to some extent is adequately covered under this Policy

Our City 4 Paragraph 4: Likes word "evolution" because includes periods of contraction as well as growth. Should not at end of paragraph 4 that "this is not the politicians', nor city staff, nor developers, nor big business owners' plan. This is all of our plan, the citizens of London"

No change - Policy 22, among other policies throughout the Plan, indicate that this is a Plan for "all of its citizen"s, or that it is a "plan for everyone"

Our City 5 Somewhat misleading to state that the last plan was set in 1989, as it has been reviewed, substantially updated and amended on several occasions, particularly after Vision 96.

No change - the vision and strategic directions, which were the basis of the updates/amendments, of the current Official Plan was set in 1989

Our City 7 We currently don’t have a “spread” pattern of growth and the current OP will not permit it. Modified - clarify the current pattern of growth

Our City 7 Under 7. Managing Costs of Growth: good to note benefits of compact city, but new subdivisions will create future financial liability to run infrastructure system. Already troubles retrofitting old infrastructure systems.

No change. New subdivisions will contribute to the compact city design pattern

Our City 8 For 8. A Growing Seniors Pop'n: The age-friendly community (last sentence) should be added also to the Vision section.

No change - already captured under Our Strategy - Direction 5 (49_6)

Our City 9 Source regarding stats about milennials migrating away from the automobile - regional? Rural vs Urban? Need to flush out details for statistic.

No change - the source was collected as part of discussion paper for ReThink London


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur City 9 My grave concern with all of this overfocusing on one or two demographics to the exclusion of

others. Yes, Millennials are important, but we were all "Millennials" at one point -- we preferred downtown living, public transit, etc. because that was our experience, our friends were all together, and that was our financial reality.

As we age, our priorities change. That back yard in the suburbs looks appealing when you have kids. Offering programs outside the core is important, because you want to stay and support your community. There has to be a balance as we need a city that's appealing for everyone from youth to retirees. It's not enough to make them want to come and stay in their early 20s... how do we keep them into their 40s, 50s, 60s, and beyond?

No change - see policy 8 and 10, which recognize baby boomers and new canadians. Focus is shared. The London Plan is intended to address all ages and demographics.

Our City 9 The London Plan may be disproportionately focusing on the Millennial demographic ( 15 to 35 years) and that assumptions such as long-term inclination for more “downtown living” or living in a Rapid Transit Village, may be an inaccurate -- – choice of housing/lifestyle/ vehicle/ auto license, etc. These matters may be more influenced by economic circumstances and “delayed” child rearing than actual personal preference. Perhaps the Millennials simply cannot economically afford to consume more? Perhaps the Millennials are not demanding ground oriented family housing because they are not having children until they are in their 30’s .

No change - Section is based on current trends. The Plan allows for lots of choice for all Londoners.

Our City 9 In London housing is very affordable compared to larger Cities (Toronto) where the millennial folk are living in small condos apartments without vehicle ownership. It is simply too expensive. In London, the Millennial folk have greater choice and not have to reside in a 500 sq. ft. condo apartment at a cost of $500,000. Alternatively, they can purchase a single detached home for that amount –either in the inner city or suburbia – and a automobile too. This has significant implications for realizing the development of high density mixed used corridors for transit and thereby the success of RT.

No change - provides general preferences of millenials

Our City 9 For 9. Preferences of Millennials: reference to "less automobile focus, env'tally conscious, seek urban evn't and focus on connection through social behaviour/use of technology" should also be in Vision section.

No change - already captured under Our Strategy - Direction 4 (48_2 & 3) and Direction 7 (51_4)

Our City 10 For 10. Growing Diversity: Should add new last line that because of London's moderate climate, there may be significant numbers of "climate refuges" with climate change further south.

No change - the intent of this Policy is to identify at a high-level that there will be an evolution to greater diversity in London. The statistical analysis Our City chapter is based on Census data and the National Housing Survey.

Our City 11 Transit ridership is up by 85%. Imagine what would happen if we had BRT and proper coverage of industrial areas. How much of Innovation Park is devoted to worker parking? Moving from Hub & Spoke to a nodal design should be a high priority.

No change - consistent with policies in Our Strategy, City Structure Plan, and City Building Policies on Mobility

Our City 11 Transportation: include reference to high speed rail linkages to region and major economic engine - GTA)


Our City 12 For 12. New Demands for Urban Living: Trend of desire to move back to urban core is significant, but need Policy to ensure it's not accommodated in highrises but rather 4-6 storey apartments that can still function in the grid goes down. High rises will be unliveable by the 2050s.

No change - other applicable policies address these matters. Variety and choice of housing type is provided by the Plan.

Our City 13 Policy 13: change "Finance, Insurance and Real Estate industry has consolidated" to "Finance, Insurance and Real Estate industries have…"

No change - "Finance, Insurance and Real Estate industry" is an industrial classification

Our City 13 For 13. Economic restructuring: there is a reference to rising energy costs in Ontario. Need a section on energy as energy is basis of the economy.

No change. Addressed under Policy 13 and 17 and within many parts of the Plan.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur City 14 For 14. Infrastructure Gap: In reference to "State of Infrastructure Report": need to start

including ecological value of things like trees/wetlands. Use the Urban Forestry figures for value of the urban forest.

No change - London Plan references trees as infrastrucutre. The Corporate Asset Management Plan recognizes the infrastructure gap of the urban forest.

Our City 14 Policy 14: word "the" redundant. Delete word "the" from first sentence that reads "...evaluated the London's $10.9 billion…"


Our City 14 Suggest strengthen by adding 'Londoners want their quality of life to improve and recognize the risk that infrastructure can degrade over time. The City is developing stronger asset management practises specifically to prevent infrastructure degradation through enhanced methods, innovative funding and creative use of the city's infrastructure.' Highlight the importance of sound infrastructure to the economy, environment, health of the public … or is this where we outline a simplistic strategy? Creative financing, innovative methods, enhanced management to acheive sustainability.


Our City 15 For 15. Affordability Challenges: last sentence re: "ensuring housing affordable for all": this is great for the Vision section.

No change - reference included under Our Strategy Direction 1

Our City 16 It is relatively easy to determine the actual percentage breakdown of the various Canada Land Inventory (CLI) soil rating classes that exist in London outside of the built area boundary. The Ministry feels that this might prove a useful GIS exercise, and the resulting statistics could modify the text of this section to include the actual %’s. RECOMMENDATION: OMAFRA recommends that the City undertake a quick GIS exercise to determine the % of CLI classes within the municipal boundary, but outside of the built area boundary. OMAFRA is available to provide data, and GIS assistance where necessary.

Modified -revised to address comment and modified infographic

Our City 16 For 16. Protecting our Farmland: supports concept of ag. Land as a precious commodity and suggests new ending to final sentence "…hub and also build on a vibrant and strengthening organic farming and gardening movement that puts the health of land and people first."

No change - addressed under Food Systems

Our City 17 to 18 After 17., add new section on Energy: "Energy is the basis of our economy. Higher fuel and electricy prices ripple through the economy. Where are we in peak oil? How should we organize the city to withstand higher prices? Compact development, renewable energy, refurbishing old buildings." Prof. Sass suggests he draft this section. Also suggests he draft new section on Biodiversity.

No change - policy relates to climate change and not energy. Covered by Green City policies

Our City 17 For 17. Climate Change: add new last sentence "London will aim to meet CO2 reduction targets by 2035 that are based on latest scientific findings (80% reduction over 1990 levels by 2035)."

Modified - monitoring section added to Our Strategy part of Plan

Our City 17 Climate change: refer to resilience, a broader strategy than protection against climate change. Resilience is broader than the green strategy and should be included in city design, structure and building policies. (from meeting: add reference earlier)

No change - addressed in Direction #8

Our City 18 For 18. Shaping our City for Prosperity: after "shaping our personal health and wellness" add "as well as those of local ecosystems"

Modified - section re-written to address concerns

Our City 18 Consider adding that 'the City needs to provide stable services supported by appropriate infrastructure to maintain the quality of life.'


Our City 20 For 20. Add reference to "Londoners want our city to be prosperous/offer opportunity, employment, quality of life/wellness" to Vision section.

No change. Addressed under Policy 45 - Direction 1 Plan strategically for a prosperous city. Have enhanced reference to prosperity throughout the Plan.

Our City 22 Building London: jobs are key; reference to diversity (from meeting: attractive for business that result in more job opportunities/availability. Western- integrate with community to make for a better experience)



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur City 22 Add 'supported by reliable and efficient infrastructure.' Modified - revised to address commentOur City 23 _1 Add a new Policy for 23.1 stating: Planning for an ecological city… name of Forest City, an

ecosystem in every sense of the word, recognizes human activity dependent on economy of nature - resources in, wastes out.

Modified - removed big ideas

Our City 23 _1 Current Policy 23.1 has economic development first. Why always list economy first? In vision statement we put health and environment first, but in the "to do" list economy is first. Economy is wholly subsidiary to natural environment/economy of nature. Economy of nature should be first on list, hence suggested new Policy 23.1 above.


Our City 23 _4 Referring to Flexibility and Mix and the "mix of uses to support 'complete communities'": Believes this is a huge shift and yet there is only one example in subsection 4. There are other more significant changes such as based on street type and that you can have small commercial and office in a neighbourhood.


Our City 23 _5 OUR CITY -– Page 9 - Big Ideas -- Clause 23 – item 5 -- Has there been enough recognition of the continued use of the automobile which is quite likely the preferred and main mode of transit by Londoners for some time? This is likely more realistic, until the RTS has been built and the associated land use there along evolved. Perhaps the Plan should recognize that automobiles are not just a means of transportation, they are integral to our culture for many? People like to drive.


Our City 23 _6 add that Urban Design Guidelines should be developed for each Place Type (and sub-type as similar types have different issues across the city). Strong consideration should be made to include reference to design guidelines related to these issues, and as a big idea. Refer to Policy 1324.


Our City 23 _6 Planning by place type: reference is to city as a "collection of places" asks if this is meant to be "place types". Also suggests that since "Place Type" is something specific within the Plan, whether it should be written in capital letters every time the term Place Type is used.


Our City 23 _7 We recommend that climate change be included, as evidence from MLHU’s Assessment of Vulnerability to the Health Impacts of Climate Change in Middlesex-London (October 2014) suggests that risks to the health of Londoners from climate change will be increasing in the coming years.


Our City 23 OUR CITY -- Page 9- Big Ideas - we note there is a difference between the 12 items in the presentation of October 29th and perhaps it would be helpful to separate BIG IDEAS on “substantive” topics ( eg. economic development, transportation, neighbourhoods, intensification) and “process and context” (eg. Accessible plan, flexibility versus certainty).


Our City 27 29 For "Realizing the Plan" section, should have a bullet on "targets" and how policies have been crafted to meet those targets. If targets are not met, explain what consequences would be. Add "Targets" under the "Our Tools" section.

Modified - added policy regarding performance measures

Our City 28 The role of the private sector, individual property owners and the land development industry needs to be better set out in terms of definition, and contribution. The implementation of the London Plan is dependent on this and the London Plan gives the impression that the City plays the major role. Clause 28 (page 10) is insufficient.

No change - development industry is identified in Policy 28 as a key contributor to this Plan. Agree that private sector is vital stakeholder that will contribute greatly to delivering The Plan.

Our City 28 Two comments regarding Policy 28: First, What about Council (they are not listed in groups that will achieve the vision of the Plan)? And second, Does not believe that the aspirational goal of this being the community's plan has been achieved. States it would have helped if there were consultations will all the groups mentioned in Policy 28 once the draft was brought out.

No change - Policy 27 is intended to address Council's role - clarify Policy to be more apparent. Policy 28 is intended to convey that The London Plan has been achieved through extensive consultation of Londoners.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur City 28 For 28, why is "development industry" listed first? Citizens of London should be listed first.

Does not reflect vision/values of plan to list developers first.No change - All groups are listed, but in no particular priority or order

Our City 30 States that “all of the graphics... including maps, schedules, diagrams and illustrations shall be considered part of this Plan”. How are they to be reviewed, modified, updated etc. if they are unsatisfactory or become outdated? Suggests that graphics and illustrations, unless part of the Schedules where they can be easily found and referred to, should be illustrative in nature, not considered as Policy.

Modified - made changes to clarify what is or is not part of the plan. Most graphics now numbered

Our City 34 For 34., really likes that Plan has been written to reflect that LP belongs to all Londoners and instills ownership/personal stake in implementation. Suggests this reference is moved up to Policy 3.

No change - but modified the policies that relate to "how to use this plan" to be more accessible

Our City 37 For 37., thinks the 8 major parts are clear organization that makes a lot of sense. No change - indicates support for the PlanOur City 40 Policy 40 states that many policies were not carried over from the 1989 OP. He states that it

would have been helpful to have the document that shows these policies. By calling it an internal document it seems like something significant is being hidden.

No change - priority was given to providing detailed response to each of the comments received on the draft of The London Plan. T

Our Strategy 41 Whole Part Vision ("Exciting. Exceptional. Connected.") is lacking. These convey no real meaning. All cities believe they are exceptional. Suggest different symbols as well. Suggest adding "principles", e.g. "generation of little or no waste"

No change - principles addressed under the Values and the eight Strategic Directions of The London Plan.

Our Strategy 41 Whole Part Directions how relevant and how do they apply? No change - addressed in policy 38. Directions are applied by policies of the Plan.

Our Strategy 41 Whole Part Need to change the way that we tie planning applications into 8 key directions No change - Policies of this Plan are designed to further the 8 key directions - from City-building, to Environmental, to Place Type, to Our Tools policies

Our Strategy 42 _5 For 42.5, suggests changing "Be innovative" to "Be creative. No change - reference to creativity is captured in the Policy text

Our Strategy 42 _6 Add new 42.6, stating "Be flexible - world is in flux, infinite growth on planet is not feasible. So to meet challenges of next 20 years, need to be flexible as possible to stay functioning as viable city where well-being of citizens is maintained".

Modified - added "think sustainable"

Our Strategy 42 Add "think sustainable" - financially, infrastructure, themes and water quality… everything that we do.


Our Strategy 43 Update vision to: "London will be a friendly city that allows people of all ages and abilities to experience health, wellness, and an exceptional quality of life. London 2035: Equitable, Healthy, Prosperous, Resilient/Sustainable."

No change - already addressed in the Vision and the eight Strategic Directions of The London Plan


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Strategy 43 Disagrees that "London 2035: Exciting, Exceptional, Connected" is a vision statement for

Londoners rather than a tourism marketing for foreign investors. Asks how we measure "exciting" and "exceptional". Connected can be measured. Instead, suggests a new vision statement (re-using language from other policies). New vision statement as follows: "London 2035: Resilient, Healthy, Prosperous and Diverse and Equitable". Vision statement followed by bullets: 1. Building an age-friendly city; 2. Nurture old and create new cultural experiences that connect people and make it exciting to live in this city; 3. build lasting connections between ecosystems and socio-economic systems of neighbourhoods, city centre, and surrounding regions/globe. Other bullets to consider: 1. building a less automobile focused, environmentally conscious, highly urban env't that places premium on staying connected through social behaviours and technology. 2. ensuring that housing is affordable for all Londoners/ provides opportunity/prosperity and wellness. 3. All Londoners want our city to be prosperous so can offer opportunity, employment and quality of life/wellness. Then new last paragraph in vision "We are a caring, responsive community committed to health/well being of all Londoners. Actions we take will be socially, env'tally and fiscally responsible so that our quality of life is enhanced and sustained for future generations. Our people, heritage, diverse economy, strategic location and land and resources are our strength.

No change - The Vision is consise. The proposed revisions to the Vision statement are already addressed under the eight Strategic Directions of The London Plan.

Our Strategy 43 OUR STRATEGY -- Page 17 – clause 43 – VISION – are three words sufficient (EXCITING, EXCEPTIONAL, CONNECTED) ?? London has or had a STRATEGIC PLAN with a Vision statement – section 2.1.2 of current Official Plan. Would it assist the public interest to keep this in the London Plan – continuity?

No change - The Vision is consise and can relate to many elements that make up London. The London Plan is a new Official Plan with different strategic directions for London's growth and development over the next 20 years.

Our Strategy 44 to 52 OUR STRATEGY -- Pages 17 – 25 - – are the KEY DIRECTIONS – are they “monitorable” and measureable? … able to reported upon annually ?? This would enable accountability! ( eg. UTRCA – Report Cards ). Clause 25 describes “monitoring”. Clauses1482 – 1483 deal with OP monitoring as well but it is more for Review and Updating.

Modified - Our Strategy now includes a requirement that a monitoring program be established to assess progress regularly over time

Our Strategy 44 Statement that London’s “status quo” planning approach will not be adequate to achieve the vision is a negative and judgemental statement. Suggests rewording or removing.

Modified - deleted this section

Our Strategy 44 What is London’s “status quo” planning approach referred to in Policy #44? Modified - deleted this sectionOur Strategy 45 _1 In direction #1, bullet 1, after "ability to compete" add "but also cooperate" with other cities. No change - collaborate with other regional partners is addressed

under Our Strategy - Direction 2Our Strategy 45 _10 401/402 NAFTA Highway Employment - OpportunitiesThe potential for job creation in this

corridor is immense (non residential). London lags behind every other Ontario municipality in developing land adjacent to the 401/402 corridor.

No change - ILDS and urban growth boundary expansion addressing land needs along parts of the Hwy 401/402 corridor

Our Strategy 45 _12 Policy 2.3.1 of the PPS (2014) states that prime agricultural areas shall be protected for long-term. This includes more than just Class 1 land. It includes specialty crop areas, Class 1, 2, and 3 lands, and any associated Class 4 through 7 lands, in this order of priority. RECOMMENDATION: OMAFRA recommends that this subsection be expanded to include more than just Class 1 agricultural land in accordance with the PPS.

Modified - revised to incorporate reference "to protect our valuable agricultural land" consistent with the Provincial Policy Statement

Our Strategy 45 _2 Direction #2, subsection 2 refers to "improving downtown" and "creating great neighbourhoods". States that there are already many great neighbourhoods and asks how are they kept great if keeping them great is not one of the goals? Suggests "creating and maintaining great neighbourhoods" as a direction.

Modified to add - "and sustaining great neighbouhoods

Our Strategy 45 _5 Not all urban neighbourhoods require revitalization. Suggest modifying wording to “Sustain and revitalize....”

No change - policy about revitalization; has been addressed elsewhere in modifications to the Plan


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Strategy 45 _6 What type of infrastructure needs to be created for the knowledge based economy? Statement

is not clear. Suggest providing clarification or example of what is meant.No change - various forms are identified throughout the Plan e.g. Smart City

Our Strategy 45 references to Discussion Paper #1

Realtors tell us that young professionals looking to move to London ask specifically about neighbourhoods with access to good schools and child care. an Age Friendly city is a city that is friendly for all ages, from infancy to the elderly, including the pre-natal and end of life stages. A city that has strong neighbourhoods where families and individuals of all abilities and ages, can choose to grow, learn and “age in place

No change - agree with comment

Our Strategy 45 to 52 Directions how relevant and how do they apply? No change - addressed under Policy 38Our Strategy 45 Direction #1, add new bullet 14, stating "build a bioregional economy focused on local

prod'n/consumption and bioregional capacity of nature/people.Modified - add a new bullet linking economy to environment

Our Strategy 45 A large number of businesses will not consider other land inside the urban growth boundary as suitable and look to other communities that offer close access to or exposure on the 401.

No change, but did expand the UGB for industrial growth

Our Strategy 46 _10 Already established. Perhaps enhance. Modified - revised to address commentOur Strategy 46 _2 Direction #2, bullet 2: expand the watershed approach to all areas of society (economy, etc.). No change - policy incdlues "all of our planning" already

Our Strategy 46 _2 Connect London to the surrounding region-add high speed rail (from meeting: link to Toronto too - not just Windsor-Quebec)-intelligent region (smart city) (from meeting: SWEA economic potential in region)-work with Southwest Economic Alliance (SWEA) (from meeting: specifically, rather than just 'partners')-London as a hub with connections to the region – in transportation (air, future high speed rail, healthcare, education etc.) (from meeting: other wording for hub? see Gregg's wording p.19)


Our Strategy 46 _2 Either it is by watershed or it spans the region. I think you mean that it will be by watershed and where the watershed crosses boundaries, the full watershed will be considered. Secondly it would not be all the planning just the relevant planning. Police department planning for example would not need to conform to watersheds.

Modified - removed "which spans the region"

Our Strategy 46 _8 As large an area as possible - up to a watershed. Make decisions at local level that benefit the larger system.

Modified - to incorporate suggested edit

Our Strategy 46 Direction#2, bullet 3: why call it a "SW Ontario Growth Plan" rather than "SW Ontario Development Plan"?

No change - consistent with Provincial terminology

Our Strategy 46 Direction #2, bullet 7: after Thames River add "and its main tributaries". No change - watersheds include all tributariesOur Strategy 47 _4 Can't afford to "provide for public facilities/programs/spaces that foster inclusiveness and

diversity within our neighbourhoods" in all neighbourhoods across city. Or asks if this is just by Planning District. Example of being told no was for a "Centre for Activity and Aging" wanted at the Sherwood Forest Public School site.

No change - Policy 508 provides the necessary policy direction to address this matter

Our Strategy 47 _4 Provide for public facilities, programs and spaces that foster inclusiveness and appeal to, and serve, the diverse populations in our neighbourhoods.

Modified - to add - "and appeal to a diverse population in" our neighbourhoods

Our Strategy 47 Direction #3 p 20, celebrate and support London as a culturally rich, creative and diverse city, does not reference movement and accessibility as a means to foster this direction. The Committee believes investment in cycling infrastructure can reduce the barriers to integration of new comers to the city because cycling is an efficient and cost effective alternative to car ownership. Recommendation: Add a Policy related to mobility integration and the investment in cycling infrastructure to reduce barriers to access.

No change - mobility addressed in many other parts of Plan


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Strategy 47 Does not reference movement and accessibility as a means to foster this direction. The

Committee believes investment in cycling infrastructure can reduce the barriers to integration of newcomers to the city because cycling is an efficient and cost effective alternative to car ownership. Recommendation: Add a Policy related to mobility integration and the investment in cycling infrastructure to reduce barriers to access.

No change - cycling matters addressed under variuos parts of the Plan, including the mobility chapter

Our Strategy 47 Direction #3, add new bullet 9: "Revitalize our cultural heritage of London as the Orchard City by supporting growing/maintenance of fruit and nut trees in orchards, parks, boulevards and backyards."

No change - look at issue as part of Food System

Our Strategy 47 Celebrate and support London as a culturally rich, creative and diverse city-need to add something about attracting and retaining immigrants (from meeting: and aboriginal communities)


Our Strategy 48 _12 Direction #4, bullet 12: at end, add "affordable fashion…and over time transition to renewable sources of energy".

No change - too detailed at this level of Policy. Best left in the City Building Policies on Green City (policies 810 to 814), which address this request as part of the Community Energy Action Plan

Our Strategy 48 _6 With regards to the infographics used in the online video about the plan, some of the statistics shared at the recent Middlesex-London Health Unit (MLHU) - workshop would be especially appropriate, for example, how we expect the number of extreme heat days to increase, or the number of severe storms, or droughts. Given that one of the Official Plans “Big Moves” is specifically to make London one of the greenest cities in, having at least one important fact related to the environment being included in presentations (and other media wherever possible) would be beneficial.

Modified - added infographic re: greenhouse gas

Our Strategy 48 _6 We support the integration of climate change throughout the Official Plan document, but would like to see it even more strongly emphasized, as both the direct impacts (more frequent storms, heat waves, etc.) and indirect impacts (e.g. loss of international food security, increased armed conflict, climate refugees, etc.) will likely be the greatest challenge faced by most, if not all, communities across the world over the next fifty years.

No change - Policy 48_6 to be moved to top of list as Policy 48_1

Our Strategy 48 _6 Move this point to top of list. Modified Policy 48 to re-order policies in listOur Strategy 48 _7 Direction #4, add new bullet (as bullet 7): Develop an Energy Descent Plan. No change - no provincial requirement/The London Plan follows

formatOur Strategy 48 _7 Asks how will protect/enhance NHS? Monitoring would be nice since we don't have a data line

and protection/enhancing to date has been poor. What will be different in new Plan? Also unclear why don't consistently use capitals for Natural Heritage System or definition of NHS from the PPS. NHS is used in a manner that is not consistent with PPS, in his opinion.

Modified - revised to address comment, monitoring section added

Our Strategy 48 _7 ADD reference to Thames River and eco-system health. Modified to add - reference to Thames River and eco-system health

Our Strategy 48 _8 Direction #4, add new bullet (as bullet 8): Develop an ecological services master plan. No change - Urban Forest Strategy addresses this matterOur Strategy 48 _8 Gives link to G&M article on street trees, from Aug 8, 2014. No change - review with best practicesOur Strategy 48 references to

Discussion Paper #5

· Urban agriculture: As the city expands, ensure some farmland is kept within the city for urban agriculture and farmer’s markets. Bike paths can be created to enable access to local grown food and “pick your own” small farm operations. Incentives would be needed to prevent the land from being sold to developers. Cornell’s and Versteegh’s are two examples prime farmland and orchards in southwest London that were easily accessed by city dwellers and have recently been sold.

Modified - refer to neighbourhood scale food production


Page 19

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Strategy 48 references to

Discussion Paper #5

• Green Corridors: The green corridor and pathways along the Thames River and neighbouring creeks are an invaluable asset that need to be protected and enhanced for public access by active transportation, whenever possible. Example: bike and foot paths that connect neighbourhoods and neighbourhood parks, to the river corridor.

No change - addressed under Green Space and Parks policies


· Think long term: It has been said that “The best time to plant a tree was 100 years ago”. Thus, when considering the re-development of abandoned space consider what lessons can be learned by considering the urban successes of today, that were seeds planted 100 years ago.

No change - addressed under Policy 48_4 & 48_8, and City Building Policies - Urban Forest


· Trees: Increasing the tree canopy with new plantings but also by ensuring new residential developments keep a certain proportion of the existing mature, healthy trees. As climate change results in more extreme heat days, shade trees are required as protection from the sun. Today children in new subdivisions lack access to shade trees and are often unable to play outside on hot days.



· Urban forests: Creating a true forest within the city is much more than planting more trees. The urban forest could be sufficiently large to provide a retreat from the increasing summer heat. If paths through the forest are strategically located to connect people with important public buildings, institutions or activities, then active travel through the forest is part of our daily routines, functional fitness and offers an environmental friendly option other than driving around the forest. Example: Zurich Switzerland has an urban forest on a large hill with busy foot and bike paths connecting residences to a university campus, the city zoo, outdoor education sites, etc.



· Outdoor Education Centres: There is a need to protect the loss of school and public access to outdoor education centres and sites.

No change - addressed under Policy 48_9


· Loss of school playgrounds: As schools are sold, the neighbourhood loses access to the public space that surrounded the school. This includes the playground, the recreational fields, the mature trees, large space to run freely and the public walking paths that connected neighbours.

No change - addressed under Policy 51


There is growing awareness that the separation of children from nature is an important educational as well as a physical and mental health concern. Children need playgrounds and splash parks but they also need easy access to safely experience and explore the biodiversity of the natural environment. Learning to relax and be soothed by nature is an anti-dote to stress. This is important for children’s wellbeing today but also, as they learn to enjoy and appreciate the natural environment, they are better prepared to be our future stewards of the environment.

No change - various policies of the Plan address these issues and plan for parks, environmental protection, etc.

Our Strategy 48 Identify London as a Pollinator Sanctuary in the City’s Official Plan. Add to: “Direction #4 - Become one of the greenest cities in Canada” - a part 15: London will become a Pollinator Sanctuary by recognizing the critical role that pollinator habitat plays in supporting ecosystem functions, the city will take all opportunities to protect, maintain and enhance pollinator habitat within City parks, Restoration Areas and Ecological Linkages, lands adjacent to stormwater management facilities and open space areas.

Modified - added policy to 48_4 to "establish London as a key pollinator centre…"

Our Strategy 48 Policy 48, Direction #4: All of the policies in 1 through 14, especially 7, are commendable! No change - indicates support for the Plan

Our Strategy 48 Direction #4, add new last bullet: "Make London a Pollinator Sanctuary recognizing the crucial role of pollinators in natural and human systems."

Modified - added policy to 48_4 to "establish London as a key pollinator centre…"

Our Strategy 48 Direction #4, bullet 3: change "carbon footprint" to "carbon and ecological footprint". No change - plain language reference applied


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Strategy 49 _1 Direction #5, bullet 1: change "growth" to "development" and add "development patterns

towards a sustainable city that can run without fossil fuels." No change - but striving towards sustainability and managing our growth

Our Strategy 49 _1 The word 'consistent' does not seem to fit mixed-use very well. Perhaps 'complimentary' or 'effective'.


Our Strategy 49 _2 There are other strategic locations where high intensity mixed use development should also be appropriate. Suggests changing wording to “...and within the Primary Transit Area and other key nodes where public transit is planned or available”.

Modified - change the word from "directs" to "focuses". Focus of infill and intensification in Primary Transit Area does not preclude other opportunities elsewhere in the city

Our Strategy 49 _3 Direction #5, bullet 3: make sure the inward and upward is not too high upward. No change - specific heights referenced in the Place Type policies

Our Strategy 49 _3 I am 100% in favor of The London Plan's inward and upward emphasis. It would have been preferable if the context of the redo of the London Official Plan had been more directly in the context of the provincial requirements that govern it. There appears to be scant acknowledgment, for example, that the Plan must be "consistent' with Ontario's Provincial Policy Statement (PPS). On the issue of how the Plan enables interactions with real-world processes, the website summary says feebly that "Our Tools are the legislative and legal regulations and processes we can use to shape our City for both public and private purposes."

No change - entire Plan is consistent with, and furthers the policies of, the Provincial Policy Statement

Our Strategy 49 _3 Compact, contiguous growth can be achieved by other means in addition to “looking upward and inward”. Suggests changing Policy to “Plan to achieve a compact, contiguous pattern of growth.”

No change - accurately reflects intent of City Structure Plan in plain language terms

Our Strategy 49 _4 49.4 states "continue to revitalize" downtown, urban business corridors and urban neighbourhoods. Response: some neighbourhoods are just fine the way they are. This makes it seem as if unwilling to accept the status quo. Also asks question of what "Urban Business Corridors" are. Term appears no where else in London Plan, consider defining?

Modified - change to revitalize "and sustain our downtown. Change "urban business corridors" to "main streets"

Our Strategy 49 _6 "so that they are complete": noting that some are already complete or established. No change - may not apply if neighbourhood already has these characteristics

Our Strategy 49 _7 This subsection notes "respect" for character of neighbourhoods, but does not state "protect the character of neighbourhood". Who will be arbiter of respect without protection?

No change - Our Tools contains evaluation criteria. Have added reference to sustaining our neighbourhooods in other parts of the Plan.

Our Strategy 49 In the references to building a mixed use city, reference to design guidelines should be considered in this section.Include ‘clean’ industrial in Mixed Uses. Consider identifying Employment Lands in other locations besides the periphery

Modified - add "clean industrial" to Policy 49_7

Our Strategy 50 & 51 Add transportation choices and increase road safety by reducing traffic congestion in Our Strategy chapter, p23, Direction 6. Add to Direction 7 the potential of increased retail sales in pedestrian friendly areas and cycling destinations.

No change - already integrated into strategic directions

Our Strategy 50 _10 Abandoned rail lines – why limit it to this? (from meeting: and other corridors - make broader) Modified - revised to address comment

Our Strategy 50 _11 Direction #6, bullet 11: should note that strong network of transportation is "public" transportation, and note at end of the bullet that this includes regional rail and bus service, integrated into cycling and walking paths.

No change - discussing network rather than the means. See 50_11 reference to add HSR and regional rail

Our Strategy 50 _2 Remove "designed" from Policy to make it stronger Modified - revised to address commentOur Strategy 50 _3 Asks: How will rapid transit be used “strategically” to create incentives for development? No change - presence of rapid transit can stimlulate demand for

developmentOur Strategy 50 _5 Direction #6, bullet 5: Need not just mixed-use, but compact development patterns, for without it

bike lanes aren't used (e.g. suburbia) as have no where to go. Should note in Direction #6 to have bike lanes everywhere.

No change. Policy 50_8 addresses this matter


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Strategy 50 _5 Mixed use development should not be restricted to areas to be served by “rapid” transit, as it

may not occur for many years. Suggests using the term “public transit” instead of “rapid transit”, to address interim period when rapid transit will not be available and provide greater flexibility.

Modified - change "direct" to "focus" at centres

Our Strategy 50 _6 Asks: How will the City “require” transit-oriented development? This may not be feasible for all sites or scales of development.

No change - is dependent upon the context of the development

Our Strategy 50 _9 Much transit and active mobility infrastructure does not reduce street widening requirements. In fact, it is quite likely to increase them to allow for transit /HOV only lanes, separated cycling lanes, etc. Suggests removing latter part of sentence, from “recognizing” onwards.


Our Strategy 50 _9 Need to address snow maintenance. Something like enhancing snow maintenance activities to extend seasonal use of the network. Right now we need snow storage space. Needs to be dealt with and does not seem considered here. This is particularly important if you want to promote bike and pedestrian use. Need to make them possible year round.


Our Strategy 50 Transportation Advisory Committee express its support for many of the London Plan’s general principles and directions including: • Identifying the “Critical Importance of transportation"• Recognizing the explicit relationship between land use and transportation, and• The London Plan’s emphasis on creating Transportation Choices

No change - indicates support for the Plan

Our Strategy 50 Change Transit station to “village” Modified - to add at "transit stations and transit villages"Our Strategy 50 Place a new emphasis on creating attractive transportation choices

Need to mention high speed rail. Add to Policy 50_11 - reference to high speed rail; added highspeed rail policies in the Mobility chapter.

Our Strategy 51 _1 Subsection 1 refers to "healthy housing options", this appears no where else. What are "healthy housing options"? Also note that methadone clinics are part of Health Services but they have been kept out of the Neighbourhood Place Type. Noted in reference to "healthy housing options".

No change - healthy is part of PPS

Our Strategy 51 _10 "Integrate affordable housing in all neighbourhoods": asks if this is possible in all neighbourhoods if character is to be protected? Asks how, if character currently is lower density, will increased intensity protect (intensity on page 49 as a will/shall Policy)? States that it has not yet been made clear publicly that intensification is a major Policy objective/primary strategy (see Policy 943). This strategy also does not say anything about respect or protection of the character of neighbourhoods. Not sure how land use planning does this, Last time he checked, "Planners do not leap tall buildings in single bounds!".

Modified - changed to "affordable forms of housing"

Our Strategy 51 _11 Support recreation and social programming which encourages..... Modified - revised to address commentOur Strategy 51 _11 Explore creative opportunities for the special needs associated with the winter season. No change - part of larger picture policiesOur Strategy 51 _2 Direction 7, bullet 2: should add that aging in place should have access to "work" as well as all

facilities and services.Modified - revised to address comment

Our Strategy 51 _2 This Policy states "design 'complete' neighbourhoods". Comments that this seems to refer to 'new' neighbourhoods, but Policy seems insistent that it will happen in all neighbourhoods. Notes that this is also the only Policy where "complete" is in quotes, however there is a specific definition for Complete Neighbourhood in the Glossary.

Modified - removed quotations

Our Strategy 51 _4 last line states "integrated within or adjacent to neighbourhoods". Notes that how Neighbourhoods are defined may make a large difference in explaining what is adjacent.

No change - Policy speaks to a range of uses where people come together


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Strategy 51 _5 Policy is on protecting neighbourhood character, and asks "by doing what to make it

'complete'? States that this language is much too flexible.No change - The London Plan is based on a hierarchy of directional policies starting with the Strategic Directions which sets out that over the next 20 years of this Plan we want to protect neighbourhood character. The City Building policies go into more detail about what we are trying to achieve and how we are going to achieve this. The Neighbourhood Place Type and Our Tools provides even more detail that implement the ways that direct growth in a manner that protects neighbourhood character

Our Strategy 51 _6 Direction 7, bullet 6: should note that all destinations should be reachable by bicycle. No change - cycling destinations are an important part of the cycling network

Our Strategy 51 _6 This Policy has a reference to "cycling infrastructure", found in Policy 214. Asks whether this means, based on the Policy 214 definition, that what is really meant is paved paths?

No change - cycling infrastructure includes pathways, bike lanes, opportunities to connect to bus, etc.

Our Strategy 51 _9 Asks if reference to "well-designed parks" means the definition of parks in Policy 493? If so, there may be some concern because Woodlands and Open Space Parks are not designed (except for golf courses) for recreational activities. Suggests being more specific/careful in use of term "park", particularly without a capital letter "P" if the Plan will include NHS and Open Space in Parks. Otherwise, could continue to be general but exclude Woodlands and Open Space parks as part of the park hierarch on Policy 493. Or specify that reference to parks does not include components of NHS, unless vagueness is deliberate.

No change - naturalization may occur by design


The aging population of London is an important consideration in city planning however, an aging population also needs to attract the young in order to remain a vibrant and complete city. It is important in a city planning document to specify the key elements of an age friendly city that supports all ages from infancy/ early childhood to the elderly. It also supports the able bodied and the disabled.

No change - addressed under policies 51_1 to 51_4


The key aspects to attracting and supporting the older and the younger populations are similar. Examples include:- service integration, neighbourhood hubs- access to community recreation areas and facilities- walkable communities with safe walking/bike paths, sidewalks- minimal stairs and curbs for strollers and little legs- access to parks etc. without the need to cross major highways- integration of natural areas with residential development- shade or semi-protected areas for resting, playing, social gathering- beautiful landscapes and urban design- easy public transit- public parks and public spaces designed with “eyes on the park”. Example: a neighbourhood park with homes facing the park

No change - addressed under policies 51_1 to 51_4


Young families are also looking for neighbourhoods with easy access to schools and school based child care.

No change - addressed under Policy 51_8

Our Strategy 51 Direction 7, suggest new bullet 12: "Support neighbourhood scale food production and processing."

Modified - add new bullet 12 for neighbourhood scale food production.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Strategy 51 Direction 7, suggest new bullet 14: "Support neighbourhood scale educational programs that

will educate the citizens on the ecological ways of the City of London (support community-based schools of Sustainability)."

No change - addressed under 51_7

Our Strategy 51 Direction 7, suggest new bullet 13: "Support neighbourhood scale recycling and especially composting organic wastes."

No change - addressed under Green City

Our Strategy 51 Regarding strong and attractive neighbourhoods, design guidelines, would appear to be a natural addition to the list under Direction 7.

No change - implementation tool is not considered a strategic direction

Our Strategy 52 _11 Policy states "genuinely engage stakeholders": Asks what will be done differently? Notes that the Our Tools section has the same public processes as before. Notes that plan doesn't have mandatory community meetings. Suggests considering mandatory community meetings in the NCN to start with.

No change - policy applies to all public engagement

Our Strategy 52 _11 Does this change notice requirements? General statements could become problematic. Perhaps change the wording from “shape” to “inform"


Our Strategy 52 _2 Direction 8, bullet 2: at end of bullet add "but recognizing that all human systems are embedded within the greater whole of global ecosystems"

No change - not considered plain language

Our Strategy 52 _2 Appreciate future plan tends to be grow and improve but the bigger job(99%) is actually sustaining what we already have. This could be stronger. Add 'Consider whole life costing and impacts in decision making.'

No change - says "sustainable" which can refer to existing infrastructure

Our Strategy 52 _5 Direction 8, bullet 5: after "foundation of our plans" add "effectively necessitating the nesting of the London Plan within a bioregional plan of the Thames River system and embedded jurisdictions."

No change - watershed and subwatershed plans are recognized

Our Strategy 52 _9 remove quotes from word "fit". Modified - revised to address commentOur Strategy 52 references to

Discussion Paper #8

In planning new subdivisions and setting aside property for a possible future school, it is important to consider the indoor and outdoor land use needs for the future school based child care. This is especially important for elementary schools and is aligned with the direction of the Ministry of Education.

No change - addressed elsewhere in the Plan

Our Strategy 52 Consider adding a new bullet which incorporates reference to the city’s interest in, and responsibility for planning and constructing infrastructure that will mitigate the variables of climate change.

No change - adequately addressed under multiple policies under Direction 8 and Direction 4

Our Strategy 52 Policy 52, Direction #8: All of the policies in 1 through 11, especially 1, 2, 3, and 5, are commendable!


Our Strategy 52 As the goal is to "make wise planning decisions" as stated on the Plan website, it would help to add a clause or two detailing pro-active outfitting of citizens with planning knowledge. Such as "Citizens who submit letters on planning issues or who send notice of intent to speak at a meeting shall be provided with the Meeting Info Kit for Citizens...." For example the Province of Ontario has a pamphlet and set of supporting PDFs on the Provincial Policy Statement (PPS) that can be super-critical in planning outcomes. I was at an OMB hearing in July where the OMB process turned on the PPS requirements. Citizens armed with the PPS (as an example again) can greatly increase the efficiency of the planning process and reduce the potential for cycling to new meetings or the OMB.


Our Strategy 52 The early establishment of design guidelines with community input would be a good step to achieving this goal. This allows the discussion and resolution at the level of, and with, the input of a neighbourhood. It sets the rules early, and mitigates the invention of the “rules” for every project.

No change - but made change to City Design policies to address comments.


Page 24

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Structure Plan 53 Whole Part In order to reduce air pollution, especially PM2.5, PM10, ozone, and other pollutants, the City

has to strategically develop healthy and environmentally sustainable neighbourhoods for our citizens. The development of a well- designed mobility system will encourage alternative modes of transportation such as cycling and thus reduce emissions and improve air quality.

No change - indicates support for plan

City Structure Plan 53 Policy 53: at the end add "but eventually will stop growing." No change - not in 20 year horizonCity Structure Plan 53 City structure Plan is a good thing in the Plan – but add other language that provides a

background and context that it is looking longer term – especially as it applies to RTModified - revised to address comment

City Structure Plan 54 Whole Part Policy 60 City structure components should be amended by adding the Mobility Network Map 2 as map No.3 prior to the street network, to reinforce the importance of cycling as a mode of transportation

Modified - maps revised to improve clarity

City Structure Plan 56 Whole Part Title of "Thames Valley Corridor and the Natural Heritage and Park System" has too much focus on the Thames Valley, need to mention urban forests and other areas of ecosystem services (backyards, boulevards).


City Structure Plan 56 Policy 56 does not include a specific reference to pedestrians, cycling, or active transportation. Add/amend a clause to specfically reference the active transportation or cycling network as part of the City Structure

Modified - policy deleted

City Structure Plan 56 Does not include specific reference to pedestrians, cycling, or active transportation. Recommendation: Add \ amend a clause to specifically reference the active transportation or cycling network as part of the City Structure.

No change - addressed as part of City Building policies under Mobility

City Structure Plan 56 Add a bullet, “Establish a city-wide cycling network that provides safe and convenient access.” Modified - policy added

City Structure Plan 56 Policy 56, 4th bullet: change "promoting growth" to "promoting development" Modified - policy deletedCity Structure Plan 57 Whole Part Sustainable Infrastructure section: suggests reading article from www.resilence.org, stating

radical societal change tends to be associated with shifts of infrastructure. Society consisting of infrastructure, structures and superstructure.

No change - comment not specific to London Plan

City Structure Plan 58 Whole Part HERITAGE CONSERVATION DISTRICTS – should they be a part of the STRUCTURE? No change - HCDs shown on map 10

City Structure Plan 59 Map layer 3 Map layer 3: seems to be missing natural heritage and park system features on the southern part of city. Was told by EEPAC that these maps aren't part of the Plan, but don't see how they aren't as they are referenced in policies.

Modfied - mapping updated to show green spaces in southern part of the city

City Structure Plan 59 Central London address densities? No change - addressed elsewhere in the PlanCity Structure Plan 60 & 87 - Map

Layers 1-10The term Employment Areas is not consistent with the term “Industrial Districts” in Item 9 of Para. 60 and Para. 87.

Modified - revised term to Employment Lands

City Structure Plan 60 & Map 1 The LP in both Section 60 and City Map 1 – City Structure Composite indicate an “industrial district” and an “employment area.”

Modified - revised term to Employment Lands

City Structure Plan 60 _1 No text provided for Rivers and Creek System. (which is an item on Legend of Map 1 City Structure Composite). Suggests modifying maps / text on page 30 to combine Rivers & Creek System with Subwatersheds, and add a paragraph or two to Sections 61-64 relating to Rivers and Streams.

Modified - map and text revised to address comment

City Structure Plan 60 _1 & 60_2 River and Creek Systems and Subwatersheds are not really separate entities for city structure. Suggests putting both on one map.

Modified - map and text revised to address comment

City Structure Plan 60 _10 The Built Area Boundary is identified as being a component of the City structure, however, no commentary is provided for the component, similar to that provided for subwatersheds, streets, neighbourhoods, etc. SUGGESTION: Perhaps a description of the Built Area Boundary and its purpose could be included as a new paragraph 89.

Modified - policies added, the Built Area Boundary is a component of the City Structure Plan.

City Structure Plan 60 _5 Need more than 4 Transit Villages. Has included map with suggested additional locations for Transit Villages.

No change - inclusion of 4 transit villages consistent with 2035 targets


Page 25

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Structure Plan 60 _7 - Map Layer 7 CITY STRUCTURE PLAN - Page 30 – 31 … COMPONENTS .. is the NEIGHBOURHOOD Map

insufficient to be commensurate with the emphasis that the overall Plan puts to the Neighbourhood planning component -“pillar” .

No change - neighbourhoods included in City Structure and addressed in many poliices throughout the Plan.

City Structure Plan 60 _9 - Map Layer 9 Show "NAFTA Super Highway" No change - intent is to show employment lands

City Structure Plan 60 Layer Map 8 Policy 60, Map 8, Main Streets: Incorrectly shows Byron Main Street at North Street and Byron Baseline Road. Should be at Commissioners Rd/Boler Rd Intersection. Byron Main Street also should be changed for Map 1-City Structure Composite.

Modified - maps revised to address comment

City Structure Plan 60 Layer Map 8 Byron Main Street is in wrong location. Modified - maps revised to address commentCity Structure Plan 60 Layer Map 8 Several Main Streets are not shown on the plan (SoHo, Old East, Richmond Row). Heritage

Conservation Districts have a greater implication / impact on City Structure than the small number of small main street areas. Suggests including all Main Streets and adding HCDs to the City Structure Plan.


City Structure Plan 60 Layer Maps 1-10 CITY STRUCTURE PLAN - Page 30 – 33 … inconsistency of content between 10 small maps and Composite. Eg. Airport and Railways are not on small maps, but on page 33 – Map 1 – Composite does label Airport. Can we review to be more consistent? Can we make Railways more prominent and give more recognition?


City Structure Plan 60 Layer Maps 1-10 The Central London boundary needs to be bolded and listed in the legend. Modified - maps revised to address comment

City Structure Plan 60 Layer Maps 1-10 There should be a city servicing infrastructure map included in the City Structure Plan showing PCPs and their sewersheds, as well as rail lines.

Modified - revised mapping to show rail lines. Growth Management Implementation Strategy to show servicing

City Structure Plan 60 Map layer 10 The Built Area Boundary should be shown. No change - map includes built area boundaryCity Structure Plan 60 Map layer 10 The built-up area is outdated (2011) and is missing existing development (e.g., Andover Trails).

Why is the 2011 built area boundary used? Update map based on latest built area boundary.No change - the built-area boundary does not change over time. Current boundary is same as 2006 boundary

City Structure Plan 60 Map Layer 6 Page 30 — Layer 6 of the “City Structure Plan” or “City Structure Composite” provides for some green areas (see below) along the northern and eastern limited of the City that are shaded green. These green areas do not seem to be identified on any map. Please advise what meaning this green imagery has and any associated Policy that pertains to these areas.

Modified - incorporated text to Policy 89 to tie the mapping of the rural-urban interface with Map layer 6

City Structure Plan 60 Whole Part On the whole, we support the draft of The London Plan for its vision to reinvest in the central area of London, encouraging transit, mixed use and higher densities. Our comments specifically relate to the geographical distribution of height and density within the Downtown and Central London.


City Structure Plan 60 Amend the City’s Structure Plan chapter, p 30 Policy 60 to include the city’s cycling route network under networks that shape how London operates – see page 81 map 2 mobility network.

No change - Map 2 the Mobility Network map serves this purpose

City Structure Plan 60 Recommendation: City Structure Components should be amended by adding the Mobility Network Map 2 as map No.3, prior to the street network, to reinforce the importance of cycling as a mode of transportation.

No change - streets are included on Map 2, which shows the integration of all modes of active transporation on the Map

City Structure Plan 60 Recommend adding Map 2 - Mobility Network (in Mobility section) to this page of maps to reinforce the importance of cycling as a viable mode of transportation.

No change - Map 2 the Mobility Network map serves this purpose


Page 26

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Structure Plan 60 Map 3 under Policy 60 identifies the City’s Thames Valley Corridor and the Natural Heritage and

Park System. However, it does not appear as though this natural heritage system includes all natural heritage features that are mapped in Map 6 of the Official Plan and does not show natural heritage features and areas linked by natural corridors as per the PPS definition. MNRF questions why certain natural heritage features and areas have not been included in Map 3 of Policy 60?Further, policies 301 and 302 of the London Plan refer to the potential for creation of ‘Upland Corridors’ and refers to Map 6 which identifies potential locations for future upland corridors. These potential corridors also do not appear to have been included in the Map 3 natural heritage system. RECOMMENDATION: MNRF recommends incorporating all natural heritage features and areas and the natural corridors that link them together as part of the natural heritage system shown in Map 3 of Policy 60. This would ensure the City is meeting the requirements of Policy 2.1.3 of the PPS.MNRF also recommends that the City consider identifying the potential Upland Corridors as part of the natural heritage system.

Modified - Map revised to address comment

City Structure Plan 60 While it is understood that the City Structure Plan provides a framework for the assignment of Urban and Rural Place Types, the City identified ‘preserving agricultural lands’ as the first bullet point in Policy 56 on page 28, which leads one to believe that the agricultural area forms part of the City Structure Plan. Yet, this area is not shown on any of the maps on page 30 of the Plan.The PPS Policy 2.3.2 requires “prime agricultural areas” to be designated. RECOMMENDATION: Ministry staff understand that the City has chosen to use the nomenclature of Rural Place Types rather than an Agricultural designation to show the prime agricultural area; however, it seems like a gap when no maps of this area are included in this section of the Plan. While OMAFRA recognizes that this area is delineated on Map 4 found on page 404 of the Plan, it would be meaningful to also show that this area forms part of the City Structure Plan here, by including it as an eleventh map on page 30 with an accompanying Policy section, or at least showing it in the legend on Map 1 found on page 31.

Modified - Map revised to address comment

City Structure Plan 60 Consider using the phrase “historical business areas” as noted in Sentence 85 for this section. No change - the reference to historical business areas is intended to clarify the term "Main Streets"

City Structure Plan 60 The Components of the City Structure Plan listed on page 30 do not match the legend on the map.

Modfied - mapping legend and corresponding components of the City Stucture Plan

City Structure Plan 60 “Neighbourhoods” as a structural element as shown on Page 31 and characterized in Policy 84, is very different from the “neighbourhoods” shown on map 4 and in the Neighbourhood Chapter. (Residential neighbourhoods vs. districts of the City). Perhaps different terminology should apply to the two concepts.


City Structure Plan 60 The map of neighbourhoods on page 31 should be approached some other way. A little too “funky” and hard to read if it’s meant to be a resource.

Modified - revised figure to show boundary of neighbourhoods

City Structure Plan 61 to 63 Policies 61 through 63: All these policies are commendable! No change - indicates support for the PlanCity Structure Plan 61 to 63 Refine policies so it is not just natural hertitage, but can also address water quality - Thames

River as a whole, ongoing work with other levels of government. Our role in watershed is infrastructure and water quality, as it affects Lake Erie. Double check direction 4 and Green City to address/define water quality



Page 27

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Structure Plan 62 While subwatershed plans may be used to get more in to the details of these systems, the

policies and protection still needs to be included in the Official Plan. PPS Policy 2.1.3 requires natural heritage systems to be identified. RECOMMENDATION: The City needs to ensure that they are comfortable that the foundational policies are in place in the City of London Official Plan to provide the protection of subwatershed and not rely on external documentation.

No change - addressed under Natural Heritage policies

City Structure Plan 62 Policy 62: Text should list the types of environment (physical, living natural and human) in the same order as the ABC’s (abiotic, biotic and cultural) for correct context.!

No change - not intended emphasis of this section, addressed under Natural Heritage policies

City Structure Plan 62 Subwatersheds, Policy 62: change "form the basis for environmental targets" to "environmental, economic and social targets…"

No change - subwatershed planning initiated in 1996 was established for environmental targets and will continue to do so under The London Plan

City Structure Plan 65 Recommendation: Add policies to allow bike paths in the ESA’s with appropriate study\mitigation where needed to obtain connectivity.

Modified - policies now point to the Natural Heritage policies that properly address this issue.

City Structure Plan 65 Policy 65: To the Thames Valley Corridor add "and tributaries". No change - the next Policy, Policy 66, addresses the tributaries of the Thames Valley Corridor

City Structure Plan 66 The recognition of the environmental and social significance of the Thames Valley Corridor is both laudable and necessary. The Policy recognizes the various uses of it and the need to balance those uses to ensure "long term environmental sustainability" and MOECC fullysupport that. MOECC believes the Policy should explicitly recognizethe importance of assimilative capacity and commit the city to makingdecisions with this in mind. In MOECC’s view, this approach isnecessary to implement many of the Strategic Directions of the Plan,particularly Making Wise Planning Decisions, Becoming One of theGreenest Cities in Canada; and Connecting London to the SurroundingRegion.


City Structure Plan 66 Policy 66: Sanitary and storm water infrastructure should be kept out of the tributaries associated with the Thames River in planning done from now on (the installation of the Trunk Sanitary Sewer infrastructure along the Medway Creek in the Medway Valley Heritage Forest ESA is an example of poor planning in the past and should not be repeated). The long-term sustainability of a healthy environment and river system should be the foremost consideration.


City Structure Plan 67 _4 P35, Policy 67_4: add Protect, enhance and restore …… Modified - revised to address commentCity Building Policies - Natural Heritage

67 _8 Pathways in ESA's - Policy No 67 TVP should not have/allow recreation areas Modified - policies now point to the Natural Heritage policies that properly address this issue.

City Structure Plan 67 _8 67_8 Thames Valley Corridor and the Natural Heritage and Park System - are tributaries included in Policy for pathways connecting parks along Thames valley corridor?

No change - corridor is not the only location for parks/trails

City Structure Plan 67 _8 Policy 67: Policies 1 through 7 are commendable. Policy 67, 8 should make it clear that any extension of the TVC Multi-use Pathway to complete the linkages will be kept outside of ESAs!



Page 28

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Structure Plan 67 _8 Clarification relating to Mobility and Transportation - #67.8, Page 35: We have just one concern

about this section of the draft plan: Given that many people want the natural resources of our open spaces, environmentally significant areas and areas of scientific interest protected from large, paved multi-use paths, it doesn’t seem clear the way that this section is worded about bicycle routes leading up to the open space areas, but not going through those areas. AND We would like some clarity and reassurance that such bicycle routes will not use our natural heritage system for such paths. A good deal of discussion and study was put forward in the Trail Management Guidelines for the London area and we would like those guidelines to be respected in term of Meadowlily Woods and the other sensitive environmental areas of the city.


City Structure Plan 67 _8 Refers to a “continuous multi-use pathway network....along the Thames Valley Corridor”. Current policies do not permit this. Suggests including policies to ensure that this can be achieved (i.e. – need to allow multi-use paths in ESA’s, in appropriate locations).


City Structure Plan 67 _9 Add new _9 on Flood Plain Acquisition: Revise to add: "As appropriate, acquire lands along the Thames Valley Corridor to support ecological, cultural and/or recreational objectives of the Plan."

Modified - Policy added

City Structure Plan 68 As per Section 2.1 (Natural Heritage) of the PPS, the natural heritage policies of the official plan are those policies that should provide for the identification, protection and/or no negative impact on natural heritage features and areas and their ecological functions in the City of London. It is not clear why this statement includes the natural resource policies in this list as they do not necessarily provide for protection of natural heritage features and areas.This Policy is saying that the natural heritage, natural resources and natural hazards chapters of this plan provide Policy also for the natural heritage systems that support natural features and functions of the Thames Valley Corridor. By “natural heritage systems” is this referring only to the Natural Heritage and Park System identified in Map 3 of Policy 60, or is this also in reference to the Natural Heritage System as currently mapped in Map 6 (Natural Heritage Features Overlay)? RECOMMENDATION: MNRF suggests referring to the comments regarding identification of a natural heritage system and also consider whether this statement should be revised to ensure that it accurately identifies the chapters of the Official Plan that will provide for the identification and protection of natural heritage features and areas.


City Structure Plan 69 Suggest adding new Policy 69 in the "TVC/NH/Parks System" section stating: recognize that ecosystem services are provided by ecological features outside of the Natural Heritage System. We will revitalize these services, placing emphasis on services particularly important for urban areas (SWM, food production, pollination, biodiversity)

No change - outside scope of policy

City Structure Plan 69 Policy 69: Street Network: should note importance of railway station in relation to street network, suggest changing last sentence to "They connect London to the Airport, the Railway Station and Highways 401 and 402."

Modified - revisions made to mobility framework to address comment

City Structure Plan 73 States that Rapid Transit Corridors will help make active forms of transportation viable and attractive to help minimize the cost of expanding streets. We encourage that all transit and active transportation infrastructure and hubs be made safe, convenient and appealing to increase the likelihood of use.

No change - Policy 177_4 ensures that streets and rights-of-ways are designed to provide a variety of safe, convenient, attractive, viable, and accessible mobility options for all Londoners

City Structure Plan 74 _1 Policy 74.1: asks why establishing the world class downtown is priority, because London's future, it is suggested, hinges on strong main-line railway connections to ports in Atlantic, Pacific and to the US Midwest.

No change - the intent of the Policy is to identify the connections starting from the local scale to the world


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Structure Plan 74 _2 Need more than 4 Transit Villages. Map provided with suggestions for more. No change - 4 transit villages appropriate for 2035 targetsCity Structure Plan 75 The Built Area Boundary is not mentioned. The Built Area Boundary should be added to this

Policy and explained as the other three are presented.Modified - revised to incorporate a Policy on Built Area Boundary

City Structure Plan 75 Show Transit Hubs as intensified zones on map. No change - Policy 74_2, under Transit Villages addresses issue

City Structure Plan 77 & 80 There is no discussion on how the 40% target is to be achieved in the Built Area Boundary. How will this be implemented, achieved, and monitored? The Built Area Boundary should be added to this Policy and explained as the other three are presented.

No change - target to be achieved through policies in rapid transit, transit villages, downtown, urban regeneration, etc.

City Structure Plan 78 _2 to _4 Bullet points 2-4: Expect this is too confining. Wonderland south to 401 will become the western edge over the next few years. Exeter Road will be the south boundary all the way.

No change - reference is for the Primary Transit Area, not the Built Area Boundary

City Structure Plan 78 Asks: Why does Primary Transit Area not include the Wonderland Enterprise Area, given the SWAP policies/Secondary Plan? Suggests modifying mapping to include Wonderland Enterprise Corridor.

No change - area is too far removed from Central London to be in PTA

City Structure Plan 80 Primary Transit Area, Policy 80: should the 40% target be included under Our Tools in a "Targets" section?. Also doesn't think 60% development outside the PTA will be sustainable, is instead sprawl.

No change - targets are appropriate and consistent with other plans such as the Growth Plan for the Greater Golden Horseshoe

City Structure Plan 80 Increase amount of development in built boundary to 50% No change - targets are appropriate and consistent with other plans such as the Growth Plan for the Greater Golden Horseshoe

City Structure Plan 81 _2 What amount? What will these be based upon? No change - the Transportation Master Plan and the Municipal Class Environmental Assessment to provide additional details. Based on Rapid Transit

City Structure Plan 81 _8 The language in this Policy is overly prescriptive, as not all development applications will be able to be transit-oriented. This reads more as a goal than as a Policy to be implemented. Consider revising this Policy to either be more flexible (e.g., “Generally development within (...)“) or to only apply in specific circumstances (e.g., “Large-scale development within (..))"

Modified - revised to allow flexibility

City Structure Plan 81 _8 Policy refers to bike paths. Should refer to bike lanes in addition to paths. revised wording to state “well serviced by bike lanes and paths.....”

Modified - revised to incorporate bike lanes in addition to paths

City Structure Plan 82 & 83 560 and 562 Wellington Street - It is also noted that the policies in the London Plan do not fully recognize the benefit of the proposed rapid transit along Richmond Street. In the draft policies, only those properties fronting onto Richmond Street are permitted increased height and densities of up to 20 storeys (“Rapid Transit Corridors” and “Transit Villages”). Planning research has shown that properties within 450 metres of lower order transit and 800 of higher order transit should be considered for greater height and density to support the transit system. The Site is located within the 800 metres and as such, additional height and density is warranted.

No change - will address through application process


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Structure Plan 82 & 83 560 and 562 Wellington Street - The proposed maximum height permission for the Site is not

appropriate and does not reflect the locational characteristics that make the Site ideal for intensification. It is our opinion that the broad-based policies for “Central London” do not recognize that the appropriate intensity of development will vary by site, depending on the unique locational attributes. Furthermore, the policies to do not contemplate any transition in built-form between “Downtown” and “Central London”. This is evident in the height permissions for the Site. While the Site is immediately adjacent to properties that are permitted up to 30 storeys (with bonusing); however, only 6 storeys is permitted on the Site. Note - add consideration/request 22 storeys above victoria park.

No change - will address through application process

City Structure Plan 84 Page 38, Policy 84: “The Neighbourhood Place Type chapter... allows for a range of uses and intensity of development that is variable depending upon a property’s location on a transportation corridor, within the Primary Transit Area or within Central London”. While we acknowledge that that this statement and the general policies of the Neighbourhood Place Type are much more flexible from a use standpoint (then present Official Plan Land Use designations), they seem to be much more limiting from a height standpoint that what is presently permitted. We understand the desire to direct the highest and most intense forms of development to the downtown area and I transit village. However, it seems as though this has been done to the detriment of building anything with any real height in the Neighbourhood Place Types, which accounts for the vast majority of land area of the City of London. Are there locations in the City that will be designated with the proposed “Neighbourhood” Place Type, where it would be appropriate to allow for development in excess of a maximum of 4 storeys (6 with bonusing)? We would encourage the City to provide for more flexibility, from a maximum height standpoint, within the “Neighbourhood” place type.

No change - the Neighbourhood Place Types clarifies the height provisions in neighbourhoods. Increased heights permitted in RT corridor, RT station, Transit Village, HDR Remnant parcels, Central London

City Structure Plan 84 This refers to "collection of neighbourhoods" but shows the "Planning Districts". And the words on Map layer 7 are illegibly written.

Modified - figure revised to address comment

City Structure Plan 84 Concern that the uses and intensities are a huge change, and it's hidden by using "transportation corridor" rather than the street classification the property is on based on Map 5 and Table 13.

No change - Neighbourhood policies state that street classification is linked to form, use, and intensity of development

City Structure Plan 85 There is confusion with other Main Street areas in other sections of the plan. Change the term Main Street used in other sections of the plan.

Modified - map revised to show all Main Streets

City Building Policies - Natural Heritage

86 This Policy has different wording again (protecting and sustaining versus protected and managed). Asks if this is different than no negative impact on features and functions which is used in other places? Suggests using consistent language from PPS, so is "a plan for ensuring no negative impacts on the features or the ecological functions of components of the NHS."

No change - text uses language consistent with the Provincial Policy Statement (PPS)

City Structure Plan 86 Policy 86: reminds that Byron Main Street mapped wrong in City Structure Composite. Modified - map revised to address commentCity Structure Plan 86 Not all of these are shown on Map 1. Modified - revised to clarify that some of the listed Main Streets

comprise part of the Rapid Transit CorridorCity Structure Plan 86 Not all Main Streets are shown on map. Suggest showing all Main Streets on map and adding

HCDs.Modified - map revised to show all Main Streets. Heritage Conservation Districts shown on Map 10

City Structure Plan 87 The schedule for this area show lands designated for industrial uses outside of the urban growth boundary and would be inconsistent with the PPS 20-year horizon. RECOMMENDATION:The City can discuss priority areas for potential industrial growth in the Official Plan and put forward policies that would help protect the lands for future industrial development, however, the lands cannot be designated on a schedule.

Modified - graphic revised to address comment to show the employment lands within the Urban Growth Boundary


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Structure Plan 87 Industrial District, Policy 87: Industrial district too far from rest of city, only most polluting (which

won't exist in long-term) should be there, rest of industrial should be integrated with residential, commercial areas so accessible by public transit/bikes.

No change - disignations exist in current Official Plan

City Structure Plan 87 Policy 87: Industrial District: Suggests adding new sentence stating "Significantly, the Industrial District is served by four railway corridors." (east-west CP and CN; CN/Goderich&Exeter RR; and CN line south to St. Thomas).

No change - issue to be addressed on revised City structure maps

City Structure Plan 87 The Policy makes reference to “Industrial Districts” and not “Employment Areas” as shown on the City Structure map. Consider revising the term used to coordinate between policies and maps.

Modified - changed to "Employment Lands

City Structure Plan 89 As it does not appear to be included in any of the map inserts found on page 30 of the Plan, nor on Map 1 located on page 31 of the Plan. RECOMMENDATION: indicated on a map in the Plan. Moreover, setting aside the fact that this Policy stems from a Board decision, it seems that this boundary is mostly about ensuring compatibility between rural and urban land uses. Therefore, it would make sense to extend the area of this ‘interface’ to include all land along the edge of the City’s Urban Growth Boundary, rather than just limiting it to those areas which also abut the City’s municipal boundary. This would be sound land use planning and would also be consistent with Policy 2.3.6.2 in the PPS (2014), which states: “Impacts from any new or expanding non-agricultural uses on surrounding agricultural operations and lands are to be mitigated to the extent feasible.”

Modified - revised map to address comment and clarify

City Structure Plan 89 Revised bullet 2. by deleting the partial sentence “beyond the City’s municipal boundary” and substituting “beyond the City’s Urban Growth Boundary”.

No change - policy is intended to apply to the City's municipal boundary

City Structure Plan 89 Policy 89: Suggest new subsection 3, addressing MDS at rural-urban interface, stating "In addition to MDS I, future MDS II implications will be considered where livestock operations or probable future livestock operations could be affected by development proposals on this interface."

No change - covered by the MDS policies in Our Tools part, consistent with the Provincial Policy Statement

City Structure Plan 89 Where are these “Rural-Urban Interfaces”? Are they the green bands shown on Map 6 to Para. 60? Are these interfaces located only where the City boundary abuts an adjacent municipality? Appropriately map the Rural-Urban Interface. Show the interface on Map 1 and provide a definition of the term Urban-Rural Interface in the Glossary.

Modified - incorporate text to Policy 89 to tie the mapping of the rural-urban interface with Map layer 6

City Structure Plan 89 Does Rural-Urban Interface refer to the Urban Growth Boundary, or the Built Area boundary? There is no Urban Rural Interface shown on the maps. No text is provided that refers to the Built Area Boundary that is referred to in text and on maps on pages 30, 31. Suggests entire section should be part of the Urban Growth Boundary section. Should be some reference / description / Policy relating to the “Built Area Boundary” if it is a component of Urban Structure, or it should be removed from pages 30, 31.

No change - Map layer 6 graphically shows the location of the Rural-Urban interface. The City Structure Plan and Urban Growth Boundary chapters have been combined. Map layer 10 of the components of the City Structure Plan graphically shows the location of the Built-Area boundary

City Structure Plan 90 _1 Policy 90.1: This paragraph does not recognize existing railway R-O-W situation. Only one abandoned railway in city and city should oppose abandonment, giving more importance to railways and their ability to meet agricultural connection objectives of London Plan.

No change - policy indicates City response to decisions made by other organizations

City Structure Plan 90 and 91 Consider revising bullet 3. As follows:3. “Explore opportunities for collaborating with the federal and provincial governments and the surrounding municipalities to foster construction of a high speed rail corridor linking London to Windsor and Toronto.”

No change - issue has been added to mobility policies

City Structure Plan 90 Regional Connections, Policy 90: after Thames Valley Corridor add "and tributaries, upland ecological corridors"

No change - policy does not indicate that connections are exclusive to the corridors


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Structure Plan 90 City Structure – REGIONAL CONNECTIONS – page 41 -- clause 90 -- Are the policies on

freight air and rail transport sufficient. The regional connections described in the London Plan need more on this. The Quebec-Windsor corridor that relates to Via Rail’s passenger rail service is noted, but not noted is the fact that London straddles major rail corridors provided by CN and CPR. CN in particular provides direct linkages from London to major port facilities on the Atlantic Coast, Gulf Coast, Pacific Coast and the James Bay-Hudson’s Bay Coast – see Ian Seddon’s comments under separate cover for Figure 3 following page 12 of his submission. Consideration should be given to policies with objectives for working with the railways to develop an intermodal facility in London. This would be an infrastructure development of significance to the activities encouraged within the industrial and rural place types, and further, it would position London as a major transhipment point for southwestern Ontario. Of all the major cities and towns in southwestern Ontario, London, Windsor and Woodstock are the only major municipalities directly served by both major railways. (Ian Seddon has submitted comments that elaborate on this more).

Modified - revisions to mobility framework to highlight rail, corridors, etc.

City Structure Plan 90 City Structure Plan does not explicitly show any important connections, particularly the railways or gateways, although Policy states “Key gateways into the City by street are also illustrated”. If railways and gateways are integral components to the City Structure, they need to be identified on a map. Not all entrances to the City can be considered as key gateways.

Modified - revisions to mobility framework to highlight rail, corridors, etc.

City Structure Plan 91 _3 Regional Connections, Policy 91.3: after "regional rail" add "or bus" service for regular commuters.


City Structure Plan 91 _4 There is no identification of “important gateways”. Suggests need to map / identify (or define) “important gateways.

No change - flexibility provided to allow future dertermination of important gateways

City Structure Plan 91 _6 Regional Connections, Policy 91.6: after natural heritage connections add in brackets: "(aquatic and terrestrial upland)"

No change - the Natural Heritage policies of the Plan clarify the features and areas of the natural heritage system.

City Structure Plan 91 _6 Asks: what is meant by “enhancing” natural heritage connections that extend across municipal boundary? What jurisdiction is there for doing things that cross the boundary? Suggests providing clarification/rewording.

Modified to address concern

City Structure Plan 91 Policy 91: Policies 1 through 6 are commendable! No change - indicates support for the PlanCity Structure Plan 91 Regional connections: promotion of London as hub for high speed rail.

Abandoned rail lines.Modified - revised mobility chapter to incorporate greater reference to High Speed Rail, which strongly promotes regional connections


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Structure Plan 92 MOECC supports the intention behind this Policy (and the linkage to growth management

described elsewhere in the Plan); however they believe the Policy should provide a clear commitment to long term infrastructure planning. MOECC notes that 50 year and 20 year master servicing plans were prepared by the city as part of its Vision 96 process (and recognized by the MOECC as Class Environmental Assessment master plans). To MOECC’s knowledge there have been no updates since. They find the continuation of no apparent public long term planning for infrastructure inconsistent with the kind of forward looking and comprehensive community development planning put forward by the London Plan. They note that Policy 102 and other policies under the heading Growth Servicing refer to aligning infrastructure plans with growth plans (and vice versa), which MOECC supports, but which they have not seen implemented. Policies 119 and 225 imply that the Development Charges Study and the Growth Management Implementation Study provide this linkage. These studies list projects without any analysis of alternatives or comparative evaluation against goals/objectives. These documents are not master servicing plans in their meaning of the term and they certainly are not the equivalent of a provincial environmental assessment as may be required but the Environmental Assessment Act.It is noted that Policy 1295 expressly recognizes the ability of integrating provincial environmental assessments with municipal planning processes. MOECC wonders why the infrastructure/servicing policies do not also recognize this integrated approach.

No change - the City recently undertook long-term 20-year plans for stormater, sanitary services and water services. In addition, the long-term Transportation Master Plan was recently prepared. In addition, the Development Charges Study evaluated the long-term servicing/infrastructure needs of the City and related costs. Finally, the City recently completed a detailed long-term corporate asset management plan that is leading-edge in the province to manage the lifecycle component of insfrastructure over the long term.

City Structure Plan 92 Sustainable Infrastructure Policy 92: for second sentence, note: infrastructure should be distributed and be based on low cost approaches at neighbourhood level, saving money in pipelines and SWM facilities.

No change - the policies under Civic Infrastructure address distribution, safety, and efficiencies

City Structure Plan 92 Asks: what is meant by a “high level” of infrastructure services? Suggests changing wording to “adequate infrastructure services”.

Modified - section rewritten to improve clarity

City Structure Plan 92 This paragraph refers in two places to the concept of “affordable” infrastructure. Though we strive to ensure infrastructure is affordable, we cannot guarantee that prices, regulatory standards, and nature of the works required will always be affordable in everyone’s opinion. SUGGESTION: Remove the word “affordable" (2 places) from this paragraph. Insert a sentence which states: “The City will also strive to ensure infrastructure remains affordable by attempting to identify cost effective solutions and impose defensible standards for engineered services that serve the City’s interests over the long term”.


City Building Policies 93 Whole Part ACE supports the city’s Building Policies chapter incorporating walking and biking under categories of what ‘we are trying to achieve’ and language such as that found on p51, Policy 131 regarding secondary plans that make reference to placemaking, multi-modal transportation network, and active transportation.

No change- indicates support for the plan

City Building Policies 93 Policy 93: should change "how we will grow" to how we will "evolve". A move from growth/competition to vocabulary of evolution and cooperation.

No change - the intent of an Official Plan is about growth and development of a given municipality

City Building Policies 97 Policy 97: new bullet at end of list for: "Ecosystem Services". No change - Green City policies have been modified to specifically address sustainabilty

City Building Policies - Growth Management

98 Scenarios 1 - 3 - pg 47

Sections on growth patterns are not necessary and misleading, therefore they should be removed. Implies that the past pattern of growth was a 'spread model' which is not the case. The growth model used to date is consistent with the London Plan.

Modified - growth scenarios on page 46 & 47 are to be removed from the Plan.



Concerns about the concentration of higher order streets ie neighbourhood connectors in the Near Campus Neighbourhood areas - other areas there's not many of these - we seem to be taking the brunt.



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Growth Management


Include reference point about growth over last 25 years. Modified - growth scenarios on page 46 & 47 are to be removed from the Plan.


98 Scenarios 1 - 3 Maps and costs - pg 47

Figures for scenarios do not mesh with Altus projections, nor with figures on page 45, which state that City is expected to grow by 77,000 people and 41,000 housing units over next 20 years. Scenarios refer to population growth of 191,000 and 101,800 new housing units. These tables are misleading, not based on extensive cost analysis and not reflective of Altus projections. Suggests removing scenario maps and figures



98 Scenarios 1 - 3 Maps and costs - pg 47

1. Costs of 3 different forms of growth - need to inform people that we are closer to the "hybrid" form of growth so that people fully understand that the Plan does not call for a halt to new greenfield dev't for SFD. The demand for SFD will continue (according to Altus report) - since SFD cannot be accommodated within the built boundary it must generally take the form of greenfield subdivisions. 2. Regarding costs of 3 different modes of growth: were revenues investigated? In the spread scenario - assume city would generate more tax revenue because of the higher number of SFD that have a higher assessment value than the average residential unit located in a more dense environment - would offset the higher costs.



98 Whole Chapter Suggest a new heading - "Redevelopment and Retrofit of Existing Buildings". Believe there is high chance not have money or energy to build new in 2035 so need targets for redevelopment and retrofitting.

No change - can be required in monitoring report as required by the Plan.


98 Whole Chapter does it take into account taxes (revenue side of model)? Team to take a look at tax/revenue. Modified - growth scenarios removed


98 Whole Chapter Was P3 design, build, finance and maintenance of infrastructure projects? The BRT would be an appropriate P3 endeavor.

Modified - policy added to 538


98 Whole Chapter Does the LP fully articulate the Cityʼs plan for promoting economic development as directed by the PPS? We are challenged to find any reference to this. As an example, the full opportunities of the land along the NAFTA highway has not been provided its due importance for job creation.

No change - plan is based on platform of economic properity. Expansion of urban growth boundary for industrial uses is in plan now - was a separate parallel process.


98 Whole Chapter It has been sometimes said if London does not want to use this corridor as an employment boosterThen they should lose it. Use it or lose it.



98 Whole Chapter London annexed these land tracts in 1991 not to manage agricultural land, but to address the expansion / development of a major settlement area, a City looking to its future growth requirements.



98 Whole Chapter Notwithstanding the huge provincial infusion of money to reconstruct the Veterans Memorial Parkway / 401 interchange to allow extension to Wilton Grove Rd. and the new Wonderland Rd. extension/401 interchange, there is not a 20 year or longer plan to open this district up for job creation.



98 Whole Chapter The urban growth boundary has not been redrawn to take this district into future consideration. No change - plan is based on platform of economic properity. Expansion of urban growth boundary for industrial uses is in plan now - was a separate parallel process.


98 Whole Chapter Areas along the 401 are specifically excluded from development (Wilton Grove Rd. to Hamilton Rd., east of Wonderland Rd. on both sides of 401, Wonderland Rd. from 401 to 402).

No change - Urban Growth Boundary expansion approved by Council


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98 Whole Chapter Add new policies (either under a new section entitled “Growth Planning” or in the Secondary Plans section):“Council may establish a secondary plan(s) to provide direction for residential and non-residential growth throughout the City and for specific areas of the City. The content of this secondary plan may contain a variety of growth policies, such as growth targets for specific areas of the City, the phasing and timing of future development lands, minimum density thresholds, affordability requirements, and servicing timelines in order to ensure efficient land utilization and infrastructure construction.”“Growth plans will be informed by anticipated market demand and an analysis of the existing and pending supply of permit-ready development lands. Council may choose to promote a pattern of development through a growth plan in order to achieve the goals of this Plan by encouraging shifts in market demand.” “Council may deem a development application to be pre-mature if the proposal is inconsistent with the City’s growth plan. Additionally, development proposals may be deemed pre-mature if there is more than 5 years of readily developable sites in registered and draft approved subdivision plans.”“Council may defer the timing of infrastructure construction through the Growth Management Implementation Strategy process if 5 years of readily developable sites in registered and draft approved plans demonstrate that additional infrastructure investments are not warranted for a given year.”

No change - addressed under Growth Financing policies in the Our Tools part of the Plan


98 Whole Chapter An Official Plan is also intended to be the guiding document on how the City anticipates lands to develop over the next 20-years. It is understood that market forces, etc. can change over time, however, the Official Plan needs to provide some certainty as how the City expects growth to occur. Within the Growth Management section of the Plan, three scenarios for growth are shown under the heading “Growth Forecast”. They reflect how these different types of development would affect the City’s land budget and infrastructure costs. While graphically impressive, the City should be providing more direction as to which of these scenarios the London Plan will follow.

Modified - revised to removed Growth scenarios on page 46 & 47


98 Whole Chapter Spread vs Compact model - clarification on use of term and convey that London is currently uses the Hybrid approach to growing as a city

Modified - revised to removed Growth scenarios on page 46 & 47


98 Whole Chapter 1397 Wilton Grove Rd - UGB expansion specifically as it applies to their lands at 1397 Wilton Grove Road (bounded by Highbury/Greenvalley/Hubrey/Wilton Grove Road) - lands are already supported by services and shovel ready to develop.

Modified - Urban Growth Boundary updated per Industrial lands development strategy


98 Whole Chapter Colonel Talbot Rd/Decker Drive/Wonderland Road S - Represent land owner for 200 ha site on Col. Talbot Rd/Decker Dr/Wonderland Rd. The site selection process for expansion of UGB does not adequately reflect primary site selection criteria previously presented/documented in several Industrial Land selection reports and studies produced since 2012.

No change - Urban Growth Boundary consistent with previous studies


98 Whole Chapter The London Plan does recognize that five year reviews of the plan are required and that on-going evaluations of the need for possible expansions to the UGB will/can occur during these reviews. Farhi land holdings located outside UGB to bring some or all of their lands are beyond the 20 year time-frame.

No change - issue included in Our Tools section of Plan


98 Policy 98: Should think of "Contraction Management" as well as Growth Management, and concerned about language of economy expanding and population growing.

No change - Direction 5 and Policy 103 under Growth Management address strategically supporting growth inward


99 Policy 99: last line: "sustainable" shouldn't be used. Sustainable growth an oxymoron. No change


100 As directed and mandated by the PPS, is the LP consistent with, responsive to and in compliance with PPS policies?

No change - yes, The London Plan, as revised, is consistent with the Provincial Policy Statement, 2014


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101 & 102 MLHU supports strategic growth management where intensification is directed to locations that best support rapid transit, higher residential densities, and multi-modal travel thus enhancing the opportunity for active transportation and achieving the targeted reduction of greenhouse gas emissions.


City Building Policies - Growth management

101 ACE supports that pollution is referenced in the Growth Management chapter p45, Policy 101 and that the city, ( p192, Policy 814), plans to establish a full fleet of city cars and efficient medium and heavy duty vehicles to reduce the city’s carbon footprint. Page 220, Policy 867, is not permitting drive-throughs in the design of proposed rapid transit corridors. Rapid transit and urban corridors p215, Policy 856/7 envision walkable streetscapes and intensification corridors involving more pedestrians, thus, the importance of air quality in these areas.



101 When identifying growth boundary take into account allowable geographic growth that does not increase emergency services infrastructure.

No change - Policy 531 under Public Facilities and Services addresses locating emergency services facilities


101 Use of the term ‘spread pattern’ is inappropriate, as the City has grown in areas that have been designated and planned for development. Furthermore, if the City ‘spreads’, it does not necessarily put greater pressure on natural heritage system – often it ‘spreads’ as a result of retaining considerably larger amounts of the natural heritage system. Also, ‘spreading’ in certain directions / areas may be more cost effective and use municipal services already constructed. Suggests modifying wording. Possible wording could be “If our City grows in an unplanned manner, we may exhaust large amounts of agricultural land, put greater pressure on the natural heritage system and not effectively utilize the infrastructure and municipal services we have developed.....Growing in an unplanned manner could be very expensive compared to growing in more compact ways....”

No change - the reference to "spread pattern" is to provide context in plain language, which is consistent with the approach taken in the ReThink London Discussion Papers


102 Add on p47, growth Policy 102, that the city looks to achieve infrastructure that recognizes population increases to London which include many young professionals who do not own vehicles and want pedestrian friendly communities.

No change - Policy 9 under Our City includes a reference that the Millennial demographic is known for being less automobile focused


104 & 940-943 Policies for intensification/infill development are insufficient to overcome NIMBY responses. Greater clarity is required with regards to expectations for intensification.

No change - policies in the Neighbourhood Place Type provides greater clarity with regards to expectations for intensification, specifically policies 940 through to 949


104 _6 Need to discuss NIMBY and achieving 40% infill. Is it possible given amount of available site? No change - policies in the Neighbourhood Place Type provides greater clarity with regards to expectations for intensification, specifically policies 940 through to 949


104 to 109 The Plan’s intensification policies speak to residential intensification, but are silent on non-residential intensification. Perhaps a Policy could be inserted that encourages non-residential intensification (especially given public concerns raised about major new commercial developments located at the periphery of the City). SUGGESTION: Add new Policy 109: “The City will encourage the intensification of non-residential lands.”



104 This Policy refers to the addition of a “secondary unit”, however the term defined in the OP is “Secondary Dwelling Unit”. Table 13 on page 127 refers to “secondary suites”, which is different term as well. There needs to be consistency in the terminology throughout the document.

Modified - revised for consistent use of the term


104 revised Bullet 1. as follows:1. “Addition of a secondary residential unit.”

Modified - revised to clarify that it is for the addition of a secondary dwelling unit


104 Policy 104: suggest growth pattern of 80% intensification and 20% greenfield in next 5 years. No change - the proposed 40% intensification target will support and implement the strategic Directions and City Structure Plan of The London Plan


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105 Intensification may occur in all of the Place Types that allow for residential uses. No change - yes, this is the intent of residential intensification proposed in The London Plan


105 Intensification "may" occur. Other parts of the plan use "will" or "shall". Should be consistent. No change - the reference to "may" is appropriate for this Policy. The Place Type policies clarify the instances when "may", "will" or "shall" is applied.


107 How is this target anticipated to be achieved? What constitutes the benchmark built area boundary? The boundary illustrated on Map 10 is already out of date. Why was 2011 chosen for the Built Area Boundary? Provide clarification on how this target is to be implemented and monitored.



107 States that 40% of new residential development “will be” within the built area boundary. How will / can this be regulated? Suggests revised wording to state “Forty percent of all new residential growth is intended to be accommodated...”



107 capitalize "built area boundary" Modified - revised to add hyphen, only. The Provincial Policy Statement does not use capitals


107 We support the establishment of a 40% intensification target. This Policy will assist in guiding future growth and may reduce the need for some growth infrastructure projects at the periphery of the City, resulting in more efficient utilization of services and reduced DC fees. Many other municipalities that have adopted intensification targets specify a year for the achievement of the target and that 40% intensification is an annual requirement. It is suggested that these provisions be added to the Policy. A two-year phase in is proposed for the intensification target. SUGGESTION: revised to: “A minimum of forty percent of all new residential development will be accommodated occur within the built-area boundary of the City annually by 2017 and every year thereafter; for the purposes of this Plan, this will be referred to as the “intensification target.”


Urban London Place Types - Neighbourhoods

107 Suggest adding a reference to Map 10 (on pg. 31) as part of this Policy. Also questions whether "Built Area Boundary" is the same as UGB, noting Built Area Boundary is not a commonly used term.

No change - the built-area boundary does not change over time. Current boundary is same as 2006 boundary


110 to 114 Policies 110 through 114: These policies, especially those listed under 114, are commendable! No change - indicates support for the Plan


110 to 116 Policies 110-116 Policies should be incorporated into the Growth Management policies immediately following section 116 regarding establishing a working group/representation from stakeholders and evaluation process (refer to Council Direction of December 13, 2013). Land Needs Study for expansion of UGB - Study flawed as study suggests housing forms and densities which are not characteristic of trends experienced in London but more typical of greater GTA. Tridon believes there is still is an opportunity to bring lands into the URB (Policy 116). Formation of the working group has yet to occur and how submissions will be evaluated remain unknown.

No change - the comment refers to a procedual matter from municipal Council, but was not required to be included in the Official Plan. Our Tools policies, 1482 through to 1484, address requirements for future amendments to The London Plan.


111 Policy 111: doesn't understand why the UGB would be expanded. No change - this Policy is consistent with the Provincial Policy Statement (1.1.3.8 PPS)


111 Tie into the “provincial interests” section (S. 2) of the Planning Act, which requires that land supply should be in the right location. revised Policy to read as, “(…) will be evaluated to ensure there is sufficient economically serviceable land available.”

No change - policies are consistent with PPS requirement


112 Policy 112: Disagrees. Thinks 90-100% intensification within 20-50 years and only "ecovillages" should be allowed to develop outside UGB.

No change - this Policy is consistent with the Provincial Policy Statement


114 _3 Policy 114.2 : what is definition of "complete" community? Live, play, shop and work or just live and play? Should be in Glossary/Definitions.

Modified - added term to glossary


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114 _3 Does "complete neighbourhoods" mean Planned Communities? Does it mean areas that have undergone an Area Plan but have parts that are outside the UGB?



114 _5 Policy 2.3.5.1 of the PPS (2014) states: “Planning authorities may only exclude land from prime agricultural areas for expansions of or identification of settlement areas in accordance with Policy 1.1.3.8 and at the time of a comprehensive review.” RECOMMENDATION: All of the land outside of the City’s urban growth boundary constitute a prime agricultural area, as per the definition in the PPS. Consequently, any UGB expansions will need to meet the following tests found in 1.1.3.8 (c, d and e) of the PPS (2014):• the lands cannot be a specialty crop area;• alternative locations which avoid prime agricultural areas or are on lower priority agricultural lands in prime agricultural areas must be evaluated;• the expanded settlement area must be compliance with the minimum distance separation formulae; and,• impacts from the expanded settlement areas on surrounding agricultural operations must be mitigated to the extent feasible.Therefore, Ministry staff require that the current Plan Policy #5 be modified to state:“Minimize Mitigate the impact on agricultural operations, lands and practices and recognize meet the Province’s Minimum Distance Separation setbacks Guidelines. Expansions of the Urban Growth Boundary onto into the prime agricultural area lands will be avoided unless there are no alternatives outside of the prime agricultural area. Where no such alternatives exist, future expansions shall take place on lower priority agricultural lands. Expansions of the Urban Growth Boundary into specialty crop areas shall not be permitted.”

Modified - revised to address comment for consistency with the Provincial Policy Statement


114 MNRF is unclear what is meant by “the natural heritage system” in this context. Does this include all the City’s natural heritage features and areas that are identified in Map 7, or the natural heritage and parks system discussed in Policy 60?Map 3 of Policy 60 and Map 6 illustrate two different natural heritage systems and it is not clear which natural heritage system is referred to here. RECOMMENDATION: MNRF recommends that all natural heritage features in the City of London are considered as part of these criteria and not just those natural heritage features and areas that are currently considered as part of the Thames River Valley Corridor, as discussed under Policy 60.MNRF suggest that the City consider the general comments with respect to the natural heritage system and that a new map is created and referred to wherever the natural heritage system is mentioned. For Policy 114, this would make it clear what areas of the City would be considered with respect to expanding the Urban Growth Boundary and would ensure the protection of the City’s natural heritage features and areas.



114 Policy only refers to UGB expansion, not alteration, however Policy 113 does allow for alteration. Suggests modifying wording as follows: “Where the Urban Growth Boundary is expanded or altered to meet required land needs or emerging opportunities....”

No change - Policy 113 does consider possible change to the Urban Growth Boundary (UGB) and Policy 114 establishes the criteria for considering a possible change to the UGB


115 A settlement boundary expansion can only occur upon completion of a comprehensive review and the demonstration that additional lands are required. If the lands have been demonstrated to be needed for particular types of uses, shouldn’t the use of those lands also be designated for those particular place types at the time of inclusion?

Modified - revised to incorporate policy regarding a comprehensive review of the Official Plan


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116 Policy 116: believes Policy 116 (UGB expansion Policy) contradicts Policy 112 (intensification target Policy).

No change - Policy 112 is for consideration of changes to Urban Growth Boundary as part of every five-year review of this Plan, Policy 116 is for private applications between the five-year review periods.


117 to 130 The policies do not make clear that developers, not taxpayers, will be charged for the costs of servicing infrastructure in new development areas (as stated in Policy 545).

No change - Policy 117 is clear that growth -related capital costs will be recovered from revenues generated from new development. The Development Charges and Growth Management Implementation Strategy, identified in Policy 119, addresses how this will be implemented


119 This Policy requires the DC Study to contain provisions to plan and budget for “all municipal services to support growth and development…” The DC Study, however, defines in its Local Service Policy applicable developer funded works and only major works are included in the DC rate calculations. Further, there are several municipal services that have growth needs that are presently not included in the DC rates (e.g., water supply and operations facilities). This proposed OP Policy has good intentions, but may be too broadly worded to place unintended burdens on future development charge rates. SUGGESTION: revised to: “Through the Development Charges Study and By-law, and the Growth Management Implementation Strategy, the City will plan and budget for the construction of major municipal services to support growth and development consistent with the City Structure Plan; this will include planned growth on vacant lands and planned growth in the form of intensification. The ability to finance planned growth works will depend in part on the health of the DC Reserve Funds.”

Modified - revised to address comment. Policy 119 updated


120 This Policy speaks to temporary servicing arrangements. MOECC's position on temporary services has always been based upon the notion that the installation of temporary services should not in any way impede or prejudice the installation of permanent services. Therefore MOECC’s position is that the conditions under which temporary services could be provided should be set out in a master plan which describes what the ultimate or permanent servicing is; what steps, including temporary services, could be considered in getting to the permanent solution; how long is temporary; and provides for decommissioning. Clause 120 does not explicitly do this.



124 Growth Servicing, Policy 124: System will collapse when development fees cease and have a huge infrastructure that can't be maintained or refurbished.

No change - this Policy will be implemented by Development Charges and the Growth Management Implementation Strategy.


126 & 127 Page 50, Policy 126 and 127: While we do not disagree with the policies, from a planning perspective, one would hope that we are not including lands within the Urban Growth Boundary that are beyond the City’s financial and physical ability to serve. If we are, then we should be asking ourselves why.

No change


126 The DC By-law is the vehicle to recover DC-eligible growth costs, however, the specific projects are identified in the Background Study. As well, implementation for the funding of infrastructure projects is provided through the City’s annual capital budget. SUGGESTION: revised to: “Development will be allowed within the Urban Growth Boundary only where the City has the ability and financial capacity to provide infrastructure services in accordance with the Development Charges By-law and Background Study, and capital budget, and to meet provincial environmental standards governing municipal services

Modified - revised Policy to incorporate suggested edit


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128 - add "at the expense of the developer or proponent" No change - the preceding policies on Growth financing policies clarify that growth-related capital costs will be recovered from revenues generated from new development


129 How does this impact the re-designation of lands within the White Oaks Business Park? No change - Policy 544 under Civic Infrastructure addresses servicing studies to accommodate growth, system improvements, life-cycle needs and regulatory changes


129 Paragraph 129 speaks to municipal services needing to be in place prior to development proceeding. An additional Policy is suggested to state that applications may be refused if existing or planned infrastructure cannot accommodate the proposed development. SUGGESTION: Add new Policy 129: “New development will not exceed the capacity of existing and planned engineering services and community infrastructure. Development proposals may be refused if:i. existing or planned infrastructure are inadequate to support the additional population and/or employment growth that would be generated orii. according to the approved capital budget, the timing of provision of infrastructure needed to serve the development does not coincide with the intended timing of the development in question (in the latter case, a Municipal Servicing and Financing Agreement Policy exists that may be used to accelerate the timing of growth infrastructure).”

No change - already addressed in policies of the Plan


129 Underutilized land results in urban sprawl and cost ineffective servicing. DC revenues that result from underutilized land are lower than those that would be achieved at higher densities, if those higher densities were anticipated during the infrastructure planning stages of development and DC rate calculations. SUGGESTION: Add:“The City may study whether the issues created by underutilization of infrastructure are sufficient to warrant corrective policies or incentives.”

No change - already addressed in policies of the Plan


130 add.. as well as the range of other municipal services including recreation and social services No change - Public Facilities policies provide the necessary policy direction to address this matter


131 _3 Secondary Plans, Policy 131.3: suggests that "placemaking design framework for development" should be changed to "placemaking, including sustainability" design framework

No change - Policy 131_2 provides the necessary policy direction, under the City Building Policies, to address this matter


131 As commented on previously, it is not clear what the meaning of natural heritage system is with respect to this Policy. Does it mean all the natural heritage features and areas that occur in the City of London (Map 6) or just those natural heritage features that are connected to the Thames River Corridor (Policy 60)? Further, Policy 2.1.3 of the PPS requires that natural heritage systems are identified, while policies 2.1.4 – 2.17 of the PPS provides for the protection of significant natural heritage features. RECOMMENDATION: MNRF suggests using the term “natural heritage features and areas” instead of natural heritage system. For example, this could be revised to:Delineate, protect and enhance the City’s natural heritage features and areas and the linkages between them.

Modified to address comments


132 States that secondary plans will be integrated with Class EA’s. That is not always necessary or appropriate. Suggests modifying wording as follows: “Secondary plan processes....minimize duplication and streamline processes where appropriate and applicable.”



132 Concept of an integration approach could be contradictory. The wording does not reflect reality as it’s not always possible to integrate (ex. Southwest area Plan). revised to “where possible”.



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133 Policy 133: This is a repeat of Policy 115. No change - Policy 115 refers to application of an Urban London Place Type or until a secondary plan is prepared, and Policy 133 is explicitly for secondary plans; therefore, is listed under "secondary plan" policies of the Growth Management chapter.


133 This chapter could be strengthened through including a section on the Corporate Asset Management Plan. I would think the province would want it to be integrated as they requested municipalities develop them.

Modified - policies from City Structure Plan part brought to this chapter


134 Why is it "may be subject" to preparation of secondary plan, not "shall/will"? If neighbourhoods are going to be changed to be made "complete", there better be a plan with lots of "engagement" before the changes begin being made.

No change - not all existing developed areas necessitate the preparation of a secondary plan. Policies 158 and 159 under the urban regeneration policies states that the city will engage stakeholders, including landowners, residents and busines owner groups to establish how positive growth and change will be accommodated.


137 Does a ‘reasonable timeframe’ mean five years, as referred to in the following Policy? Somewhat repetitive to Policy 138. Suggests policies 137 and 138 be combined into one.



137 Cross reference these to 138, change to 3 years. Modified - revised to address comment, changed to 3 years


138 The approval of planning and development applications five years in advance of expected provision is an concept that may had its roots in the Urban Works approach to financing infrastructure. Under this approach, developers would front end the infrastructure, under the understanding that they would absorb all financing costs and take the risk as to when their investment would be repaid. With the new MSFA policies put in place during the 2014 DC Policy review process and the GMIS approach to the planning of infrastructure, this approach is no longer considered realistic, or feasible. This presents problems for the City in financing infrastructure as it essentially commits the City to construction of infrastructure where other avenues are in place (i.e., GMIS process and Capital budget approval process) to approve financing of infrastructure required by growth. SUGGESTION: We suggest that this provision be removed and the following put in its place:“The City may entertain approval of planning applications if there are current plans for the servicing of those sites being constructed within three years of the submission of the application. For proposals up to 5 years out, the acceleration of infrastructure through a Municipal Servicing and Financing Agreement will be necessary to progress such proposals. In both cases, a holding provision may be applied.All City financial commitments for funding of infrastructure are subject to the annual capital budget approval process (which in turn is informed by discussion with community stakeholders through the Growth Management Implementation Strategy Update) or through municipal financing and servicing agreements (according to MSFA Policy) that provides for terms under which the construction of infrastructure may be accelerated in a financially prudent manner.”

Modified - revised to address comment, changed to 3 years

City Building Policies - City Design

139 to 151 Our view of the Policy requirements of this section are not suitable for practical application to our campus.

No change - general comment regarding Fanshawe campus


139 Whole Chapter We find this section in general to be too prescriptive and many of its requirements are impractical for our campus community.



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - City Design

139 Whole Chapter MLHU, in conjunction with Western University and Health Canada, conducted a study of the urban heat island effect in Middlesex London (March 2014), using Environment Canada’s Urban GEM-SURF numerical modeling to assess the heat island effect on the City of London and on its citizens. We recommend that the results and recommendations from that study be considered in city designing in order to mitigate the adverse health effects of the heat island effect.

No change - addressed under Urban Forest policies


139 The answer to this question begs a more comprehensive response that seeks to describe the “nature of city design”. For example:“139_ City design is the purposeful planning, design, development, management and integration of the built and natural elements and landscapes of a city by both private and public sector agents and agencies. It instigates, is governed by and is an outcome of this Plan.”

No change - general commentary


139 It is unrealistic/unfeasible to expect developments to apply all design requirements in the LP, however staff may interpret the LP this way. revised wording such that not all policies need to be included in every development. These highly prescriptive policies may alienate the development community



140 Whole Chapter The policies in the City Design section look good. No change - indicates support for the Plan.


140 The City Design chapter, p53 Policy 140 notes young professionals seek walkable communities. Add, London recognizes the need to attract and retain this talent through demographic effectiveness assessment of their needs.

No change - addressed under Our City


140 It’s important to recognize the efforts of those who have worked tirelessly to advance the design and identity of our city to date and who understand its importance to the economic health of our city.For example:“140_City design in keeping with this Plan is one way London will reinforce its unique identity and continue to distinguish itself.”



140 Policy 140: change by adding the text in parentheses as follows: 1. …A captivating "and sustainable" city design creates… 2. …cities that are exciting, authentic, "healthy, resilient", and walkable, and businesses want to locate...

Modified policy 142 to incorporate this language


141 Whole Chapter Should the UD Panel be replaced with a more general term – DESIGN REVIEW and define it to include the Panel or other means. The Urban Design Review Panel is but one way of doing DESIGN REVIEW.

No change - UDPRP was established by Council for this purpose


141 Link the answer to Why is city design important? to The London Plan’s vision.For example:“141_ City design that follows this Plan will lead to a more exciting, exceptional and connected London.”



142 _11 How are "strong and vibrant neighbourhoods" measured? How are "complete neighbourhoods" measured?



142 _2 Subsection 2 states "An integrated and supportive relationship between the private realm and public realm". What does that mean?

No change - issue addressed in policy 139


142 _3 Subsection 3 states "a cityscape that carefully integrates natural and built features". Asks what does this look like? Woods surrounded by buildings? The Plan has used "protect", "integrate", "carefully integrate", and sometimes "enhance" natural features. "Protect" and "enhance" are understood, but what not sure what's meant by "integrate". Does it mean SWM ponds integrated into NHS?

No change - policies 143 - 149 provide direction. Policy 568 addresses this issue


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142 It is unclear whether the question seeks an answer which expresses the city’s objectives for city design or lists goals to achieve city design.For example:“All city design is to contribute positively to the achievement of:1. A connected, dynamic, resilient city.2. Integrated private and public realms.3. Integrated built and natural systems and elements.4. Integrated and interconnected active, public and private transportation networks.5. Complete neighbourhoods and streets.6. Contextually-relevant development.7. Sustainable development.8. Linked natural areas and parks system.9. Lighter, greener, cheaper, smarter infrastructure. (Condon, 2010)”

Modified - wording revised to fit in context of all the policies in 142.


142 The response as written is grammatically weak and missing the action verbs. Modified - wording revised


142 Policy 142: verb missing before the colon and list of actions. Modified - wording revised


142 Suggests rewording as follows: “...as a municipality, we will strive to achieve:” Modified - wording revised


142 Opening sentence does not make sense with the list. SUGGESTION: Instead of saying “…we will:” perhaps say “….we will strive for:”

Modified - wording revised


143 to 149 The over use of the prescriptive term “will” or “shall” in sections 143 to 149 leaves little room for design creativity. There are approximately 90 prescriptive policies in Paragraphs 143 to 149. Replace the term “will” with “may”, “should”, “is preferred”, “encouraged”, or “shall be encouraged” to allow for design creativity.

Modified - wording revised for consistent usage of will and shall throughout the plan and allow for greater flexibility in approach to meeting policy objectives


143 Greater flexibility in design is needed - concern that some designed requirements will limit creative planning and design processes.

Modiied - revised will, should and may


143 The heading is ambiguous. Suggest wording to the effect:“143_ Achieving our City Design goals” or“143_ How do we achieve our city design goals?”

No change - request is not consistent with approach taken throughout the Plan.


143 First use of the term ‘objectives’ linked to City Design. It’s assumed the objectives are the ‘initiatives’ of 142_ which would then cast the list in 143_ as city design goals.For example:143_ To achieve our city design goals, all planning and development applications, public projects and all by-laws shall conform with the City Design policies relating to: …

No change - use of terms is consistent with plan.


143 Policy 143 (How are we going to achieve this?): add new bullet at end of list for "Sustainability" No change - addressed under Policy 143_9 & 10, and integrated as part of the policies in the City Design chapter.


143 There are circumstances where not all of the policies contained within this Chapter will be applicable. Flexibility should be incorporated to require conformity with only the applicable polices. Consider revising to read as, shall conform with the following City Design policies where applicable (. .)“

Modified - wording revised for consistent usage of will and shall throughout the plan and to allow for greater flexibilty in the approach to meeting design objectives.


143 States that “all” applications, public projects and by-laws “shall conform” with the city design policies. There are many by-laws (and public projects) that have no relationship to city design. Suggests rewording to "all applicable applications…"

Modified - to reference all relevant by-laws.


143 This section should mention the engineering design standards that keep the City safe. Roads and utility services have requirements that should be supported in the Official Plan.

No change - addressed under complete streets manual and city standards manual.


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144 _1 Lotting: Bullet 1 - should be modified to incorporate reference to the preferred street pattern i.e.“Neighbourhoods will be designed with a diversity of lot sizes as generally allowed within a grid or modified street grid.”



144 _1 Character and Identity: Recommend second sentence of bullet 1. be re-worded as follows:“Where adopted, such guidelines will inform all planning and …. “

No change - it is the intent that guideline documents be used for review (refer to Policy 1434).


144 _1 Edges, Focal Points and Parks: Bullet 1 - is about character and identity. It could be the lead in to the ‘Edges, Focal Points and Parks’ section.

No change - purpose of policy is to describe principle of good design


144 _1 Policy 144.1: Policy begins that guidelines may be adopted by Council. Guidelines are a difficult process. How can they be amended? How can a legitimate proposal contest validity or appropriateness of staff's application of guidelines adopted outside of processes of the Planning Act?

No change - Policies 1432 to 1436 addresses how guideline documents are intended to be prepared, amended, and implemented.


144 _1 Safe, Accessible and Healthy: Suggests that "demographic populations" is unnecessary 'buzzword' language and that ending Policy with "safe for all" is sufficient/more accessible.



144 _1 Reliance on guideline documents is problematic, particularly as it refers to “all” applications and public projects. Many projects are not relevant to design guidelines. Suggest revising wording.



144 _1 Edges, Focal Points and Parks: Does this mean for NEW neighbourhoods only? No idea what is meant by subsection 1. Asks how does the design of edges create character and identity? Many neighbourhoods are defined by arterial roads at their edge and that character and identity is from businesses and open spaces in the area (e.g. in Oakridge, Old South and Orchard Park/Forest Hill)

Modified - maintains intent to establish edges and elements that contribute to character


144 _1 to 144_5 Edges, Focal Points and Parks: These policies are too prescriptive as not all of these policies are applicable in all circumstances. Considering revising these policies so that they apply, “where appropriate".



144 _1.4 Character and Identity: remove "in the neighbourhood". Modified - revised to address comment


144 _12 Streets and Streetscapes: It is not clear how the upgrading of building facades, which is a private undertaking (except for public buildings), can be coordinated with the other public improvements listed in this Policy. Provide clarification on how this Policy is to be implemented.



144 _2 Character and Identity: Recommend bullet 2. be re-worded as follows:“Neighbourhoods will be designed to convey a character related to their built and natural context.”

Modified - comment addressed in a separate bullet


144 _2 Street Trees and Landscaping: Consider including reference to native species and the need for a diversity of street tree types.



144 _2 Lotting: Bullet 2 - refers to window streets. How do window streets fit with a gridded street imperative noted in bullet 1. under ‘Streets and streetscapes’?

No change - window streets can fit under modified street gridded system under streets and streetscapes.


144 _2 Lotting: This Policy should be flexible to be able to respond to unique circumstances in a manner similar to Section 20.5.3.3(iv)(e) to the SWAP Secondary Plan or so that it applies, ‘where appropriate”.



144 _2 (Lotting section) States that neighbourhoods “will be” designed to preserve view corridors. That is not always possible. Suggests wording should provide more flexibility and definition should also be provided for “view corridors”



144 _2 Safe, Accessible and Healthy: Needs to be strengthened to speak to the infrastructure being managed and sustainable over time.

No change - addressed in Civic Infrastructure chapter.


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144 _2 Character and Identity: Does subsection 2, referring to "will be designed to have sense of place/neighbourhood character", apply to new subdivisions? Or is this for existing neighbourhoods that are not complete and will be redesigned?

Modified - to improve wording, applies to all neighbourhoods.


144 _2 Street Trees and Landscaping: bullet 3 - at end add "…wildlife (especially pollinators), allow for food production and stormwater management."

No change - pollinators better addressed under Green City or Food Systems.


144 _3 Lotting: This issue needs to be examined in greater detail to determine if greater flexibility is needed. What are the implications to subdivision design?

No change - rear lotting is not the desired form of development


144 _3 Character and Identity: Should "each neighbourhood" be changed to "each new neighbourhood"? Suggests that the geographic boundaries of neighbourhoods should be defined. Also questions the use of "will be" to state that "community vision and character…will be identified". Notes that existing neighbourhoods do not have community vision/character statements, although they have character as opposed to "planned character". Asks if existing neighbourhoods will get vision statements before the new Plan takes effect or is this a "nice to have"?



144 _3 Edges, Focal Points and Parks: Policy refers to "augmenting" NH features. Asks if "augment" is the same as "enhance"? Suggests that it should be NH "functions" as well as NH features". Asks if an open space system is part of the NHS? If ESAs are Open Space Parks, then what kind of parks will be strategically located? Since there is a Parks classification system in Policy 493, the looser use of "park" here and other places creates confusion and uncertainty because it provides flexibility to mean more than one thing. And for NHS that would mean a DIMINISHMENT of natural features and functions in the face of increased recreational use.



144 _3 Street trees and landscaping - objectives on all streets (eg - small lots) may not be able to fit them in.. Ties with 149_2. remove reference to "large" street trees and "maximum". Change reference from "will" to "should"



144 _4 Edges, Focal Points and Parks: Is it all of these things, or things such as those listed? Modified - revised to allow flexibility


144 _4 Streets and Streetscapes: There needs to be a better way to establish connections that do not require a full road allowance. A road should not be the only means of establishing a pedestrian connection. What about the recently constructed, lit, pedestrian path between Bradwell Chase and Pelkey Road in the Sunningdale neighbourhood?

No change - there will be opportunities to provide pathway connections, however they may not replace necessary road connections.


144 _4 Safe, Accessible and Healthy: Asks why "Natural heritage areas" is not called "Natural Heritage features and functions"; Notes that Policy 142 says NH will be integrated, so suggests that "protect" is contrary to that; Asks what does "sustainable" mean that is different from "protected" and "preserved"? ; and also suggests that there is a conflict with point #3 of Edges, Focal Points and Parks (pg. 56), because in that Policy parks "augment" NHS and Open Space system, whereas all (parks, NHS, and Open Space) are part of the same category in other parts of plan. So different meanings for these 3 things in different policies.



144 _4 Policy states heritage buildings and historical elements “will be conserved as focal points”. That is not always possible or appropriate. Suggests revising wording to “are encouraged to be conserved”. Policy should also make reference to applicable HCD / HC documents.



144 _4 Character and Identity: #4 suggests existing, #5 says new. Add "redeveloped" to be consistent with intent.

Modified - revised to improve clarity - applies to redevelopment


144 _4 144 - Streets and Streetscapes #4 - will walkways be maintained (ie - salted and plowed). Should recognize that in new neighbourhoods these paths are typically not lit or plowed

No change - hence why they are not considered as alternatives to road connections.


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144 _4 Streets and Streetscapes: The utilization of public pathways, regardless of their location, provides connections between neighbourhoods, from a planning perspective. It is the City’s maintenance practice that limits their function. Accordingly, public pathways, regardless of their location should be considered as neighbourhood connectors. Identify alternatives to establishing pedestrian connections that do not require a full road allowance.

Modified - changed to pathways and walkways in policy. Walkways/pathways are not an appropriate alternative for streets where necessary connections are required. Pathways are not lit or maintained during winter months undermining safety and accessibility.


144 _4 Character and Identity: This Policy is too prescriptive; there is a need to provide context and flexibility in its application. The use of the word “will” denotes an action is expected or required and is an alternative form of “shall”. Consider revising so that the Policy only applies to designated heritage buildings and elements in accordance with the Ontario Heritage Act, or where appropriate and justified. Provide clarification on what the use of the word “neighbourhood” specifically denotes. Add a definition of "Neighbourhood" to the Glossary.



144 _4 Edges, Focal Points and Parks: It is not clear who will be responsible for these features and their costs. How does this Policy relate to the section 37 (Bonusing) or 51.1 (Parkland) of the Planning Act? Provide clarification on how this Policy is anticipated to be implemented.



144 _4 Character and Identity: What is “heritage” in the context of this Policy? Is it designated, listed, or just simply stating that it is X years old?



144 _4 Safe, Accessible and Healthy: Is a lawn or a pasture to be preserved and protected as a natural area?



144 _4 Safe, Accessible and Healthy: It is not clear what constitutes a “natural heritage area” in this context. Does it include only “significant” areas? How does this Policy relate to PPS? Consider revising this Policy to provide greater clarity on the specific type of “natural heritage areas” that will be protected.



144 _4 Streets and Streetscapes: This Policy conflicts with Para. 492, Ss. 6, and Para. 501. No change - policies do not conflict. Listed policies intended to apply the same provision of the Planning Act to secure linear pathways for mobility in identified open space areas.


144 _4 Suggests (1) that "crime prevention through environmental design" should all be capitalized as "Crime Prevention Through Environmental Design (CPTED)" and that (2) CPTED says to get rid of vegetation in areas where there is people. If NHS areas are "integrated" you will have to remove vegetation. Asks if that is the intent?



144 _4 Streets and Streetscapes: Indicates pathways will not be considered a means of establishing connections as they are typically not plowed. Perhaps OP should state that pathway connections shall be plowed.....

Modified - changed to pathways and walkways in policy. Walkways/pathways are not an appropriate alternative for streets where necessary connections are required. Pathways are not lit or maintained during winter months undermining safety and accessibility.


144 _4 Edges, Focal Points and Parks: States that public art, etc. “will be” incorporated into new neighbourhoods. By whom? Is this necessary / appropriate all the time? Suggests the wording should provide more flexibility.



144 _4 Safe, Accessible and Healthy: Policy states natural heritage areas will be preserved, with no reference to significance. Suggests rewording as follows: “Significant natural heritage areas will be preserved....”



144 _5 Lotting: Bullet 5 - should be strengthened as follows:“Retaining walls are unacceptable along street frontages.”

Modified - revised to improve clarity and allow flexibility


144 _5 Safe, Accessible and Healthy: Walkways that lead up to schools are not maintained by the City and are a barrier to active transportation when obstructed by snow. Two schools identifying this concern are Stoneybrook and Clara Brenton

No change - Reinforces need for roads to provide pedestrian access.


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144 _5 Character and Identity: This Policy is too broad and prescriptive and does not provide flexibility for circumstances where these features cannot be reasonably integrated into neighbourhoods. Consider revising this Policy to provide flexibility in its application (e.g., “integrated into new neighbourhoods, where appropriate,’” for features that are significant or notable.



144 _5 Character and Identity: Page 55, Policy 144_5: “Existing Landscape and topographical features will be retained and integrated into new neighbourhoods”. Pursuant to the provisions of the Natural Heritage Policies within the London Plan?



144 _5 Streets and Streetscapes: The implications of this Policy on subdivision design are not clear. Perhaps verbiage which provides more flexibility than “will be” should considered here. There are many types of design criteria which are considered when designing neighbourhoods and it is not always possible to implement all, as some compete with one another. This Policy conflicts with Para. 484 (“Plant More”), Ss. 10. The City should provide guidance on how to achieve this Policy through subdivision design.



144 _5 Safe, Accessible and Healthy: Generally okay, but policies should be supportive of active transportation in appropriate locations. For example, there is no use to a bike path that doesn’t connect destinations. Consider revising this Policy so that active transportation facilities are incorporated "where appropriate".

Modified - revised to include "connected"


144 _5 Character and Identity: Notes that SWM unit of City may have some concerns about retaining topographical features.

Modified - revised to allow flexibility, issue also addressed under Policy 541.


144 _5 Character and Identity: States that existing topography and landscape “will be retained and integrated.” That is not always possible. Suggest revising wording.



144 _5 Streets and Streetscapes: States that streets, lots, buildings “will be” designed for solar orientation. That is not always possible. Wording should provide more flexibility.



144 _6 Streets and Streetscapes by adding the following to second sentence “…or where buildings are fronting onto Major Streets where front-loaded garage access is not permitted and as an alternative to window street designs.”



144 _6 Streets and Streetscapes: Indicates rear laneways may be permitted.... Suggests a Policy needed that accepts them as publicly owned and maintained as well.

No change - ownership is an operational issue


144 _7 Safe, Accessible and Healthy: Bullet 7 - should be repositioned as a general design imperative which emphasizes that all municipal physical design (public realm and public buildings) should meet applicable federal, provincial and municipal accessibility legislation including but not limited to the City of London Facility Accessibility Design Standards .



144 _7 FADs tied to buildings only. Should expand to universal accessibility and accessibility design standards. Also add to "what are we trying to achieve"



144 _9 Safe, Accessible and Healthy: The word sustainable in bullet 9 should be defined in the glossary.

Modified - reference included to Green City chapter for additional information


144 _9 Safe, Accessible and Healthy: Policy 144.9: This subsection raises a question: Will all new place types incorporate sustainable development features?



144 _9 Safe, Accessible and Healthy: The implications of this Policy are not clear as no information is provided on what “sustainable development features” are or how this Policy is to be achieved. Consider revising this Policy to provide clear direction on what constitutes “sustainable development features” or direct the reader to another section of the LP where this Policy is expanded upon.

Modified - reference included to Green City chapter for additional information


144 _9 Safe, Accessible and Healthy: States that new neighbourhoods “will” incorporate sustainable development features. That is too prescriptive. Suggests rewording as follows: New neighbourhoods are encouraged to incorporate.....”



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144 Whole Chapter Establish gateway changes to beautify Wellington Road corridor @ Hwy 401/Wellington Road rather than promoting industrial odours and unkept uses.

No change - gateways and beautification of Hwy 401 is addressed under 1115_2 and 1115_3. Other similar form policies apply to all Industrial Place Types (see Policy 1115).


144 Street Trees and Landscaping: Add trees that offer ideal habitat for pollinators will be planted wherever possible, also city street landscaping will encourage the planting of short and tall prairie grasses and other native flowers, shrubs and trees that offer habitat for pollinators.



144 144 - difficult to refer to policies as there are a number of lists. Modified - revised to include section numbers


144 Neighbourhood Design: article be re-worded as follows:“Neighbourhoods exist and will be developed within different city place types (Map 4; p. 404). The following neighbourhood design policies will apply to all Urban London Place Types as well as the Rural Neighbourhood Place Type.”



144 For ease of reference and clarity the policies under 144_ should be numbered consecutively. Thus bullet 1. under the heading ‘Safe, Accessible and Healthy’ would be numbered bullet 6. and so on.

Modified - revised to include section numbers


144 Street Trees and Landscaping: All the policies are commendable. No change - indicates support for the Plan.


144 Edges, Focal Points and Parks: add new last bullet: "All neighbourhoods will provide space for community to grow food in community gardens, including fruit/nut trees and provide areas for compost of organic waste from backyards and allow community to build simple structures (playground/gazebo) where the community plays and works together."

Modified - Policy 144_4 revised to address comment


144 Safe Accessible and Healthy section. Add new 10th bullet for: "Old buildings/neighbourhoods will be retrofitted with sustainability in mind".



144 Streets and Streetscapes: add new last bullet: "Streets should be viewed as sustainability corridors where besides transport and utilities there is space for SWM bioswales, biodiversity gardens (pollinators and other organisms), food production areas (fruit/nut trees plus vegetables), and places where we put renewable technologies that work on neighbourhood scale (geothermal loops in blvds)."

No change - such opportunities are addressed in City Building policies on Civic Infrastructure, and will also be covered in the Complete Streets Design Manual (refer to Policy 198).


144 Is very prescriptive and seems to dictate with the word “will” used so often. Perhaps the wording could be improved by stating that the goals and objectives of what we are trying to achieve will be based on a review of the following criteria – then list the criteria …. (144) have a sense of place …. address neighbourhood character … respect cultural and natural heritage …, etc. The use the word “will” should be preserved for those matters such as safety and health, natural and man-made hazards. For example on page 55, items under Character and Identity, all clauses from 1 thru 5 could be “criteria”. Under Safe, Accessible and Healthy, clauses 1, 2, 3, and 7 could use the word “will”. All others could be listed as criteria to be addressed for evaluation.

Modified - revised to address comment and to add flexibility


144 Neighbourhood Design: It is not clear what constitutes a “neighbourhood” when referenced in these policies. Does it comprise a draft plan; multiple, integrated draft plans; all of the lands within an arterial grid block, the City’s planning areas?



144 Neighbourhood Design: Generally, the sub-headings within this section get lost to the reader and are difficult to follow. Without a specific sub-section number, it may be difficult to properly reference these sections.



144 Numbering of policies in Policy 144 will lead to confusion – cannot reference sections by number as there are several 144.1, etc. under various headings, but headings are not numbered.



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144 Under Neighbourhood Design include a Policy to address design to accommodate emergency services.

Modified - policy added


144 Streets and Streetscapes: Acknowledge snow maintenance needs. No change - snow maintenance to be covered in the Complete Streets Design Manual (under Policy 198). The intent of this Policy is about the overall design in terms of street layout.


144 Include emergency services in the list Modified - policy added


145 _2 Policy 145.2 after word topography add "and other biophysical attributes (soil, vegetation)" of a site…

No change - comment adds too great a level of detail for the intent of the policy


145 _6 Retaining and incorporating trees runs counter to storm water management needs. May need to hedge and add "where not in conflict with infrastructure needs".



145 _6 States that desirable trees “will be” retained. It is not always possible to retain trees due to engineering standards. Suggests adding "where possible" at end of sentence.



145 _6 Site Layout: This Policy should be flexible to respond to unique circumstances. What types of “desirable trees” should be retained? Consider revising this Policy to read as: “Where possible"



145 _7 This Policy should be flexible to respond to unique circumstances. How does this Policy apply to industrial developments which may required substantial setbacks? Consider revising this Policy to read as: “Where possible and appropriate"



145 _8 Policy 145.8: at the end after solar energy add "and geothermal energy." No change - building orientation does not affect geothermal


145 _8 This Policy is ambiguous and provides no clear direction. This Policy conflicts with Para. 492, Ss. 6, and Para. 501. Consider revising this Policy with specific requirements or references to other sections of the LP which provide direction.



145 _9 This Policy needs to have the flexibility to respond to functional design matters. Consider revising this Policy to read as: “Where possible and appropriate"

No change - require drive aisle be located in a manner that satisfies the intent of the Policy.


145 _9 The intent of this Policy is to mitigate the visual impact of drive-throughs and to maintain pedestrian accessibility/linkages from the public street to buildings. While we agree with the intent, the wording of this Policy should be modified to allow for some flexibility.

No change - require drive aisle be located in a manner that satisfies the intent of the Policy.


145 Whole Chapter Redevelopment in heritage conservation districts - opportunities? Do road classifications still apply?

No change - road classifications apply to all streets including HCD's.


145 Consider rewording the first two sentences as follows:“Site layout is determined by place type, building design and function, site landscape characteristics and urban design considerations. All existing and planned contextual factors will be considered in the review of a site plan/design and associated planning and development applications.”

Modified - new wording added


145 revised bullet 2. as follows:2. “Site layout and associated building design is to impact existing site topography, soil, drainage and vegetation to the least extent possible assuming an undisturbed site.”



145 revised bullet 6. as follows:6. “A site plan is to retain and incorporate existing trees when merited by their species, size, health, aesthetic quality, ecological value and/or contribution to sense of place.”



145 revised bullet 1. as follows:1. Site design is to be compatible with site context – a good fit - and in keeping with associated place type policies.

No change - policy is consistent with intent of the Plan


145 Policy 145: add a new last bullet (subsection 11) stating "Boulevards and backyards as habitat and places to grow food."

No change - addressed under 144_9 - Safe, Accessible, and Healthy.


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145 Under site layout: This section should include incorporating waste storage and access for removal.

No change - addressed under Policy 145_10.


146 to 149 MLHU strongly endorses the city design / development policies within these policies, especially those that support safe and efficient, connected, multi-modal transportation options including pedestrian, cyclist, public transit and vehicular



146 _ 10 Refers to “tall” buildings. What is considered as ‘tall’? Need to clarify definiton of "tall". No change - policy unchanged, term "tall" added to Glossary.


146 _1 revised bullet 1 as follows:1. “Secure, covered bicycle parking will be incorporated into …”

No change - active transportation addressed elsewhere in the Plan


146 _10 consider striking this clause Modified - revised to allow flexibility


146 _11 Requires “slender” towers for “tall” buildings. Tall is not defined. Policy is too restrictive. revised wording to provide greater clarity and flexibility.



146 _12 Policy 146, 12 Built Form: Commendable Policy. No change - indicates support for the Plan.


146 _2 revised bullet 2. to address spaces that are not easy to navigate and/or are not comfortable to use?For example:“Buildings will be sited to best define streets and spaces in keeping with place type policies.”

No change - easy to navigate and comfortable to use are goals for built form.


146 _3 revised bullet 3. as follows: “Street-oriented buildings should be designed to address the functional and aesthetic relationship of the building to pedestrians and the street in general regardless of place type.”

No change- Policy as written achieves the functional relationship of the building to pedestrians. Policy 146_1 addresses the aesthetic relationship.


146 _4 revised bullet 4. as follows:4. “The height of buildings is dependent on place type policies.”

Modified - wording revised to include "within the context of the Place Type"


146 _4 Policy 146.4: Believes that the building height proportionate to street ROW means buildings no higher than 10 storeys, ideally 6. Higher is not human scaled.

No change - height restrictions included in place type chapters


146 _6 Bullets 6. thru 11. inclusive are prescriptive, overly simplistic and do not by themselves guarantee appropriate design results. Buildings have been built in the City of London since the addition of the Urban Design Policies within the current Official Plan that are contrary to the prescriptive directions contained in bullets 6. thru 11. and yet they are considered to be fine examples of urban design.Consider re-wording bullet 6. as follows:6. “Buildings will be designed in keeping with site context, proposed function, Plan policies and place type urban design guidelines.”Deleting bullets 7 thru 11 and renumber bullets 12 and 13 accordingly.

Modified - some policies reworded. Section is important to set context for chapter


146 _6 Design guidelines should be specifically referenced within each Place type Policy under Built Form. Delete Clause 6 and deal with these issues as part of the urban design guidelines for each Place Type and Neighbourhood.

No change - policies do not prevent guidelines in any place types


146 _6 Requirement for base, middle and top should only be required for a minimum number of storeys. Not really applicable to every type of building (e.g. – one storey buildings). revised wording to define intent and applicability.



146 _7 delete clause - similar to issues with 146_6. Modified - revised to allow flexibility


146 _8 consider striking this clause Modified - revised to allow flexibility


146 _9 consider striking this clause No change - based on good urban design practice.


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146 _9 As noted above, much of the development is oriented to internal private driveways or parking areas. In the case of our Client’s properties fronting onto Fanshawe Park Road West and Hyde Park Road it will be difficult to have primary entrances facing the street as there is currently no on-street parking. A strict interpretation of the implementation policies would require that any Site Plan application for the addition of internal buildings would have to orient entrances to a public right-of-way. We do not think that this is the intent of the Policy and therefore require clarification.



146 Policy 146: add new last bullet (subsection 14) suggests wording "City will provide direction and resources for retrofitting old energy inefficient buildings."

No change - addressed under Urban Regeneration policies 157_7 and 171.


146 Policies in Plan that are to be followed principle (e.g. base, middle, top – may be taken too literally) suggested wording to balance the guiding principle vs literal approach



146 Prescriptive nature of the policies – will/shall – takes away creativity & flexibility or may require an amendment to the OP



146 Generality of policies may also have implications – keep City Building Policy on City Design No change - indicates support for the Plan.


147 _7 What constitutes “sympathetic” materials and design is subjective and could be problematic. It is not clear if this applies to designated heritage buildings, heritage buildings within a conservation district, or listed buildings. Consider revising this Policy to provide flexibility in permitting “complementary” design and materials, Provide clarification on which heritage buildings this Policy applies to.



147 Policy 147: Materials. Suggests new subsections related to (1) that materials should be locally sourced where possible and have lowest embodied energy; and (2) buildings should be designed to minimize bird deaths.

No change - 1. Too detailed of a Policy for an Official Plan to require locally sourced building materials. 2. Minimize bird strikes addressed under Policy 147_6 and design manuals can deal with mitigation measures.


147 Materials: Avoid using the word “and” when “or” works. (The Building Code is a useful reference to making clear the difference!)

No change - use of "and" is appropriate


148 _3 Policy 148.3: Term "sharing" is supported and such cooperative language should be emphasized throughout London Plan.



148 _3 Support the Policy re: sharing and consolidating parking, however, should also have a Policy somewhere that allows for reduction of total parking requirements when sharing / consolidation is undertaken. Should include Policy somewhere in OP to permit reduction in parking to allow for changes to zoning by-law parking requirements.



148 _4 revised bullet 4 as follows:4. “Parking should be located underground or above ground, Chicago style for large buildings, such as apartments, office buildings and mixed use buildings.”

No change - "Chicago style" may not be relevant in all cases.


148 _7 revised bullet 7 as follows:7. “Surface parking will be located in the rear yard or interior side yard (not exceeding 1/3 of the lot frontage.”

Modified - revised to improve clarity, specifying 1/3 too detailed for Official plan policy


148 _7 Again use of the word “will” is too restrictive to apply to all situations in the City. In certain instances it would be appropriate to have some parking between the building and the road right-of-way. As the draft London OP policies are



148 _8 Policy 148, 8 Parking: Commendable Policy. Modified - revised to allow flexibility


148 _8 SE corner of Adelaide St N and Huron St - Clarify how the 50% tree coverage requirement is applied - will it be site-by-site or across the place type? Add that it applies to full redevelopment and not minor additions.

Modified - revised language to "should" be designed to include a sustainable tree canopy.


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148 _8 Ensure that there is sufficient flexibility in this Policy, as the tree canopy may be limited due to design constraints. 50% may not be achievable in most parking lots. Consider revising this Policy to read as, “Surface parking lots wiil be encouraged to be designed (. .)"



148 _8 50% canopy coverage in a parking lot seems very high. What is this figure based on? Has any consideration been given to liability over time from potential damage to vehicles due to broken limbs, etc.? Need to consider tree species in parking lots carefully as some species drop sap which can damage vehicles. Suggests reconsidering 50% target.



148 _8 It is unclear how this Policy/ standard is to be implemented (i.e. on a site by site basis, across a place type, or other).

No change - to be implemented through site plan process


148 _8 States “Surface parking lots will be designed to include a sustainable tree canopy with a target of 50% canopy coverage within 20 years.” This target seems quite high if it is to be implemented in parking lots, which are currently required to include some perimeter and island plantings but wouldn’t come close to 50%. The 50% target is also higher than the City-wide tree canopy targets identified in policies 479 & 480, which are 25% by 2035 and 32% by 2100. The concern is that 50% may be unrealistic for parking lots and may substantially reduce the development potential of commercial sites.



148 _8 Policy 148.8: Canopy cover should be 100% not 50% in 20 years, and should add following wording at end of Policy: "and have permeable surfaces to allow for infiltration".

No change - requested target is not feasible. Permeable surfaces addressed in section 143_10


148 _9 Ensure that there is sufficient flexibility in the design of screening. Consider revising this Policy to read as, “(...) low walls and / or landscape treatments”



148 Given the age and size of the existing College campus, Fanshawe believes that many urban friendly parking features will present challenges on the existing Campus, incluidng as examples limiting parking to rear and interior side yards and screening parking areas therby eliminating natural surveillance opportunities that promote community safety.

No change - comment noted


148 Parking: Some of what are intended to be friendly urban features would pose problems for Western to incorporate into our existing campus. Western is also a partner in Crime Prevention Through Urban Design, which has resulted in the University putting a priority on the safety of our campus community and visitors. Design elements in this section, including clause nine, would pose significant safety concerns for our populations, and especially our students, many of whom are 17 years of age.

No change - concern is addressed under Policy 148_9, which is consistent with CPTED principles and shouldn't pose a threat to safety.


148 Policy 148: suggest new Policy stating "Surface parking lots will be designed to have all stormwater recycled on-site."



148 Policies on parking do not address the management of run-off, especially oil and salts. Suggest adding.



149 _1 This Policy requires future infrastructure to be cost-effective, but also enhanced for non-functional purposes specific to the piece of infrastructure. There is the potential for conflict between these two Policy directions. SUGGESTION: Further consideration of this Policy is suggested to rationalize the dichotomy between “cost-effective” and “enhanced aesthetics and functionality.”

No change - streetscape design has functional value to support active transportation


149 _5 Ensure that this Policy provides enough flexibility to respond to unique circumstances. Consider revising this Policy to read as: “Where possible and appropriate switch boxes, transformers (...)“

No change - addressed in Policy 551.


149 Consider creation of a citywide sign guidelines document. Modified - revised to address comment


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149 The article on ‘Signage’ should be numbered. Modified - revised to improve clarity


149 Suggest that this article should be revisedd to incorporate reference to Wayfinding and Information Signs?

No change - policy relates to sign design


149 Add Policy to address lighting and lighting pollution No change - addressed elsewhere in the Plan


149 Under Signage: This entire section would not apply to regulatory road signs such as stop signs. The wording should be adjusted for the exclusion.

Modified - to reference that this Policy is not intended to apply to regulatory road signage.


150 _2 Wording of Policy is awkward. Possible revisedd wording: “Key design objectives - for developing a site will be established based on the evaluation of context established in part 1, the policies of this plan, applicable guideline documents and sound urban design principles.”



150 and 151 The layout of the document graphically suggests that policies 150_ and 151_ form part of the chapter on Urban Regeneration as they are cut into a photograph which spans pages 62 and 63.



150 Sentence 2. refers to “sound urban design principles”. Suggest that these principles be defined or outlined within The London Plan, or the wording revisedd to refer to urban design guidelines to be developed for each Place Type.

Modified - removed "sound urban design principles" from policy


150 The markedly different purpose of a Planning Application (OPA /ZBA) as opposed to a Development Application (SPA) suggests that it would be appropriate to establish separate guidelines for each type of application commensurate with purpose of the particular application.

No change - requires revision to the Urban Design brief terms of reference.


150 Urban Design Brief: The Urban Design Review Process will be significantly improved when, Design Guidelines are implemented, (both broadly, and more specifically), since there would be more generally understood intent (less personal interpretation) of design expectations. The Urban Design Review process may have more weight if the recommendations of the Panel are presented directly to EPC. (as in Heritage)

No change - issue is better resolved through a separate review process.


150 Similar approach to policies duplicated throughout the Plan: There are many sections in the London Plan that outline specific policies / requirements for planning and development applications (i.e. – pages 62, 205, 213, 226, 232, 240, 256, 284, 296, 308, 312, 336, 340, 362). However, the majority of these are identical with the only difference being the place type they refer to. Exceptions to the repeated policies are those dealing with Environmental Review, New Future Growth and Rural Neighbourhood place types. Consider putting the Urban Design Brief section in the Our Tools section with the section relating to Planning and Development Applications so that users do not need to go through the entire OP looking for requirements for applications. Also consider removing all the repeated Planning and Development Applications sections from throughout the various place type sections of the plan as page 362, paragraph 1324 identifies all of the same criteria with added detail in some cases. This will reduce the overall document by several pages.

Modified - plan updated to remove application review criteria from place types. Urban design brief section to remain in City Design chapter

City Building Policies - City Design & Our Tools

151 & 1407 The opening sentence says “ Council will appoint an UDPRP” . On Page 378 Policy 1407 regarding development permitting as an example the sentence reads as follows: “…Council may establish…” The latter terminology provides flexibility to continue or discontinue the UDRP without the need for an OPA – this should be changed

No change - UDPRP was established by Cuncil for this purpose.


151 The commentary on the Urban Design Peer Review Panel indicates that it is made up of “urban design experts”. The Panel has been well served since its inception by urban design professionals including but limited to registered Architects, Urban Designers and Landscape Architects.



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151 Consider adding an additional requirement regarding the need for all Secondary Plans to meet the Urban Design Guidelines

No change - secondary plans may allow for specific design requirements


151 UDPRP, Policy 151: suggests turning the UDPRP into an advisory committee with public members and include the lens of sustainability.

No change - operational issue outside of Official Plan policy


151 Urban Design Review Panel: Provide cross-references to the criteria for review by the Urban Design Peer Review Panel in the Place Types sections.Add reference to Design Guidelines to this list.


City Building Policies - Urban Regeneration

152 Whole Chapter Supports Affordable housing through the regeneration of urban neighbourhoods No change - indicates support for the plan


152 Whole Chapter Clarify where opportunities exist for intensification and show on mapping. No change - the intensification target is within the built-area boundary of the City as shown on map layer 10. Staff to review specific opportunities for intensification


152 Whole Chapter Suggested new Policy (172) at end of Urban Regeneration section: Alternative ways of financing regeneration projects will be explored including programs that allow property owners to borrow at very low rates and pay back over long time periods (e.g. LIC to run programs such as PACE)

No change - achieved in policy 171.


152 Reference to Design Guidelines in this sentence would help clarify the critical anticipatory understanding a neighbourhood might have of proposed changes to its district, and therefore help smooth and accelerate the process.

No change - Policies 158 and 159 under the urban regeneration policies states that the city will engage stakeholders, including landowners, residents and busines owner groups to establish how positive growth and change will be accommodated.


155 Policy 155: add "environmentally" so reads "repurposing buildings so that they can become economically and environmentally viable again."

No change - Policy 157_7 addresses the promotion of long-term sustainability.


155 Policy 155: should include a paragraph on sustainability and resilience and how urban regeneration's goal is to increase these things.

No change - Policy 157_7 addresses the promotion of long-term sustainability.


157 _3 Policy 157.3: add at the end "focusing on low cost, well designed and renewable technologies." No change - Policy 157_7 addresses the promotion of long-term sustainability and viability of their economic connections.


157 A consistent approach is required to this section/question throughout The London Plan. For example in Policy 142, the question is answered with a list of descriptive statements, while in Policy 157 the response forms a list of imperatives or goals.

No change - Policy 142 has been revised to follow a similar style as Policy 157.


157 Policy 157: add new last subsection stating: "Implement community energy planning in all old and new neighbourhoods."

No change - The Green and Healthy City Policies include a requirement for a Community Energy Action Plan.


158 How Are We Going to Achieve This? - The titling would benefit from additional description.For example:“How do we achieve our Urban Regeneration Goals?”

No change - this is the structure established for The London Plan.


159 Asks if this Policy is following on the intent of Policy 52 (Direction on Making Wise Planning Decisions)? Policy 159 states that the City "will" work collaboratively with groups, so asks if this is aspirational, or if "will" work with groups, when will it be started? Also asks why this isn't included in the Our Tools section?

No change - Yes, this Policy is consistent with Direction 8 - Make Wise Planning Decisions. The reference to "will" is aspirational. Including a policy on enagement in integral to urban regeneration. It is best to keep this policy as part of urban regeneration to address a related concern expressed by Sandy Levin under Policy 134 "If neighbourhoods are going to be changed to be made "complete", there better be a plan with lots of "engagement" before the changes begin being made".


160 How will proposed projects fit with existing character? Nothing in the other policies provides detail to measure "character".

No change - Policy 1324_5 under Our Tools - Evaluation Criteria for Planning and Development applications provides the criteria for the degree to which the proposal fits within its context, including character.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Urban Regeneration

162 Policy 162: add at end that Council will work with other levels of government and partners to work out funding mechanisms for retrofits and other urban regeneration programs focused on env'tal sustainability.

No change - Policy 158 already addresses the requirement of the city to work with stakeholders and partners to achieve the goals of urban regeneration.


163 This Policy addresses the provision of infrastructure support for community regeneration (eg. SOHO lands). A major environmental and infrastructure issue around the regeneration of older neighbourhoods is the prevalence of combined sewers (storm into sanitary sewers). The city has had a program for a number of years which provides financial assistance to homeowners to disconnect their storm drains from the sanitary sewers and is proceeding with a Pollution Prevention Control Plant. MOECC believes Policy 163 should specifically mention the Pollution Prevention Control Plant and affirm its commitment to complete and implement it. This is particularly relevant given the city's emerging Climate Change Adaptation Strategy. RECOMMENDATION: Please see comments/concerns. In addition, there needs to be a link to asset management plans and land use planning decisions.

No change - the City recently undertook long-term 20-year plans for stormater, sanitary services and water services. In addition, the long-term Transportation Master Plan was recently prepared. In addition, the Development Charges Study evaluated the long-term servicing/infrastructure needs of the City and related costs. Finally, the City recently completed a detailed long-term corporate asset management plan that is leading-edge in the province to manage the lifecycle component of insfrastructure over the long term. The City is currently undertaking a large project to de-couple sanitary and storm sewers in a large portion of the downtown.


165 "urban neighbourhood" is used in this Policy. Is this to distinguish it from "Rural Neighbourhood" Place Type? And, if you can make this distinction, the Plan should be able to also split Open Space to distinguish NHS from "public spaces". Also asks how public space can be supportive of AT?

Modified - see changes made to the Environmental Policies; addresses this comment.


165 When / how / why will “new public spaces” be created and by who? Suggests further clarification needed in this Policy.

No change - new public spaces will be created in neighbourhoods as part of development or re-development (refer to Policy 144_5 - Safe, Accessible and Healthy)


169 How / why would existing public housing be redeveloped and to what? This could lead to a reduction in the amount of public housing available. Consider rewording or deleting.

No change - this policy provides the opportunity for existing public housing projects to redevelop into new forms of affordable/public housing

City Building Policies - Mobility

172 & 177_3 Policy 172 shows an order of transportation modes – walking, cycling, transit, mobility devices, and motorized vehicles. Policy 177_3 changes the order to public transit, walking, and cycling. Recommendation: Keep the order of the transportation modes consistent throughout the Plan showing importance of each transportation mode, being walking, cycling and transit

No change - list does not imply importance


172 to 243 City staff advised that the Mobility section will be re-worked. No change - commentary on status


172 Whole Chapter Transportation Planning in Rural Areas - get from N/W part of the City to the SW part. Need more commercial traffic w/o stopping. Not necessarily a ring road

No change - road system to address this issue


172 Whole Chapter CN's habitual Policy and regulatory recommendations to be included in the final document, including separation of sensitive land uses, setback requirements, fencing and other mitigation provisions.

No change - issue addressed in policies 1459-1465


172 Whole Chapter MLHU supports all the policies in this section. No change - indicates support for the plan


172 Whole Chapter The Plan does not address traffic flow issues in the area surrounding Western that impact the University. In an effort to avoid traffic issues on Western Road and Richmond Street, thousands of drivers use University roads to cut through campus on their way elsewhere adding to traffic congestion on a daily basis. This additional, non-university traffic impacts our operations and raises concerns about bicycle and pedestrian safety.

No change - operational transportation issue; rapid transit will reduce congestion


172 Whole Chapter Extend transit service to industrial areas. No change - review of network is underway


172 Whole Chapter Include Policy that supports more roundabouts. No change - not an Official plan policy, needs to be considered in context


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Mobility

172 Whole Chapter Consider alternative means of transportation other than rail with tracks, such as alternative vehicles run by hydrogen, etc.

No change - not applicable to intent of plan


172 Whole Chapter The only example of transit I see is Downtown and Masonville. North to South London is quite short. East to West London is quite long. Sensible rapid transit would bring the east and west closer to the core by serving the routes to Byron and Lambeth for example with non-stop service from these regions to the centre, particularely at rush hour. Maybe I have not read the whole thing, but I'm afraid you are going to offer rapid transit to poeple already close to the centre.

No change - rapid transit is within th ePrimary Transit Area to support infill and intensification and where it is viable based on compact ridership; Environmental Assessment for rapid transit to confirm the routes and stations is currently underway


172 Whole Chapter It appears the plan does not accommodate the industrial workforce getting transit at all. How will London attract or keep industrial jobs if the workforce is disconnected from worksites? I’m also curious to know why our industrial areas are moving so far from local rail and the airport, isn’t having convenient shipping options a factor in placing industry?

No change - operational issue, but goal of the plan is to support transit service to employment areas where viable


172 Whole Chapter I would recommend adding a ring line around the Primary Transit Area to by-pass the downtown, extending the rapid transit lines east and south to connect into the industrial areas, and having an express line between western and Fanshawe. I would also recommend the Planning Staff, and candidates, to see London differently by taking the current bus system, especially to the city’s most marginalized areas. Try getting from the Argyle area where many low income people live to where London has been putting the new jobs, and do it in a reasonable time to arrive when a shift starts.

No change - rapit transit EA to review possible routes


172 Whole Chapter Arterial roads should be given better boulevard treatments. Eg - Sunningdale east of Adelaide has varying fences and berms with no properties addressing the street.

No change - issue addressed in plan


172 Whole Chapter Rear lane access should be permitted to prevent snout-houses and improve local streets No change - rear lanes are not prohibitted in plan


172 Whole Chapter Consider walking streets/corridors in the Downtown. No change - issue addressed in Downtown Master Plan.


172 Whole Chapter Railway corridors impede Rapid Transit, there is potential for explosion with container cars going through the Downtown. Consider re-routing CP/CN lines?

No change - rapid transit EA will review design issues


172 Whole Chapter An additional river crossing will be needed very soon b/w the Wonderland and Byron Bridges. I propose a "skybridge" joining Hyde Park Road with Commissioners Road across Springbank Park.

No change - current transportation master plan does not require additional crossing


172 Whole Chapter CITY BUILDING POLICIES –MOBILITY -- Pages 67 thru 84 - need some examples, cases and demonstrations to better understand these policies and tables. The word AVOID is confusing.

Modified - revised tables to improve clarity


172 Whole Chapter Do the Near Campus Neighbourhoods (NCN) support the density needed for rapid transit? This may need reconciliation.

No change - intensification in downtown and along corridors supports rapid transit


172 Whole Chapter Clarify what the Rapid Transit System (RTS) and routing is based on. Is RTS a much longer than 20 year plan. What is expected to be completed by 2035? Could there be a “Plan B” which would apply if the RT is not feasible? Since London is not and will likely not grow and re-develop as in the GGH (Toronto) we feel the Plan B approach should be considered.

No change - rapid transit EA will identify phasing. Transportation master plan indicates enough demand for rapid transit


172 Whole Chapter Has the City compared itself to other Cities such as Calgary and its rapid transit system for the BRT/RTS. And the proposed ones in Mississauga and Cambridge/Kitchener and Waterloo??

No change - Rapid transit EA includes such a review


172 Whole Chapter Ensure cycling routes are established that are easy, safe, and have direct connections (eg. Support commuting).

No change - already included in plan


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172 Whole Chapter Promote cycling as an attractive choice - to be successful, incorporate parking strategies in the Downtown such as reduce the inventory of car parking lots/on-street parking and increase the cost of parking.

No change - already included in plan


172 Whole Chapter There has been no cost analysis on how much the London Plan will cost the tax payer. Is there no concern that we might be adopting a vision that is unachievable?As the BRT is an integral part of the success of the entire London Plan, how can the LP be finalized without knowing the viability of the route or its cost implications? What will happen if major changes are needed to accommodate a new or different route? Approving the LP without knowing that it can in fact be achieved, does a disservice to all stakeholders, from the home owners living along the route to the investors the City is hoping will bring the vision to life.

No change - analysis included in Transportation Master Plan and Rapid Transit EA


172 Whole Chapter Transportation Cycling - need to place more emphasis on commuter rather than on just recreational cycling

No change - issue to be addressed Bicycle master plan


172 Whole Chapter The rail corridor should be dropped below ground east to west and replaced with LRT and a linear city of high rises of various heights thereby stopping urban sprawl (the line at Oxford and Richmond ) and opening east london to gentrification (Highbury to Richmond 15 minutes? Highbury to Hyde Park 30 minutes ? no more worries of hazardous derailment and rapid transit.

No change - railways are a federal jurisdication and not under authority of the City.


172 Whole Chapter I love the transit plan but I think it would be a great idea if the airport was included. There is nothing connecting the airport to public transportation you have to take a cab or pay for parking. We are a big enough city and have enough flights out of London to have better transportation to and from the airport

No change - transit extension anticipated to airport


172 Whole Chapter Keep the order of the transportation modes consistent throughout the Plan showing importance of each transportation mode, being walking, cycling and transit.

No change - order does not imply priority


172 Whole Chapter Table 6 - Rapid transit Boulevard and Main Street should be amended for Bicycle Facilities from "encourage" to "yes" symbols to indicate their importance and integration with transit

No change - Must be context sensitive


172 Whole Chapter Street classification includes six Major Streets, two Minor Streets and one Rural Street. This is a significant increase over the exisiting Plan and is difficult to know the difference in type. Could the number of street classifications be reduced?

No change - streets are complicated, with a variety of characteristics. Various classifications achieve different objectives


172 Whole Chapter Add winter maintenance program policy Modified - policy added


176 Policy 176: change ending of "changes in energy costs that may come in the future" to "that are already here"

No change - policy is consistent with intent


177 _9 the priority for pedestrian and cycling environment should not be limited to Primary Transit Area but include all Place Types where cycling is part of the circulation system.

No change - policy establishes priority area, not exclusive


177 _9 Policy 177_9 the prioirty for pedestrian and cycling environment should not be limited to Primary Transit Area but include all Place Types where cycling is part of the circulation system

No change - policy establishes priority area, not exclusive


177 Place a high priority on the pedestrian and cycling environment … (replace Primary Transit Area with) … throughout the city where cycling is one of the mobility options.

No change - Plan applies pedestrian and cycling enhancements across the city, priority is PTA


177 Consider re-wording of this section as follows:177_ “All mobility related plans and actions are to contribute positively to the achievement of:1. Mutually supportive land use and transportation infrastructure.”, et cetera.

Modified - wording updated


177 For "What are we trying to Achieve?": suggests 3 resources related to Swedish Road Planning Strategy, unsigned streets, and public art instead of stop signs.

No change - refer to Complete Streets Manual project


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177 Policy 177: This section deals with what we ant to achieve for mobility. London Plan largely overlooks need for enhanced mobility for products of industry and agriculture, i.e. integrated manner of freight in contrast to movement of people. Suggest new Policy 177.15: "work with railway companies to achieve convenient and integrated linkages with City's mobility infrastructure to enhance multi-modal transportation opportunities and encourage maintenance of existing railway corridors (and possible new ones) commensurate with policies of this Plan"

Modified - revised to support links with railway infrastructure for the convenient, safe, and integrated movement of goods


178 Policy 178: City should have 2 long-term goals for contributions of existing railway infrastructure: 1. connect London to High Speed Rail; and 2. enhance freight capacity to support industry. Policy 178 needs broadening to consider freight/industry/commerce role of railway and connections to Atlantic, Gulf, Pacific and Arctic ports.

Modified - paragraph added to 183, mobility investments will support safe and efficient movement of goods to national and international ports


180 to 199 Add safe and efficient movement of emergency vehicles somewhere in this section Modified - revised to address comment


180 Policy 180: suggests changing Policy to add reference to railway as multi-modal hub, as follows: "…foster the London International Airport's role and the railways' roles as multi-modal hubs for the movement of goods and people."



181 Policy 181: Policy should clarify that it's focus is passenger travel. Add reference to passengers as follows: … "inter-municipal passenger connections by…". Also suggest adding new sentence at end "City will work with other governments to ensure funding for and service by convenient regular rail service. Railway companies will be encouraged to maintain and enhance freight hub operations within or adjacent to industrial place types or in association with industrial activities."

No change - issue addressed in direction #2


183 184, 187, and 188

The Policy is rightfully concerned about the impact of the city-wide street network on neighbourhoods. However, there are areas of the city where streets pass solely through Place Types other than Neighbourhoods e.g. Downtown. City-wide Network policies should address this situation.

No change - use of term neighbourhoods does not refer to the place type


183 Expand on the applicability of the connectivity ratio to city planning and design. No change - issue addressed in subdivision process policies


183 Policy regarding connectivity ratio is very confusing. Consider providing a specific example of a connectivity ratio calculation somewhere in the plan or definitions.



186 Desfine a LOS “E” condition either here or in the glossary and explain the referenced target’s application.

No change - defined in the transportation master plan


186 City-wide Network-186: A LOS “E” is not a target; it is the least the City would accept. LOS “E” means that the demand equals the available road capacity, applied on a corridor basis, as the justification threshold for roadway capacity improvements. This item should be reworded to “The City of London shall establish the upper limit of LOS “E” during the afternoon (PM) peak hour as the justification for road improvements to improve traffic capacity”.



186 Should there be an LOS for Neighbourhood Streets? No change - intent is that there is no LOS

Glossary 186 Suggest adding term "LOS 'E' " to the glossary, as term is referred to in Policy 186 but is not defined.

No change - data is available from engineering


187 City-Wide Network - if NHS is considered a public space, Policy conflicts with preservation objectives.

No change - Natural Heritage policies 293 to 297 address provisions for corridors, including Policy 297 that specifies pathways & trails will be determined through the preparation of an environmental impact study, and/or subject land status report


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187 Asks if the assumption is that ESAs are public spaces? If so, then Policy 187 conflicts with goal of protecting Natural Heritage. Asks which wins out, because Policy doesn't say.

No change - Natural Heritage policies 293 to 297 address provisions for corridors, including Policy 297 that specifies pathways & trails will be determined through the preparation of an environmental impact study, and/or subject land status report


191 What does this Policy (on access management) really mean, and what are the implications? No change - intent is that where possible, access will not be from the higher priority road


191 City-wide Network-191: Add that Council will adopt Access Management Guidelines, same as in item # 193 for TIA’s. Both of these guidelines are included under Infrastructure Guidelines in “Our Tools” Section.

Modified - added that Council will adopt Access Management Guideline's


192 change the order to walking, cycling and transit. No change - order does not indicate priority


192 MTO would like to see this section reworded to recognise MTO as the owner of interchanges.The Mobility section of the London Plan is not to classify Provincial Highways and provide for right-of-way width and associated planning and design characteristics as provided for in Table 6. Provincial Highways will require their own category in the Mobility section of The London Plan. In addition, Map 5 – Street Classifications will require a separate classification category (and colour) for Provincial Highways. Provincial Highways are not to be classified as ‘Freeways’ (Highway 401 and Highway 402) or ‘Rural Thoroughfare’ (Highway 4 – south of Highway 401) on Map 5. They shall be classified as ‘Provincial Highway’ and a separate colour assigned. A new section 194 – Provincial Highways shall be required with the following text.Provincial Highways 194. The following is a description for Provincial Highway corridors within the city.1. Provincial Highway corridors are under the control and jurisdiction of the Ministry of Transportation (MTO)2. Provincial Highways include Highway 4 (south of Highway 401), Highway 401 and Highway 402.3. Development adjacent to Provincial Highways 4, 401 and 402 shall be subject to MTO permits and permit requirements pursuant to the Public Transportation and Highway Improvement Act. MTO permit requirements, include, but are not limited to, access management, traffic impact studies, stormwater management reports, site/servicing plans (setback requirements from the Provincial Highway property limits) and any other technical studies MTO may require.Goals and Function:• Move people and goods safely, efficiently and sustainably to support a globally competitive economy and a high quality of life.• Move large volumes of vehicular traffic

Modified - Mobility Chapter to add Provincial highway designation and criteria


192 Policy 192, Recommendation - change the order to walking, cycling and transit No change - order does not indicate priority


193 Policy 193: reiterating concern with guideline documents. No change - consistent with current practice. Guidelines inform regarding how to complete a TIS


194 The CAM program does not have the hierarchy set up this way so we will need to adjust our system to the new definitions. No changes needed. Just a comment.

No change - commentary on proposed policy


195 & Map 5 Map 5 should differentiate between existing and planned roads. No change - EA's and other studies will determine future alignment


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196 It appears as though the Map to be referenced has been incorrectly identified as Map 7. MTO believes it should be referencing Map 5.

Modified - Provincial highway designation and criteria added


196 Typo - Map 7 is the Natural Hentage and Hazards, Reference should be to Map 5. Modified - revised to address comment


196 Refers to Map 7, which is the Natural Resources and Natural Hazards map. Should refer to Map 5.



196 Streets-196: “ Additions to Map 7 will be consistent with the City Structure Plan” - Typo, it should be Map 5 not 7.



197 , 202, Table 6 SE corner of Adelaide St N and Huron St - The minimum access distance of 300m from an intersection on a Civic Blvd may impact the existing accesses to the site. How will tthis Policy be applied to the site now or if future redevelopment is proposed?

No change - policies will be applied in varying degrees based on scale of development, while maintaining the vision throughout the redevelopment process


197 Policy 197 explains the purpose of Tables 6 – 8 Street Classification in relation to pedestrian and vehicles. It does not speak to cycling. Are bicycles included in the term “vehicle”? Should the term be expressly defined in the Glossary of the Plan?

No change - bicycles in the vehicle zone section


197 Policy 197 explains the purpose of Tables 6-8 Street Classification in relation to pedestrian and vehicles. It does not specak to cycling. Are bicycles included in the term "vehicle"? Should the term be expressly defined in the Glossary of the Plan?

No change - bicycles in the vehicle zone section


198 Policy 198: should ensure the Complete Streets Design Manual looks at streets as sustainability corridors (habitat, food production, alternative energy, swm bioswale, etc)

No change - the complete streets design manual will consider all components of streets given the limited space


200 Figure 1 Policy 200 and Figure 1 prioritizes pedestrians, cycling and transit. Figure 1 should be reivsed to show a cycling zone and show a cyclist in the image because this will be used as a precedent graphic for decision makers and investors

Modified - bicycles shown in the vehicle zone section


200 Policy 200 and Figure 1 prioritizes pedestrians, cycling, and transit. Recommendation: Figure 1 should be revisedd to show a Cycling Zone and show a cyclist in the image because this will be used as a precedent graphic for decision makers and investors. Street classification includes six Major Streets, two Minor Streets and one Rural Street. This is a significant increase over the existing Plan and is difficult to know the differences in type. Could the number of street classifications be reduced?

Modified - bicycles shown in the vehicle zone section


200 Figure 1 – Addition of a cycling zone to indicate the importance of and commitment to making cycling a mobility option priority.

Modified - bicycle shown in the vehicle zone section.


201 The Policy indicates that “Development adjacent to streets will conform with the goals established in Tables 6, …” . However, Table 6 Major Streets (Page 74) refers to Land Use and makes no reference to Place Types.

No change - land use permission in place types, table sets general goals


203 Proposed streets are not identified on Map 5 as dashed lines. No change - EA's and other studies will determine future alignment


205 Policy 205: Consider adding a new subsection 5, allowing amendment to street classification through a TIS, stating: "Justification of the proposal shall be provided through completion of a Transportation Impact Study"

No change - policy adequately addresses amendments


205 Policy only refers to potential to “undermine” the street network. Amendments should also be considered if they enhance the street network. Suggests changing wording to “The potential to undermine or enhance the street network....”

No change - amendments to change street classification are discouraged


206 Policy 206: Note that the mobility options should be integrated with care share and bike share programs.

No change - addressed in plan


207 P79, Policy 207 under the Mobility chapter, add the city’s transportation mode share targets, noting ‘telecommuting’ is a viable option to reduce traffic congestion. This is not referenced in The London Plan.

No change - polcies achieve intent of plan


208 & 209 P79 policies 208 and 209 add bicycle parking as an option to park and ride facilities for transit. No change - issue addressed in policy 214


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208 Where are these parking lots proposed to be located? There will be implications to private property owners.

No change - location to be determined upon detailed review


210 TDM program is either required for all applications, or it “may be” required for some, but not both. Need to gain an understanding of the implications of this Policy. We would encourage this Policy to be written in a way that provides clarity as to the criteria that will be employed to determined when a site plan application will require a Transportation Demand Management Program and when it will not.

Modified - revised to require TDM program


211 to 218 No mention of bicycle signage or education as mentioned in the existing Plan. Modified - revised to address comment


211 to 218 This Section appears to use cycling infrastructure and cycling facilities interchangeably. The policies do not clearly differentiate the intended differences. Recommendation: Define the differences in Policy or in the glossary of the Plan.



211 P80 Policy 211 shows active transportation as walking and biking, whereas, p55 Policy 144 lists active transportation as cycling, walking, blading, boarding, and transit (the only reference in the document).

No change - walking and cycling is a "key focus", not exclusive


211 Active transportation: reference to provincial cycling strategy (from meeting: add Policy between 215/216)

Modified - issue addressed in policy 213


213 Policy 213 to prepare the Bicycle Master Plan is strongly supported. Amendment - change "will be prepared" to "will be prepared and dopted" to ensure council adopts the recommendations. Change "a complete network" to "a complete and continuous network" to qualify the meaing of a complete network.

No change - current language is consistent with rest of plan


213 to prepare the Bicycle Master Plan is strongly supported. Amendment: Recommendation change “will be prepared” to “will be prepared and adopted” to ensure Council adopts the recommendations. Change “a complete network” to “a complete and continuous network” to qualify the meaning of a complete network.

No change - current language is consistent with rest of plan


213 Add the following – A Bicycle Master Plan will be prepared to establish a plan that connects … through a complete and continuous network of cycling infrastructure …

No change - included in plan


213 I thought the plan was to develop a more comprehensive Active Transportation Plan or Mobility Plan instead of just a Bicycle Master Plan – we need to include walkability within this somewhere as biking and walking share much of the same infrastructure.

No change - plan speaks to mobility system throughout


215 and 218 This section appears to use cycling infrastructure and cycling facilities interchangeably. The policies do not clearly differentiate the intended differences - define the difference in Policy or in the glossary of the Plan. Check/change to "cycling" throughout Plan.



217 & 253 217 & 253 - is the use of the term linkages referring to ecological or something else? No change - Language is appropriate in these polices


217 Policy 217 identifies key destinations for the network. Recommendation: Educations centres including Western University, Fanshawe College and high schools should be added because these are major cycling users.

No change -policy is general in nature


217 Policy 217 identifies key destinations for the network. Eduaction centres including Western University, Fanshawe College and high schools should be added because these are major cycling users.

No change -policy is general in nature


217 Add “education centres including Western University, Fanshawe College” since these are major cycling destinations within the city.

No change - policy addresses connections to other policies dealing with access to ESAs


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217 Clarifification relating to Mobility and Transportation - #217, page 80: We have just one concern about this section of the draft plan: Given that many people want the natural resources of our open spaces, environmentally significant areas and areas of scientific interest protected from large, paved multi-use paths, it doesn’t seem clear the way that this section is worded about bicycle routes leading up to the open space areas, but not going through those areas. AND We would like some clarity and reassurance that such bicycle routes will not use our natural heritage system for such paths. A good deal of discussion and study was put forward in the Trail Management Guidelines for the London area and we would like those guidelines to be respected in term of Meadowlily Woods and the other sensitive environmental areas of the city.

No change - policy addresses connections to other policies dealing with access to ESAs


217 Because Open Space includes NHS features and areas, and they will be integrated utilizing linkages including multi use pathways, the Policy should add "…linkages between but not through open space areas"

No change - plan includes specific policies for each


218 ACE strongly supports p80 Policy 218 that all street reconstruction/widening include cycling lanes.



218 Policy 218 is strongly supported by the Committee as the process to expand a continuous cycling network. Recommendation: Change the Policy from “will” to “shall” to be more directive. It should exclude freeways and expressways.

No change - policy intended as a long term objective


218 Policy 218 is strongly supported by the Committee as the process to expand a continuous cycling network. Change the Policy from 'will' to 'shall' to be more directive.

No change - policy intended as a long term objective


218 Policy 218: supports the Policy. States that bike lanes need to take precedent over left turn car lanes. All streets should get "share the road" if not feasible for bike lane.



218 Is it appropriate to require cycling or cycling-related facilities on all street types? What are the implications of this Policy? What constitutes “cycling and facilities, where warranted and appropriate,” cycling_related_facilities”? Consider revising this Policy to read as: “All street reconstruction and/or street widenings will incorporate cycling or cycling related facilities, where warranted and appropriate.”

No change - issue is included as part of the city's Complete Streets program and is consistent with the trasportation master plan


218 States that all street reconstruction and widening will incorporate cycling or cycling related facilities. However, Table 6 expressly states that there are not to be any bicycle facilities. Clarify Policy to exclude freeways and expressways or modify Table 6.

Modified - table revised for consistency


221 Policy 221: change "associated car share" to "associated car and bike share service" Modified - revised to address comment


223 Do we need a study if it’s a minor variance? Suggestions that parking plan “may be required” Modified - revised to address comment


224 _5 2. On page 82, section 224_5 mentions “alternative modes of transportation”. Change this reference to “sustainable modes of transportation”.

Modified - changed to active forms of transportation and transit


224 Policy 224: add new subsection 6, stating : "support sustainability by permeable surfaces and tree cover over all parking lots"

No change - issue addressed in City Design chapter


225 The purpose of this paragraph is not clear, Is it supposed to be a new heading? Modified - policies was intended as a heading, not a policy


225 Parking-225: What does this condition mean? It should read “Future streets…..” Modified - policies was intended as a heading, not a policy


228 The proposed streets on Map 5 may not all be approved, and only shows existing routes. The ranges of right-of-way widths for each of the various street classifications, are significantly larger than those within the existing Official Plan. What justification is provided for the identified range of widths? Provide justification for the ROW widths. Consider revising this Policy to clarify that the streets on Map 5 may not all be approved.

No change - policies 231 and 232 address alignment and width of future roads


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230 It is not clear if the inclusion of the transit right-of-way has been properly justified. The ranges of right-of-way widths, for each of the various street classifications, are significantly larger than those within the existing Official Plan. What justification is provided for the identified range of widths?

No change - widths removed


231 Parking-231: This statement is not consistent with the EA process and will compromise any EA undertaken to determine a streets alignment. Functional studies cannot be used to determine the alignment of a road. Any reference to these should be removed from this condition and replaced with clear wording that an EA will be required.

Modified - revised to add EA


231 The protection of proposed streets should be extended to site plan agreements. SUGGESTION: Include “site plans” in the list of planning reviews through which street corridors will be protected and appropriate land dedications, without cost, will be requested of the applicant.

No change - see policy 234


235 Parking-235: A list should not be provided in this condition. Other unforeseen issues may arise that require additional roads that are not on the list. Lists limit the ability of the City to obtain needed ROW.

No change


239 New Policy should be added after Policy 239, which should state: increased number of roundabouts to increase safety; allow alternative traffic calming measures such as surface painting. (web link to a design resource is provided)

No change - roundabouts do not necessarily acheive this objective


239 This Policy does not appear to be consistent with Section 4.14 (‘tots Reduced by Public Acquisition”) in the Zoning By-Law. Should properties in these circumstances not be deemed to conform?

No change - Zoning to be reviewed after adoption of London Plan


240 Is there some type of Map / Schedule included within The London Plan that depicts the location of this various infrastructure that the City may deem necessary for dedication? How does an individual know, in advance of coming in with some type of planning act application that he may or may not need to dedicate some type of infrastructure? This needs to be transparent for all involved.

No change - information provided in Mobility chapter and on Map 5. Pre-consultation may generate additional information


241 Page 83 - street widenings – clause 241 -- Partly, arising from the RTS demands, is the need for wider roads and rights-of-way where the routes are chosen. Council has already passed a bylaw and is applying it- even-though it has been appealed – to require from adjacent land owners as much as 24 m from centreline. If the original road allowance is 10 m that means the dedication of road widening land is 14 m – without any land owner compensation. This may discourage development that otherwise may occur. LAPC feels this to be unfair and compensation should be afforded after a threshold widening is taken. Historically, the City did have a Policy that after a 10% (threshold) land area widening – compensation would be paid. The unfairness is increased when we understand that an Environmental Impact Study is about to be commissioned by the City for the RTS. Road widenings to the extent of the Bylaw are premature until the EA is complete.

No change - permitted under the Planning Act


242 Acquisition and Protection of Lands-242: Reference to “no expense” should be removed to be consistent with item 241.

No change - reference is to two diferent processes


242 Is this transit reference just the bus or does it mean all transportation. Modified - clarified that road widening can be required beyond public transit


243 add cycling parking to other transportation infrastructures. No change - can be considered "other related infrastructure"


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243 The language of the first half of this Policy is consistent with Section 51(25)(b. 1) of the Planning Act. However, the underlined portion is not consistentwith Section 51(25)(b.1). The requirement to dedicate land for commuter parking lots, transit stations and related infrastructure needs to be identified somewhere in The London Plan, so applicants are not surprised by these requirements. This is similar to how road right-of-way requirements are identified, so applicants are aware of what their right-of-way dedication requirements are up front. These other features cannot be requited on their own (i.e., without streets), or the word including” would not have been used in the legislation. Consider revising the last sentence of this Policy so that it is consistent with Section 51 (25)(b.1) of the Planning Act, “(...) conditions may be established to require that streets, including pedestrian pathways, bicycle pathways, and public transit rights-of-way, be dedicated as the Approval Authority considers necessary.”

Modified - wording consistent with the Planning Act unchanged, separated policy 243 to two parts, added "Approval authority considers necessary"


244 (New 1225)

to 249 (New 1230)

Definition of Natural Heritage System within the London PlanThe City defines its natural heritage system in multiple ways throughout policies 244 to 249, as well as in earlier policies (beginning at Policy 65) of the London Plan with respect to the Thames Valley Corridor and Natural Heritage and Park System. Many of these policies are inconsistent and do not contribute, nor do they appear to add value to the Official Plan policies. Instead of providing multiple interpretations of what the City’s natural heritage system includes, MNRF recommends providing one clear, concise and consistent definition of the City’s natural heritage system. They also recommend making this definition easy to find (see above comments regarding subtitles). To ensure that the information provided in the Official Plan with respect to natural heritage policies is clear and consistent, MNRF recommends that the City use the following definition of natural heritage system, which is consistent with the definition in the PPS:The City’s Natural Heritage System is made up of natural heritage features and areas, and linkages intended to provide connectivity at the regional or site level and supports natural processes. Natural heritage systems maintain biological and geological diversity, natural functions, viable populations of native species and ecosystems. In London this includes natural heritage features and areas, provincial parks, other natural heritage features, lands that have been restored or have the potential to be restored to a natural state, areas that support hydrologic functions and working landscapes that enable ecological functions to continue. The City’s Natural Heritage System is shown in Map _¬_ (see MNRF comments on mapping a natural heritage system below).

Modified - revised to address comment and in accordance with the PPS


244 (New 1225)

to 249 (New 1230)

The introduction (What is Natural Heritage PP244-249) to the natural heritage policies appears to include some repetition/duplication. Perhaps the definitions and key terms (i.e. natural heritage and natural environment) could be provided in an appendix. Also, perhaps consider renaming Map 6 – Natural Heritage System.


City Building policies - Natural Heritage

244 (New 1225)

to 249 (New 1230)

The natural heritage section preamble should be italisized to differentiate guiding text from actual Policy.

No change-all text to be read as policy. New section in Our Challenge-How to Use the Plan.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Natural Heritage

244 (New 1225)

to 252 (New 1233)

Further, if these policies are intended to provide an overview of high level goals/objectives with respect to how natural heritage is being considered by the City of London, MNRF recommends that subheadings are provided to set the context for each Policy. Examples/suggestions for each Policy, based on the information provided within each Policy include:• Policy 244 – What are Natural Heritage Features and Areas• Policy 245 – London’s Natural Heritage System• Policy 246 – Why a Natural Heritage System is important• Policy 247 – What is a Natural Heritage System• Policy 248 – Incorporating Ground Water Features, Hydrologic Functions and Surface Water Features into the Natural Heritage System• Policy 249 – Intent of Natural Heritage Policies in the London Plan



244 (New 1225)

to 252 (New 1233)

MNRF has interpreted that policies 244-252 be intended to establish an understanding of the terms ‘natural heritage’, ‘natural heritage features’ and ‘natural heritage system’ and provide reasons for why natural heritage policies are being established within the Official Plan. However, the overall intent/purpose of policies 244-252 is unclear to MNRF. There are also a number of inconsistencies with the PPS. As currently written, it seems that many of these policies should likely not be listed as policies as they do not appear to lay out a clear planning framework. For instance, none of these policies identify the consideration/need for long-term protection of natural heritage, nor do they incorporate the high level policies of the PPS. MNRF recommends that these policies are revisedd to incorporate/better reflect the policies and definitions in the PPS. This would help ensure that these policies are clear, concise and consistent with the PPS.



244 (New 1225)

to 291 (New 1268)

With Climate Change, there will be intensification in the frequency of extreme weather events, thereby increasing risk to all developments in close proximity to the flood plains and other natural heritage systems such as, trees & woodlands. Trees mitigate heat illnesses by delivering shade and cooling, reducing air pollution, and improving flows & nutrients in storm waters systems, limiting sun exposure, and protecting surface & groundwater quality. Therefore, we support an increase in natural heritage protection.

Modified-The Forst City and The Green and Healthy City policies note the value of trees and woodlands for climate change mitigation.


244 (New 1225)

to 365 (New 1344)

Adjacent Lands PolicyUnder each subsection of the natural heritage policies of this plan is a Policy related to development and site alteration not being permitted within the natural heritage feature. The same Policy should be identified for adjacent lands (and refer to Table 9 – Areas Requiring Environmental Study) of Policy 359 (see notes above). While Policy 359 requires that an environmental impact study be conducted, there is still a need to prohibit development and site alteration in adjacent lands unless ecological function of the adjacent lands has been evaluated and it has been demonstrated that there will be no negative impacts on the natural features or on their ecological functions, in accordance with Policy 2.1.8 of the PPS.

Modified - revised to address comment and in accordance with the PPS. Policy 1296 (new) defines adjacent lands and Table 15 is clarified.


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244 (New 1225)

to 365 (New 1344)

Structure of the Natural Heritage PoliciesMNRF acknowledges that the policies that start at Policy 264 after subtitle, ‘Components of the Natural Heritage System’ apply to recognized, potential, or unevaluated natural heritage features and areas. However, the structure of the policies provided for each type of natural heritage feature (referred to as components of the natural heritage system) is not consistent, i.e., for some natural heritage features it is clear how the feature will be protected and for some, there is no Policy provided. Also, for all of the natural heritage features, it is unclear who is responsible for determining significance. Therefore, to assist in improving the consistency of policies written for each natural heritage feature (component of the natural heritage system), MNRF provides the following suggested structure for outlining the policies under subtitles for each natural heritage feature.1. Definition of the natural heritage feature that is clear and consistent with the PPS.2. Description of how the natural heritage feature should be identified, delineated and evaluated for significance, i.e., outline criteria that should be followed that is consistent with the Natural Heritage Reference Manual (NHRM).3. Description of how the natural heritage features will be mapped (i.e., in Map 6) and within what Place Type it will be included.4. Identification of who is responsible for determining significance of the natural heritage feature. For provincially significant wetlands (PSW), habitat of endangered species and threatened species, and areas of natural and scientific interest, MNRF is responsible for determining significance. For all other natural heritage features, planning authorities are responsible. That should be made clear by outlining this in Policy within the London Plan.5. A description of how the natural heritage feature is protected (i.e., ensuring consistency with policies 2.1.4 - 2.1.7 in the PPS). For example, for PSWs, this would be development and site alteration is not permitted within Provincially Significant Wetlands within the City of London.6. A description of the requirements to consider adjacent lands associated within the natural heritage feature (i.e., ensuring consistency with Policy 2.1.8 in the PPS).7. Identification of the adjacent lands width applied to each natural heritage feature, including a reference to Table 9 under Policy 359 of the London Plan.

Modified - revised to address comments and in accordance with the PPS.


244 (New 1225)

to 365 (New 1344)

Consistent Use of Natural Heritage TerminologyWithin all natural heritage policies of the Official Plan, MNRF has noticed that the terms, “natural heritage”, “natural features” and “natural environment”, as well as other similar terms are being used interchangeably. To ensure that the information provided in the Official Plan with respect to natural heritage policies is clear and concise, we recommend defining and using consistent terminology throughout. MNRF recommends the term natural heritage features is used. Consistent terminology will assist with implementation, ensuring the appropriate Policy is being applied and that decisions are being made in a manner that is consistent with the PPS. MNRF would be supportive of a Policy that recognizes other terminology that are generally used, such as natural environment, natural heritage, etc. but that clarifies that for the purposes of this document, the term natural heritage features will be used to represent other commonly used terms.

Modified - revised to address comment and in accordance with the PPS. Definitions added to plan.


Page 67


244 (New 1225)

to 365 (New 1344)

Wetlands Policies 272-275 and Suggestions for Additional Wetlands PoliciesMNRF has provided specific comments and recommended Policy changes to the Wetlands policies 272-275 in the chart that is attached. In addition to those comments, MNRF has noted that it appears the City has not identified specific policies associated with the type of protection provided to Provincially Significant Wetlands and Locally Significant Wetlands. While Policy 273 makes reference to mapping Provincially Significant Wetlands and Locally Significant Wetlands on Map 6 and including them in the Open Space Place Type on Map 4, there are no policies that specify if these wetland types receive varying levels of protection. It should be noted that Policy 2.1.4 of the PPS states that development and site alteration shall not be permitted in significant wetlands. Therefore, the MNRF strongly recommends that the City include a Policy under the wetlands Policy that ensures consistency with Policy 2.1.4 of the PPS. MNRF recommends the following Policy is added:Development and site alteration shall not be permitted in Provincially Significant Wetlands as identified on Map 6 or determined through environmental studies.The City should determine, and make it clear in the policies of the London Plan, whether they wish to identify the same Policy for Locally Significant Wetlands as that level of protection goes above and beyond the PPS.Policy 275 suggests that Council may require wetland evaluations where unevaluated wetlands have been identified. This is not adequate to address the requirements of the PPS as per the definition of “Significant” with respect to wetlands. Therefore, the City has not yet adequately identified policies that clarify the process with respect to identifying wetlands and the requirement to evaluate unevaluated wetlands where development may be proposed within an identified wetland and/or within adjacent lands. MNRF strongly recommends that the City include the following Policy with the Official Plan:Where development and site alteration is proposed within a wetland and/or adjacent to a wetland that is identified as Unevaluated Wetland in Map 6 and/or if Ecological Land Classification determines that a vegetation community is a wetland that has not been evaluated, the unevaluated wetland must be evaluated using the Ontario Wetland Evaluation System and the status of the wetland determined through the wetland evaluation must be approved by the

Modified revised to address comment. Revisions to policies 273 and 275, now 1252 and 1253


244 (New 1225)

to 365 (New 1344)

Komoka Provincial ParkPolicy 1.5.1 of the PPS states that Healthy, active communities should be promoted by…d) recognizing provincial parks, conservation reserves, and other protected areas, and minimizing negative impacts on these areas. It does not appear that the City has identified a Policy in respect of Policy 1.5.1 of the PPS, in consideration of Komoka Provincial Park being located within the City of London. MNRF recommends that the City include a Policy that recognizes Komoka Provincial Park and provides for minimizing negative impacts on the Park.

Modified-Komoka Provincial Park recognized as a provincial Life Sciences ANSI.


244 (New 1225)

Whole Chapter The section in the current OP that lists ESAs is not in The London Plan. Was that by design? If so, why?

No change - Individual ESAs not required to be listed in the text to be protected by the policies of the Plan.


244 (New 1225)

Whole Chapter The other part of the discussion at EEPAC was around the 401/VMP intersection that was part of the proposed redesignation for industrial. While it seemed OK to redesignate Ag lands to Industrial, the ER lands are staying ER, despite the recent EA by MMM for the VMP extension that indicated the woodland at the SE side of the highway/VMP intersection is Significant. Again, it seems that there is no clear process in the OP by which staff are directed to take action based on an environmental study that is not directly related to a development application. Is there a way to change that by adding something to the London Plan? If so, what might you suggest?

No change - addressed through a separate Official Plan Amendment as part of the City's Urban Growth Expansion for industrial lands.


Page 68


244 (New 1225)

Whole Chapter Subject lands status report - why do we still have them. We are unclear if any guidelines for the preparation exist, even in draft



244 (New 1224)

Whole Chapter Definitions and key terms (i.e. natural heritage and natural environment) could be provided in an appendix

Modified - revised for consistency with PPS


244 (New 1224)

Whole Chapter Policy 2.1 of the 2014 PPS requires that natural heritage systems be identified and protected. As has been presented to the City planners, the UTRCA has prepared The Middlesex Natural Heritage Systems Study (MNHSS) in conjunction with a number of key partners including the City of London. This study evaluates the natural heritage system in Middlesex County and we believe that the findings will be a complimentary tool that the City can incorporate to protect London’s natural heritage system. This study is being considered by Council on October 14, 2014.



244 (New 1224)

Whole Chapter We note that many terms are used throughout the London Plan to describe the natural heritage system and suggest that a simplified, consistent terminology be used to avoid any confusion regarding the intent of the policies and what is being protected etc.



244 (New 1224)

Whole Chapter It is essential that all of the vulnerable areas – SGRAs, HVAs and WHPAs be identified and mapped in the new Official Plan and then be protected with Policy. This may include developing a process or framework for scoping future development proposals all of which shall be consistent with the PPS. A similar process is defined through s59 for significant drinking water threats which requires Risk Management Official involvement. This process could be expanded upon to include other concerns. The Policy may stipulate that the proponent may be required to prepare and pay for supporting technical studies which would have to be prepared by a qualified expert and would be peer reviewed. The constraint mapping could be the trigger for a study and perhaps the planning application would include a disclosure matrix that the proponent would have to fill out.

Modified - revised natural resources chapter to address.


244 (New 1224)

Whole Chapter The policies in the Natural Heritage section generally look comprehensive and good. No change - indicates support for the Plan.


244 (New 1224)

Whole Chapter There is no commitment to preventing human / wildlife conflicts through the established of wildlife corridors as it is currently written in the London Plan. To do so, would require language specific to common species. Capturing the habitat needs of keystones species will automatically capture the habitat needs of other species. Complete life-cycle habitat requirements of the largest keystone species also guarantees enough space to accommodate the influx of visitors for recreational purposes and sensitive species with unique habitat needs such as wetland species. Creating successful green spaces to avoid human/wildlife conflicts and for the recreation of residents requires a concerted planning effort and specific language to clearly give direction.

No change - Policies included for the identification and protection of significant wildlife habitat.


244 (New 1224)

Whole Chapter The language in the Natural Heritage section is contradictory. While it realizes a need to protect the habitat of sensitive species, it also describes the ideas of building up to the boundaries of natural heritage protect areas and discussing the potential for logging. Development next to natural areas is highly desirable and very marketable but the very idea of destroying buffer zones and building to the boundary of a protect area is contrary to the long-term viability of an area.

No change - policies require the identification and protection of natural heritage features and areas, including the provision of buffers as required.


244 (New 1224)

Whole Chapter Concern with wording in section that requires development to preserve all aspects of the natural environment, whereas that is not considered possible. The wording should be changed to reflect the goal to enhance where it is demonstrated to be beneficial, such as is done in an EA process.

No change - The London Plan Natural Heritage Policies are intended to protect and enhance the significant components of the NHS.


Page 69


244 (New 1224)

Whole Chapter wording in London Plan Section 351 has changed from "the city HAS prepared emvironmental management guidelines: to "The City MAY prepare environmental management guidelines". Why the change?

No change - consistent with the language used in the Plan. The wording recognizes that new guidelines may be prepared, or where guidelines have been prepared, they may be amended or revised from time to time.


244 (New 1224)

Whole Chapter Title of "What is Natural Heritage": need a paragraph to note that 90% lost in southern Ontario, and need to preserve/restore what is left.

Modified - important of the natural heritage system is identified in the Green and Healthy City section of the Plan.


244 (New 1224)

Whole Chapter I think London is ready to take it’s ecosystem management to the next level of ecosystem services from pollination to food production to flood mitigation. This would integrate our traditional Natural Heritage Planning with Urban Forestry, Stormwater Engineering, Parklands planning under one umbrella. Brampton is doing: http://www.brampton.ca/EN/residents/Environment/Pages/Natural-Heritage-and-Environmental-Management-Strategy.aspx. I also attached a paper that looks at ecosystem services in the context of urban planning. ACE’s Pollinator Sanctuary idea would fit perfectly into such a document. London should also be recognized as a Pollinator Sanctuary and all other policies and by-laws aligned with this goal. We are not asking for an outright ban on neoniconitoid pesticides as this would be a tough battle but please note that Hamilton is considering it:http://www.cbc.ca/news/canada/hamilton/news/consider-banning-insecticides-to-save-honeybees-merulla-1.2677556 We need to be creating pollinator habitats throughout the city and make sure that the plants we plant have not been treated with neonics.

No change - The London Plan is consistent with the PPS and NHRM approach. The City is also already working on updating the standard seeding protocols that will use pollinator friendly seed mixes in all naturalization projects where seeding is required. Policies have beeen added to address pollinator habitat.


244 (New 1224)

Whole Chapter the Natural heritage section should focus only on natural heritage and should not include other compenetns such as parks planning and urban forest.

No change -policies in Parks and Open Space and The Forest City also provide opportunities for natural heritage system protection.


244 (new 1224)

Whole Chapter The Plan places equal emphasis on all types of natural heritage features, whereas it should recognize that some features require greater protection than others. Eg-a recently abondoned farm requires less protection than a highly sensitive component of the natural heritage system. Introduce recognition that there is a heirarchy of of of natural sensistivities in pre-amble and provide flexibility in the guideline documents for development considerations.

No change - components of natural heritage system identified and protected in accordance with the Provincial Policy Statement and the intent of this Plan.


244 (New 1224)

Whole Chapter Some sections in the Natural Heritage Policy reference Subwatershed "Plans" whereas other sections of that Policy and the Storm Drainage and Stormwater Management Section references Subwatershed "Studies". We request that the terminology consistently refer to Subwatershed Studies

No change - both terms used in Plan

City Building Policies - Natural Heritage & Natural Hazards

244 (New 1224)

Whole Chapters These sections to be reviewed and commented on after revised version is available. Modified-"What is Natural Heritage?" policies revised for clarity and consistency with the PPS.

http://www.brampton.ca/EN/residents/Environment/Pages/Natural-Heritage-and-Environmental-Management-Strategy.aspx
















Page 70


244 (New 1224)

The definition of natural heritage provided in Policy 244 is not consistent with the definition in the Provincial Policy Statement, 2014. For instance, missing from the list of natural features provided in this definition are natural features as identified in the PPS such as habitat of endangered species and threatened species and areas of natural and scientific interest. RECOMMENDATION: Recommend revising the statement in Policy 244 to provide a definition of Natural heritage features and areas in London, that is consistent with the PPS definition, such as:Natural Heritage Features and Areas are defined in London as significant wetlands, fish habitat, significant woodlands, significant valleylands, habitat of endangered species and threatened species, significant wildlife habitat and significant areas of natural and scientific interest, which are important for their environmental and social values.



244 (New 1224-1230)

This statement could be enhanced by pointing out that areas that have been restored or improved (i.e. not inherited from the past) are also worth maintaining and conserving. This statement could also be enhanced by acknowledging the importance of restoring and enhancing natural heritage features and areas, which promotes stewardship, as well as conservation and management. RECOMMENDATION: Recommend adding the following statement:At the same time, creating and improving natural heritage features and areas through restoration and stewardship is also important to facilitate maintenance of ecological function and biodiversity, but also the restoration and improvement of these features in the City of London.



245 (New 1225-1230)

Stating that the City will not be considering natural heritage features and areas on their own is implying that the City does not consider natural heritage features and areas individually, but only as part of a Natural Heritage System. This is inconsistent with the PPS because different natural heritage features have different policies under the PPS. For example, Section 2.1.4 of the PPS states that development and site alteration shall not be permitted in significant wetlands and significant coastal wetlands, while Section 2.1.5 states that development and site alteration shall not be permitted in significant woodlands, significant valleylands, significant wildlife habitat, significant areas of natural and scientific interest and coastal wetlands, unless it has been demonstrated that there will be no negative impacts on the natural features or their ecological functions. RECOMMENDATION: See previous comments for MNRF’s suggested definition of London’s natural heritage system, which MNRF recommends using in place of the definition currently provided in Policy 245.MNRF suggests revising this statement to read as follows: The City will consider how natural heritage features relate to one another and the role each natural heritage feature plays within the natural heritage system.



Page 71


245 (New 1225-1230)

Though many of the natural heritage features and areas may be associated with valleylands and floodplains within the City of London, there are other natural heritage features and areas, such as woodlands and wetlands, which are located outside of valleylands and floodplains that should be considered part of the City’s natural heritage system. As currently written, the Policy appears to exclude natural heritage features that are not associated within valleylands and floodplains from the City’s natural heritage system. It is recommended that the City consider other linkages for the natural heritage system beyond valleylands and floodplains.

It is also not clear based on the list of natural heritage features identified as part of the City’s natural heritage system whether the significance of the features plays into whether or not they are included in the natural heritage system. MNRF recommends further consideration of linking natural heritage features and areas beyond those associated with floodplains and valleylands are part of this discussion regarding the Natural Heritage System.

See previous comments for MNRF’s suggested definition of London’s natural heritage system, which MNRF recommends using in place of the definition currently provided in Policy 245.

Modified - section revised to address comments proivded


245 (New 1225-1230)

Policy 245: 3rd sentence: change "we use the word system" to "we use the word eco-system…" No change- section revised and reference removed


245 (New 1225-1230)

Policy 245: add air and water to list of what makes up our NHS. No change - air is not a component of our natural heritage system as defined by the PPS. Water features and hydrological features are identified as being a component of the NHS.


245 (New 1225-1230)

Policy 245: add new last sentence: "For example, excess nutrients from farm fields and sewage facilities cause massive algal blooms in receiving lakes like Lake Erie."

No change - This sentence does not fit in the context of the natural heritage system policies.


246 (New 1225-1230)

It would be helpful if this identified the type of natural heritage feature that the Thames River Valley is considered to be, considering the definition in the PPS. For instance, is it a significant valleyland that is considered to be the most important natural feature in the City and/or is it considered a corridor that is central to the City’s natural heritage system? RECOMMENDATION: Recommend clarifying what type of natural heritage feature the Thames River Valley is as part of this statement.

Modified - revised to address comment - Thames River Valley is Significant Valleyland


246 (New 1225-1230)

Policy 246: after "Thames River Valley" add "and its tributaries…." Modified - revised to address comment.


247 (New 1225-1230)

247 - definition of NHS does not match the one in the PPS. Modified - revised for consistency with PPS


247 (New 1225-1230)

The PPS requires that natural heritage features be mapped and protected until it has been determined that they do not need to be protected through an appropriate evaluation. RECOMMENDATION: Until such a time that the significance of a feature can be determined, those features need to be protected.

No change - Comment is addressed in Policy 1244


Page 72


247 (New 1225-1230)

MNRF considers this to be a fair statement, but recommends clarifying the next step required for natural features and areas that have not yet been mapped or evaluated. RECOMMENDATION: MNRF suggests clarifying that when an application for a change in land use is received by the City, site-specific evaluations will be undertaken to identify, evaluate and map these features and that these will be included in the City’s natural heritage system as new information is received.Also, if the above is already incorporated into an OP Policy, MNRF recommends referring to that Policy (or policies) within Policy 247.

Modified - revised for clarity and consistency with PPS


247 (New 1225-1230)

This statement introduces a new term (natural landscape). It appears to refer to a natural heritage system as a “connected natural landscape”, which could be confusing for readers. RECOMMENDATION: See general comments for MNRF’s suggested definition of London’s natural heritage system, which could be used in place of this statement and would resolve MNRF’s concern with respect to introducing new terms.



247 (New 1225-1230)

The beginning of this statement refers to a natural heritage system as an “ecologically-based definition”, making this Policy unclear as written. RECOMMENDATION: Please see MNRF’s previous comments for a suggested definition of London’s natural heritage system, which MNRF recommends using in place of the definition provided in this Policy.If the City wishes to retain a statement about the ecological benefits of a natural heritage system, MNRF suggests the following revisedd statement:The natural heritage features and areas that are part of a natural heritage system include, for example, wetlands and woodlands that function to provide flood protection by absorbing flood waters and contain trees and plants that help produce clean air, productive soils and filter pollutants from water. Other ecological benefits of a natural heritage system are a reduction in fragmentation, which facilitates the movement of wildlife and plants, promotes biodiversity and better positions the City’s natural heritage features and areas to adapt to the stresses due to climate changes. Natural heritage systems also influence human activity, facilitating health and mental well-being and promote social interaction and inclusion.

Modified - revised for claity and consistency with PPS.


247 (New 1225-1230)

This is the first time the term “natural areas” is being used in the OP and no definition is provided here. RECOMMENDATION: MNRF recommends using the term “natural heritage features and areas” as per the PPS and defining it as per the PPS. MNRF suggests revising this statement as follows, for clarity:Not all natural heritage features and areas are connected within the natural heritage system. This is because there is a scattered pattern of remnant natural heritage features and areas across the landscape that have been modified over time by urbanization and agricultural activities.



247 (New 1225-1230)

P.247 – reference is made to a scattered pattern of remnant natural areas. How will these be protected?

No change - This reference is to existing components of the NHS that are located outside of connected areas. They are still components of the NHS and are protected features on the landscape.


Page 73


247 (New 1225-1230)

It is difficult to understand where these 'naturally functioning eco-systems' occur in the city. It is a romantic definition at best but not accurate. At best we have only remnants of systems that were once fully functioning but are no longer. It would be better if the city dropped the term 'natural heritage' and replace it with natural environment which would encompass a greater definition of green space and is easier to understand. I prefer very plain and clear speak, easy to understand and not embellished that would otherwise cause confusion or misinterruptation. Natural Heritage is a misleading term because it implies something greater than it is. To liberate constrained ecosystems, the city would need to prioritize linkages in a true planning fashion over the life of the new OP. Equal to the effort invested in transit and greater density.

No change - The natural heritage system language is consistent with the Provincial Policy Statement (PPS).


247 (New 1225-1230)

Policy 247: should open up concept of NH System, to note that ecosystem processes are happening everywhere not just in defined NHS, and that recognition of ecosystem based planning needs to account for all these processes across city.



248 (New1225-1230)

The PPS does not define “critical” with respect to features, species or function.Also, the context of this statement is unclear with respect to the water component. RECOMMENDATION: MNRF recommends using the term “significant natural feature” in place of “critical feature” to be consistent with the PPS.Recommend clarifying this statement using terminology and statements that are consistent with the PPS.



248 (New1225-1230)

The PPS requires identification of natural heritage systems. Natural Heritage Features do receive protection under the PPS. Therefore, it should be noted that Policy 248 goes above and beyond the PPS.

Also, where it is stated that the “Natural Heritage policies establish requirements for the identification and protection of the Natural Heritage System”, it should be clarified whether this is referring to the policies of the PPS or of the London Official Plan.MNRF recommends clarifying this Policy by revising it as follows:

The Natural Heritage policies of the London Plan establish requirements for the identification and protection of natural heritage features and areas in London. London’s natural heritage policies include how we identify the various natural heritage features, how we determine their significance, how we assess the impacts of development on them, and how we will protect them and mitigate the impacts of development. By protecting natural heritage features and areas in London, we are protecting core components of London’s natural heritage system.



248 (New1225-1230)

Policy 248: note that surface and groundwater features and hydrological functions are happening everywhere, e.g. can turn driveways back to gravel etc.

Modified-groundwater recharge areas and hydrological functions identified in both Natural Heritage and Natural Resources policies of the Plan.


249 (New 1224-1230)

As it has been mentioned by MNRF, this Policy should also reference features and functions as well as habitat and species. RECOMMENDATION: Use terminology that is consistent with the PPS with respect to natural heritage.

Modified - revised forclarity and consistency with PPS


249 (New 1224-1230)

Policy 249: add at the end "…and restore and enhance what has already been lost." No change - paragraph deals with the existing and future natural heritage system


250 (new 1231)

250 - requirement to improve ecological health is new. Should specifiy if health = functions. Modified - revised wording to use "ecological integrity"


Page 74


250 (new 1231)

It is not clear whether the natural features and areas listed in this Policy are areas of natural and scientific interest (ANSIs), provincially significant wetlands (PSWs), etc.Also, this is the first time the term “natural places” has been used and it should be defined, or otherwise, as commented previously, the term “natural features and areas” should be used throughout to ensure consistency and avoid confusion. RECOMMEMDATION: For clarity, MNRF recommends that these natural features and areas are referred to using the appropriate names as established by MNRF, especially recognizing that some of these natural features and areas are City parks, while some are PSWs and ANSIs.MNRF also recommends referencing a map that corresponds to these areas, because the names of these natural features and areas might mean different things to different people.

Modified - revised for clarity and consistency with PPS and included in maps


250 (new 1231)

P.250 - refers to Westminster Ponds, Sifton Bog etc as “natural places”. It should be clearly stated that these are environmentally significant areas.

Modified - revised for clarity and consistency with PPS and included in maps


250 (new 1231)

Policy 250: need a new paragraph on idea of stewardship and how long term we will only protect and enhance NHS if we have strong stewardship from citizens.

No change - issue addressed inboth the urban forest strategy and the stewardship policies of the Plan.


250 (new 1231)

Policy 250: suggest adding "Komoka Provincial Park" to list of natural places because portion of it lies within City.

Modified-Komoka Provincial Park identified as a provincial Life Sciences ANSI.


251 (New 1232)

Policy 251: last line change to ...natural heritage "and socio-economic" system more sustainable… (Need more on concept of ecosystem services and they're also taking place outside NHS. Also need to better integrate as one unit science of ecology with socio-ecological system)

No change - policies relate specifically to natural features and areas. The importance of natural heritage features and areas to the City is identified in these policies, and in the Green and Healthy City, Forest City and City Structure policies of the Plan.


252 (New 1233)

As commented through previous comments, the statements made within this Policy do not appear to lay out a planning framework with respect to natural heritage in the City of London. It could also be interpreted as promoting development within natural heritage features.Also, with respect to the natural heritage system “creating opportunity to share the areas with plants and animals”, the City should recognize that sharing areas with animals could be viewed negatively by Londoners, especially by those who may have been involved in human-wildlife conflict. RECOMMENDATION: MNRF recommends either (1) not identifying these as policies, but rather providing paragraphs of information for policies to come within the Official Plan; or (2) revising these policies in a way that clarifies the intent of each Policy, avoids repetition and ensures consistency with the natural heritage policies of the PPS.



253 (New 1234)

The PPS requires the “identification” and protection of significant natural features and areas, as opposed to the “recognition” of natural heritage features which has a different meaning.Also, it should be noted that for some natural heritage features, the PPS requires protection (e.g. development and site alteration within a provincially significant wetland is not prohibited), whereby for other natural heritage features (e.g. significant woodlands), the PPS requires proving no negative impact if site alteration is proposed within the natural feature. RECOMMENDATION: To ensure this statement is consistent with the PPS, MNRF provides the following suggested statement,The Natural Heritage policies of this Plan provide for the identification and protection of significant natural features and the ecological functions, processes and linkages that they provide.

Modified - revised to include the reference "identified" and protected, and for consistency with PPS


Page 75


253 (New 1234)

P.253 – is the intent of the natural heritage policies to protect only the significant natural heritage features?

No change - intent is to identify, protect, and enhance all components of the City's natural heritage system.


253 (New 1234)

P.253 – wetlands should be added to the list of hazard lands. Modified-address natural heritage aspects of wetlands in this section. Wetlands hazards addressed in Natural and Human-made Hazards policies.


253 (New 1234)

P253 – consider reworking this paragraph to clarify or simplify how the various Policy components work together.

No change - new Environmental Policies text addresses relationship and application of policies


254 (New 1235)

_2 P.254, item 2– focuses on significant natural heritage areas - what about other areas? Should this be referring to natural features vs areas?

No change -" natural features and areas" is correct terminology


254 (New 1235)

_4 P.254, item 4 – what is the intent of this Policy? Shouldn’t urban form and community design be sensitive to the natural heritage system and be appropriately setback to protect the system?



254 (New 1235)

_6 Policy 254, 6: Should say “enhancement of “, not “enhancement to”. No change - wording is correct


254 (New 1235)

_7 Sec. 254 of the Natural Heritage System portion of the plan says that “We will plan for our city to ensure that London’s Natural Heritage System is protected, conserved,enhanced and managed for present and for future generations” and that this will be done in part by item 7 (“Develop targets for tree canopy cover through the preparation and implementation of on Urban Forest Strategy.”) There is a logical inconsistency here: canopy cover targets do not necessarily affect the Natural Heritage System, as canopy cover targets could be achieved solely through extensive use of stand-alone shade trees in yards and landscaped parks (which would generally not be seen as part of the Natural Heritage System), without ever creating a “forest”. Consequently, we would stress the need for woodland cover targets (as per the Urban Forest Strategy), and that in thisparticular case (when talking about the Natural Heritage System) it should replace the Canopy Cover target item (#7), which suffers a logical disconnect with specific regards to the NHS.

Modified - reference removed, issue addressed in the Forest City chapter


254 (New 1235)

_7 P.254, item 7 – should this be in the Urban Forest Strategy section? Modified - reference removed, issue addressed in the Forest City chapter


254 (New 1235)

_7 Policy 254.7: add "and woodland (including riparian woodland cover)" after targets for tree canopy. (NB: The CA's report cards include woodlands and should be added to Targets section).

Modified - reference removed, issue addressed in the Forest City chapter


254 (New 1235)

_7 This is an Urban Forest Issue. Remove from Natural Heritage. Modified - reference removed, issue addressed in the Forest City chapter


254 (New 1235)

_8 P.254, item 8 – which management activities need to be adjusted? No change - adjustments to occur as identified as a result of monitoring


254 (New 1235)

MOECC thinks "significant" must be defined in Bullet 2 when a Policy provides for the differential protection/management of parts of the city's Natural Heritage System (especially since the NHS itself is defined by significance).In Bullet 4 the reverse should be recognized; that is, urban form and design can be used to enhance the NHS. This is consistent with a number of the plan's Strategic Directions.

Modified - revised to remove "significant" and revised point 4 to improve clarity


Page 76


255 (New 1236)

This Policy appears to repeat concepts and/or provides similar statements already made in previous natural heritage policies.Also, as commented above, the policies should provide for the “identification” of natural heritage features and areas, as opposed to the “recognition”. RECOMMENDATION: MNRF recommends re-consideration of repetitive natural heritage policies within the Official Plan. As stated within the previous comments, it seems that instead of these being identified as numbered policies, that they instead be provided as “introductory statements” and that policies focusing on defining terms that are used within the natural heritage policies and on establishing the process for identifying, mapping, protecting, etc. significant natural heritage features and areas, as well as identifying the City’s natural heritage system as is required under the PPS.



256 This is one very long sentence that can lead to confusion and it is also not clear why this is written as a Policy.For example, “mitigation of negative impacts” is not consistent with the PPS, which requires demonstration of no negative impacts (which can be done through mitigation). Also, what does it mean to “refine the Natural Heritage System through public ownership and acquisition…”? The term “enhance” might be clearer than “refine”. RECOMMENDATION: MNRF suggests that this information is a summary of natural heritage policies that should be provided as an introductory paragraph and at the same time, should be revisedd so that it is not confusing for readers and is revisedd to be consistent with the PPS.

Modified - policy removed


257 (new 1237)

Is it the City’s intention to undertake evaluations of significance of natural heritage features as part of subwatershed studies to update Map 6? MNRF would like this clarified. Also, how regularly will subwatershed studies be updated?Have additional resources been used to update Map 6? RECOMMENDATION: If the City intends to use subwatershed studies as a resource to update Map 6, MNRF recommends that an evaluation of significance is needed during the subwatershed study.MNRF suggests stating other sources that are used to keep Map 6 and Natural heritage policies current, beyond the info obtained from the subwatershed studies.

Modified - revised to clarify that subwatershed studies is one source that is used to ensure that natural heritage policies and map remain current. Policy 1238 includes that other studies may be required.


259 (New 1239)

Policy 259: Suggest all monitoring info gets put up on website so citizens have access, and also suggest online map showing health of all subwatersheds within the city.

No change - monitoring and monitoring requirement are specific to the individual sites or projects. Some information is posted on the City's website.


259 (New 1239)

The initial filters are set high so improvements are difficult to track with this process. Add the word “refine” in last sentence.

No change -policiy notes that these provide base level data to be used for other management activities.


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260 (New 1240)

Provincially significant wetlands should be designated and protected, rather than being shown in an “overlay”.Also, can it be explained in which instances an identified or delineated natural heritage feature would not be shown as Open Space Place Type or Environmental Review Place Type? If not one of those place types, what would place type would they be put under? RECOMMENDATON: Suggest revising this to include clarification with respect to the type of protection that should be provided for provincially significant wetlands, i.e. provincially significant wetlands should be identified within their own Place Type, e.g. ‘Environmental Protection Place Type’ given the level of protection provided to them under the PPS.For instance, the following revision could be made: Most, but not all natural heritage features identified or delineated on Map 6 are within Open Space Place Type or Environmental Review Place Type on Map 4… All Provincially Significant Wetlands are identified as Environmental Protection Place Type [for example], all unevaluated wetlands are identified as Environmental Review Place Type, all Significant Woodlands are identified as Open Space Place Type, etc…MNRF also requests clarification on which Place Type the remaining natural heritage features will be placed into.

Modified - revised for clarity and consistency with PPS. Reference to "overlay" removed


261 (New 1241)

If not within the Open Space or Environmental Review Place Types on Map 4, what are they identified as instead? Is there a reason why these features are not included within the Environmental Review Place Type if they need to be further assessed for significance? Can it be clarified how these features will be further evaluated?This Policy also states that features and functions may be protected through site alteration. Site alteration is defined in the PPS as activities, such as grading, excavation and the placement of fill that would change the landform and natural vegetative characteristic of a site. By definition, site alteration generally would not provide for protection of natural heritage features and areas. RECOMMENDATION: MNRF recommends placing any natural heritage features that are not yet evaluated under the Environmental Review Place Type to trigger the need for further evaluation. Once evaluated and if determined significant, MNRF recommends that they are placed within the Open Space Place Type.MNRF recommends that “site alteration” is removed from this list as the definition of the PPS suggests that this would be an impact to a natural heritage feature, rather than a measure to protect a feature.

No change - Policy 1244 addresses issue.


262 (New 1242)

Policy 262: suggest that NHS gets a separate Natural Heritage Place Type, separate from Open Space.

No change - theGreen Space place type language does not reduce the level of protection. See polices within this chapter that identify specific components of the NHS contained within the Green Space place type and that the protection they are afforded is in accordance with the PPS, and does not require a separate Place Type.


263 (New 1243)

_2 An environmental Study may not identify re-naturalization conidors etc are required as part of system and council may deem them later. This section requires a separate heading under Other Natural features if deemed by Council.



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263 (New 1243)

_2.d. It appears that SGRAs and HVAs have been lumped into the Open Space Place Type (Paragraph 263.2.d). Due to the extensive areal coverage of these vulnerable areas it is doubtful that they will remain open space. This seems to be implied with lumping them in with features often associated with the open space type. This concept should be the subject of more discussion to explore the implications of including them in this way. The City may wish to consider the vulnerability of these designated vulnerable areas which ranges from 2 to 6 for SGRAs and is 6 for HVAs. As described in the CWA the vulnerability affects the risk to the drinking water source posed by activities within the vulnerable areas.



263 (New 1243)

_3 The subheading references the Species at Risk Act not the Fisheries Act. Change to “as defined by the Species At Risk Act (SARA).”



263 (New 1243)

_4 This is where the lack of direction, focus or objectives in the context discussion tends to lead to divisiveness in planning submissions. Remove “may require” and leave at “encourage” in subheading a. Item b also requires rewording with removal of “accepted by the City”. Need a better dispute resolution process and a better evaluation process to decide.



263 (New 1243)

_4. a. P.263, item 4a) – “Council may require or encourage the retention….” We recommend that this wording be strengthened.

No change - Wording indicates that council has the authority to require the protection of a feature regardless of criteria being met for significance.


263 (New 1243)

_4.a Page 88, Policy 263 (4.)(a.): “Other Natural Features - Council may require or Having some difficulty with this Policy which is in addition to Policy No. 263 (2.)that identifies all the type of Natural Heritage Areas that are required to be protected I retained. If a specific type of Natural Feature is not requited to be protected I retained, pursuant to Provincial Policy and I or Official Plan policies, then how could Municipal Council (may) “require” it to be retained? Please consider removing the verbiage “may require” and simply leave as “encourage”.

No change - wording carried from existing Official Plan


263 (New 1243)

By stating that these are “areas identified on the basis of environmental study”, this implies that these areas are not already mapped by the City and will only be identified through environmental study.Why does this list not include Significant Valleylands?Have the Significant Woodlands been mapped by the City using criteria from the Natural Heritage Reference Manual? This is required in order to be consistent with the PPS definition of significance with respect to significant woodlands.Are all natural heritage features identified on Map 6, mapped as Open Space Place Type or are some identified as Environmental Review Place Type?As per the previous comment, MNRF has moved Locally Significant Wetlands to subsection 1, as it is MNRF’s responsibility to determine the significance of wetlands. RECOMMENDATION: To clarify this, MNRF recommends revising the introductory subheading as follows:These areas have been confirmed or will be evaluated by the City on the basis of environmental studyHowever, MNRF requests that the City provide clarification on what is considered to be an “environmental study”, e.g. environmental impact study, subwatershed study, etc.MNRF recommends that this Policy clarify when/how a natural heritage feature mapped in Map 6 is identified as Open Space Place Type and when/how a natural heritage feature mapped in Map 6 is identified as Environmental Review Place Type.

Modified - policy revised to include a list of natural heritage features and areas in Green Space Place Type


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263 (New 1243)

Not all provincially significant natural heritage features receive the same level of protection under the PPS. Therefore, it is problematic to group them all together within the same Place Type, unless it is clarified that separate policies apply to various natural heritage features within that Place Type, or that separate policies apply to the natural heritage features identified in the Natural Heritage Feature Overlay (Map 6).For example, Policy 2.1.4 of the PPS states that development and site alteration is not permitted within PSWs, whereas, Policy 2.1.5 states that development and site alteration shall not be permitted in significant ANSIs, unless it has been demonstrated that there will be no negative impacts on these natural features or their ecological functions. Therefore, it is problematic to identify PSWs and ANSIs within the same Place Type because separate policies apply under the PPS. Further, Policy 2.1.7 of the PPS states that development and site alteration shall not be permitted in habitat of endangered species and threatened species, except in accordance with provincial and federal requirements. Note that this Policy does not make any reference to the “significance” of this habitat. Also, the word “Species at Risk” can be removed as it says the same thing as “Endangered Species and Threatened Species”.Also, it should be noted that the opening statement reads “Areas Identified as Provincially Significant by the Province” and under “b”, “Regional Earth Science and Life Science ANSIs are included, which are not provincially significant as stated. RECOMMENDATION: MNRF provides the following suggested revisions.Natural heritage features and areas identified in the Open Space Place Type include:1. Areas identified and/or confirmed by the Province2. Provincially Significant Wetlands3. Locally Significant Wetlands4. Provincial and Regional Earth Science and Life Science Areas of Natural and Scientific Interest5. Habitat of Endangered Species and Threatened Species.

Modified - policy revised to include a list of natural heritage features and areas in Green Space Place Type


264 (New 1244)

We strongly support Sec. 264 (which recognizes that not all components of the Natural Heritage System may yet have been mapped on Map 6, and requires a review of lands to confirm the presence or absence of natural features as a part of the planning application process).



265 (New 1245)

Does this Policy mean that all significant natural heritage features mapped in the Open Space Place Type receive the same level of protection? The PPS identifies varying levels of protection for certain natural heritage features. See previous comment regarding Policy 260. RECOMMENDATION: MNRF recommends ensuring that Official Plan policies distinguish between the type of protection provided to each type of natural heritage feature and area identified in Policies 2.14 to 2.18 of the PPS.

Modified - revised to add components of the Natural Heritage System will be identified and evaluated in accordance with provincial requirements


265 (New 1245)

Policy 265: reiterating this Policy has a reference to guidelines. No change - comment; no change required.


266 (New 1246)

While the City may establish criteria for delineating locally significant features, the Province is the only authority that can delineate PSW’s and ANSI’s. RECOMMENDATION: This Policy needs to reflect that the Province (MNRF) is the only authority that can determine significance of PSW’s and ANSI’s.

Modified - revised to add components of the Natural Heritage System will be identified and evaluated in accordance with provincial requirements


266 (New 1246)

P. 266 – recommend listing the ESAs as per the current OP. ESAs are the City’s natural heritage gems and should be recognized in the Plan.

No change - ESAs are recognized in the plan and on the associated mapping. Listing the individual sites is not required.


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266 (New 1246)

An ESA includes core features and core habitat zones plus adjacent vegetation as buffer that is not discussed and leads to conflict over additional buffer and trail planning. Introduce text to indicate other habitat has been added to supplement the core protected zones. No change - ESAs are determined in accordance with the criteria as

described in the Plan. Criteria unchanged from current Official Plan.City Building Policies - Natural Heritage

267 (New 1247)

& 271 Policy 267 and Policy 271: It is important that ESAs and all NHS features and area boundary policies be within the London Plan as OP Policy and not left to guideline documents. Province's Natural Heritage Reference Manual is suggested for direction instead.

No change - ESAs are a City designation. Council-approved guidelines refer to NHRM. Policy 271 deleted.


268 (New 1248)

Remove this Policy as delineation of ESA should include boundary guidelines or should have been left as Candidate ESA if not completed. No change - Language and intent is from the current Official Plan.

Policy recognizes that ESA boundary may be refined over time. Different land owners come forward with development applications for their lands at different times. This policy identifies the need to conduct further evaluation on lands that may or may not meet the criteria for inclusion into the ESA


270 (New 1240)

Areas with only one of the criteria could still be recognized (i.e. endangered species, etc.) RECOMMENDATION: The Policy should reflect that areas with only one of the criteria could still be considered for recognition.

No change - ESAs represent the largest and highest quality natural areas in the City, but are not the only components of the natural heritage system. Other criteria for significance and inclusion within the NHS exist and the factors identified (i.e. Endangered Species) would allow for protection for example as a Significant Woodland or Valley land. It does not have to be an ESA to be a protected significant component of the NHS.


271 Do not agree with the filters used. Policy needs revision. Modified - policy deleted


273 (New 1252)

Map 6 This discussion regarding mapping of PSWs is unclear and should clarify MNRF’s role in the process of approving the significance of wetlands. RECOMMENDATION: MNRF recommends revising this information as follows:Wetlands evaluated using the Ontario Wetland Evaluation System are classified on the basis of scores determined through the evaluation. Wetlands meeting a score of 600 or more points, or 200 or more points in either the biological component or the special features component, and confirmed by the Ministry of Natural Resources, are mapped as Provincially Significant Wetlands on Map 6 and included in the Open Space Place Type on Map 4.



273 (New 1252)

change that wetlands MAY be delineated to SHALL be. Modified - revised for clarity and consistency with PPS


273 (New 1252)

This discussion regarding mapping of PSWs is unclear and should clarify MNRF’s role in the process of approving the significance of wetlands. RECOMMENDATION: MNRF recommends revising this information as follows:Wetlands evaluated using the Ontario Wetland Evaluation System are classified on the basis of scores determined through the evaluation. Wetlands meeting a score of 600 or more points, or 200 or more points in either the biological component or the special features component, and confirmed by the Ministry of Natural Resources, are mapped as Provincially Significant Wetlands on Map 6 and included in the Open Space Place Type on Map 4.



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273 (New 1252)

This statement can be revisedd to recognize that MNRF currently recommends use of the Ontario Wetland Evaluation System, as amended from time to time, to determine significance of wetlands. RECOMMENDATION: MNRF’s suggested Policy change includes:The determination of significant wetlands in accordance with the Provincial Policy Statement (PPS) is made by the Ministry of Natural Resources and Forestry using the Ontario Wetland Evaluation System, as amended from time to time. The Ontario Wetland Evaluation System is a scientific point-based ranking system used to identify, map and score wetlands.



273 (New 1252)

Wetlands can be identified using Ecological Land Classification (ELC), i.e. there are a number of ELC communities that MNRF considers to be wetlands (please see attachment titled, Identifying Wetlands and Potential Wetlands from ELC). However, the significance of wetlands must be determined using OWES, not ELC, as is suggested within this Policy. Also, the scoring and determination of provincially vs. locally significant wetlands is made by MNRF. After MNRF confirms the significance of a wetland, the City can then determine if they wish to map any wetland that is determined not be provincially significant, as a locally significant wetland. RECOMMENDATION: MNRF recommends revising this part of the Policy as follows:Wetlands can be identified using Ecological Land Classification. Where a wetland is identified through Ecological Land Classification, the significance of the wetland must be evaluated using the Ontario Wetland Evaluation System. For wetlands that are evaluated using the Ontario Wetland Evaluation System and confirmed by the Ministry of Natural Resources and Forestry to be not significant, the City of London may delineate the wetland on Map 6 as Locally Significant Wetland and include it in the Open Space Place Type on Map 4.



273 (New 1252)

P.273 – Evaluated wetlands “may” be delineated on Map 6? Suggest this be revised to shall be delineated.



273 (New 1252)

Our particular environmentally significant area, Meadowlily Woods, is under a Conservation Master Plan study and it seems areas of sensitivity and concern need to be identified and discussed before any change of classification of our wetland areas are considered. From our last conversations with the Upper Thames River Conservation Authority, the Ministry of Natural Resources office in Aylmer and the city ecologists, we were assured that the Meadowlily Wetland Evaluation Studies of 2004 and 2008, where our wetland areas achieved a score of 600 or higher warranted recognition as a provincially significant wetland and that the Ecological Land Classification system registered our wetland areas as being provincially significant. Is this evaluation process, mentioned in paragraph 273, transparent and does it involve community and public input? We have evidence to the effect that there are more species on the Species at Risk list for endangered species than there were in 2004 or 2008, not less! Does the wording “LocallySignificant Wetlands” from “Provincially Significant Wetland” imply a downgrading of the status of our wetlands in Meadowlily Woods?

No change - this area is an ESA and is protected


273 (New 1252)

Policy 273: suggest changing PSW status from "may be delineated on Map 6" to "shall be" delineated.

Modified - Policy identifies that any wetland identified as a PSW through the evaluation process shall be delineated on Map 6 and included on Map 4


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273 (New 1252)

Often MNR has updated wetland boundaries without consultation with the landowner or City. These boundaries have often been incorrect and not ground-truthed by MNR. Before changes occur on the schedules, there needs to be a process that vets these changes and does not impose undue costs on landowner (private or public) to correct mistakes.

No change. Province provides information to the City regarding wetlands and wetland boundaries for inclusion on Map 4.


274 (New 1299)

MNRF is aware only of an agreement made under the Endangered Species Act, 2007 that addresses impacts Endangered Species and Threatened Species and their habitat during works subject to the Drainage Act. MNRF is not familiar with an agreement that addresses Provincially Significant Wetlands, significant features, functions and wildlife habitat as is written in this Policy.Also, it should be noted that the Endangered Species Act, 2007 agreement will only be in place until June 30, 2015. As per the link below, the City will be required to register on or before July 1, 2015:https://www.ontario.ca/environment-and-energy/ditch-and-drainage-work-and-endangered-or-threatened-species. RECOMMENDATION: MNRF suggests either removing the statement regarding the agreement between MNRF and the City of London. Alternatively, the City could clarify that the agreement is made under the Endangered Species Act, 2007, that it applies to endangered species and threatened species and their habitat and place it under an alternative subheading within the London Plan.

Modified - Policy 274 moved to 1299. Reference to ESA/ Significant Wildlife Habitat clarified.


274 (New 1299)

P.274 – Work may be required within or adjacent to wetland areas to fulfill the City's responsibilities under the Drainage Act. A protocol approved by the Ministry of Natural Resources and the Ministry of Agriculture, Food and Rural Affairs will guide the City on how to proceed in such cases, in order to help protect significant features, functions and wildlife habitat. Other Federal, Provincial and Municipal legislation may be applicable for new drainage proposals contemplated within wetland areas as well and must be considered prior to works proceeding.

Modified - revised for consistency with legislation


275 (New 1253)

MNRF is concerned by use of the word “may” with respect to Council requesting any identified or unevaluated wetlands be evaluated. As per the PPS and the Natural Heritage Reference Manual, this is something that should always occur to ensure that the City is making planning decisions that are consistent with the PPS. RECOMMENDATION: As per previous comments provided regarding policies associated with PSWs, this Policy should be revisedd to state that any development or site alteration proposed in or within 120 m of an unevaluated wetland must be evaluated using OWES.

Modified - policy reworded to address comments


275 (New 1253)

P.275 – consider deleting “known” at the beginning of this sentence. Modified - policy reworded to address comments


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277 (New 1255)

Based on MNRF mapping, there are a number of concerns regarding the list of ANSIs provided in these policies:• ‘Warbler Woods or Byron Woods’ are not identified as a Provincially Significant Life Science ANSI in MNRF mapping.• Komoka Park Reserve is a “Provincially Significant Life Science ANSI”, as opposed to “Provincial Life Science ANSI” as written in this Policy.• The statement regarding Komoka Park Reserve ANSI exhibiting part of a Lake Maumee II bluff does not provide any context, i.e. how is the Lake Maumee II bluff designated (is it an Environmentally Significant Area?)• Kilworth Shoreline Provincial Earth Science ANSI should be identified as Kilworth Lake Maumee Provincially Significant Earth Science ANSI.• This Policy states that Regionally Significant and Provincially Significant ANSIs are included within Environmentally Significant Areas as delineated on Map 6, while Policy 279 states that development and site alteration is not permitted with ANSI’s. Without ANSI’s being mapped in Map 6, how will the City ensure that Policy 279 is implemented? RECOMMENDATION: MNRF suggests that the City revised the list of ANSIs identified within this Policy as per MNRF’s comments in the adjacent column.MNRF also suggests that the City map the boundaries of ANSIs separately from Environmentally Significant Areas. When updated mapping is provided, MNRF will be able to verify that the boundaries of ANSIs in the City of London have been accurately depicted.

Modified - revised to address comment. Language will be updated for consistency. ANSIs included on Map 6


277 (New 1255)

Policy 277: “Byron Bog” should be “Sifton Bog” for consistency in the Plan’s text. Modified - revised to address comment


277 (New 1255)

Policy 277: Suggest changing reference to "Komoka Park Reserve" ANSI to "Komoka Provincial Park", was regulated as new provincial park under 1989 Ont. Provincial Parks Act.



279 (New 1257)

Policy 279: suggests deleting the clause "unless demonstrated no negative impact on natural features or ecological functions".

No change - policy consistent with PPS


280 (New 1258)

PPS 2005 made reference to significant habitat of endangered species and threatened species, while PPS 2014 refers to it as habitat of endangered species and threatened species, which removes the word significant. This is because all habitat of endangered species and threatened species receives either general or regulated habitat protection under the Endangered Species Act, 2007. RECOMMENDATION: MNRF recommends revising this statement of Policy 280 to, Guidance for surveying and determining habitat of endangered and threatened species may be provided by the Ministry of Natural Resources and Forestry.



280 (New 1258)

Policy 280: Use leading capital for “Extirpated”, “Endangered”, “Threatened”, and Species of Special Concern” (as they appear in Policy 282).



280 (New 1258)

Federal species are protected on federal lands and federally funded projects only. In the context of planning, the DFO aquatic list is the only pertinent federal legislation . Add a sentence For provincial planning considerations, federally protected aquatic species at risk needs to be considered in a planning application.



280 (New 1258)

Federal species are protected on federal lands and federally funded projects only. In the context of planning, the DFO aquatic list is the only pertinent federal legislation . Add a sentence For provincial planning considerations, federally protected aquatic species at risk needs to be considered in a planning application.



281 (New 1259)

change terms to 'species of special concern' to be consistent with SARA wording. Capitalize SLSR and EIS



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282 (New 1260)

_3 Policy 282, 3: Insert hyphen in “Species-specific”. Modified - revised to address comment


282 (New 1260)

As per previous comments, “significance” should be removed from this statement, i.e. it is not a matter of determining significance when it comes to habitat of endangered species and threatened species, it is more about identification/determination of its presence on lands proposed for development and site alteration. Also, it should be noted that while habitat of endangered species and threatened species is protected under the Endangered Species Act, 2007, habitat for special concern species is considered significant wildlife habitat as per the Significant Wildlife Habitat Technical Guide and as outlined in the Natural Heritage Reference Manual.As commented above MNRF makes determinations with respect to habitat of endangered species and threatened species. The City of London makes determinations regarding the significance of wildlife habitat. RECOMMENDATION: MNRF recommends the following revision:The identification and determination of the presence of Habitat of Endangered Species and Threatened Species will be confirmed by the Ministry of Natural Resources and Forestry.MNRF suggests that the points provided in this Policy can be removed as they consist of the definition of habitat of endangered species and threatened species. The above suggested statement should be sufficient to address this.

Modified - revised to address comment. Policies 1279-1281 amended.


282 (New 1260)

” The significance of the Habitat of Endangered, Threatened and Special Concern species" are not protected under ESA. Remove reference to special concern here.

Modified - removed reference to special concern


283 (New 1280)

Certain species have habitat protection under the Endangered Species Act. This Policy would not be consistent with that legislation. RECOMMENDATION: revised this Policy as per MNRF’s recommendation.

Modified - revised to address comment.


283 (New 1280)

The location of this Policy appears to be misplaced as it is a Policy with respect to significant wildlife habitat that is included within the Species at Risk policies of the London Plan. RECOMMENDATION: MNRF suggests moving this Policy to Pg. 94 of the London Plan where the policies for Significant Wildlife Habitat are written.



283 (New 1280)

P.283 – should this be moved to the section on Significant Wildlife Habitat – paragraph 303? Last sentence – typo – replace “of” with or.



283 (New 1280)

Policy 283: Should say “ or [not “of”] their ecological functions.” Modified - revised to address comment.


283 (New 1280)

Policy 283: suggests deleting the clause "unless demonstrated no negative impacts on natural feature or ecological function".

No change - wording is consistent with the PPS


283 (New 1280)

This is misplaced and not part of Species At Risk. Move to the Significant Wildlife Habitat section, beginning at Para. 303.

Modified - moved to the Significant Wildlife Habitat section, beginning at 1279.


284 (New 1261)

City may go beyond the PPS, add species of special concern to list. No change - wording is consistent with the PPS. Other tools are available for considering identifying/protecting the feature that has a species of special concern.


285 (New 1262)

It should be noted that in some cases the Endangered Species Act, 2007 will have greater jurisdiction over aquatic species at risk. RECOMMENDATION: MNRF recommends consulting DFO on this Policy for consistency.

No change - issue addressed in Policies 1258-1262.


285 (New 1262)

P. 285 – “will” not be permitted – should this be “shall” as in the previous paragraphs? Modified - revised to address comment


286 (New 1263)

P.286 - makes reference to climate change. What is the intent of this Policy? To protect woodlands because their carbon sequestration functions helps to mitigate climate change? How does this relate to P.254, item 8?



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286 (New 1263)

P.286 – reference is made to woodlands straddling the municipal boundary. As previously indicated, the new Middlesex Natural Heritage System Study will likely be helpful to the City with respect to identifying and protecting London’s natural heritage system.



287 (New 1264)

If the woodlands have not been evaluated, how can the significance be determined? RECOMMENDATION: There appears to be overlap between this Policy and Policy 288. Natural heritage features should be protected until their significance is determined.

No change - policies provide criteria for the evaluation of unevaluated woodlands.


288 (New 1265)

This Policy and the previous seem to overlap. Unevaluated patches should be protected until it can be determined that they are not significant. RECOMMENDATION: There appears to be overlap between this Policy and Policy 287. Natural heritage features should be protected until their significance is determined.

No change - policies provide criteria for the evaluation of unevaluated woodlands.


289 (New 1266)

The criteria listed in this Policy for determining the significance of woodlands is not consistent with all criteria listed in Table 7-2 of the Natural Heritage Reference Manual and therefore, does not appear to be consistent with the PPS. Planning authorities have the ability to go above and beyond the criteria in the Natural Heritage Reference Manual for determining significance of woodlands; however, the criteria should first, at a minimum, contain the criteria outlined in the NHRM.Section 7.3.1 of the Natural Heritage Reference Manual states, Woodlands that meet a suggested minimum standard for any one of the criteria listed in table 7-2 should be considered significant. This evaluation approach will avoid overlooking sites that are outstanding in terms of only one criterion. RECOMMENDATION: MNRF recommends revising this Policy to ensure that the criteria from the Natural Heritage Reference Manual are included as part of the criteria for determining significance of woodlands in the City of London.

No change. City's guideline document references MNRF's Natural Heritage Reference Manual.


289 (New 1266)

Woodland significance criterion now added to the Official Plan. Removal or edits are needed. At a minimum, remove Ss. 3) which reflects park desires not natural heritage. Review filters in supporting document that is referenced. No change - language consistent with the current Official Plan.


289 (New 1266)

references to balanced distribution of open space amenities and passive recreation (item 3) should be incldued in parks planning not natural heritage. No change - language consistent with the current Official Plan.


289 (New 1266)

Policy #289, 292 could also include bullet 6 to read “Ontario Ministry of Natural Resources guidelines as may be published from time to time”

No change.City's guideline document references the Natural Heritage Resources Manual.


290 (New 1267)

The Natural Heritage Reference Manual establishes the criteria that MNRF considers relevant in determining significance. The PPS states that MNRF establishes the criteria. RECOMMENDATION: The Policy should reflect that the Natural Heritage Reference Manual is the document that guides the determination of significance.

No change. Guideline documents are based on, and reference the Natural Heritage Resources Manual


290 (New 1267)

It is not clear how the criteria in the London Plan (Policy 289) differ from the criteria in the Guideline Document for the Evaluation of Ecologically Significant Woodlands. RECOMMENDATION: MNR suggests that the City provide clarification within the London Plan regarding the criteria for determining significance of woodlands.

No change. Same as current OP and is consistent with the PPS.


290 (New 1267)

Policy 290: reiterate concern with Policy's reference to guidelines. No change. These guidelines are the same as those in the current Official Plan and have been extensively tested. They have been fully utilized for all assessments.


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291 (New 1268)

Before changing the woodland from Environmental Review Place Type to another Place Type, will the City also ensure that said woodland does not contain wetland, significant wildlife habitat, or other natural heritage features? RECOMMENDATION: MNRF recommends the following revisions:If a woodland is evaluated and confirmed as not being ecologically significant, it is confirmed that it does not contain other natural heritage features, and the property owner or the City have no interest in their retention, the lands may be changed from the Environmental Review Place Type to another Place Type in accordance with the policies of this Plan. In this case, the Woodlands or Unevaluated Vegetation Patch delineated or identified on Map 6 may be removed.

No change. In evaluating the woodland for significance, the presence of other natural heritage features would be identified.


291 (New 1268)

P.291 – if a woodland is determined to be “not ecologically significant” and no one has an interest in the feature, the lands can be changed to another place type? Is this Policy consistent with the Urban Forest Strategy and the City’s objective to increase its tree canopy cover?

No change. This policy relates to the ecological significance of a fwoodland, and how it is identified on Map 4 if it is determined to not be a significant woodland.


292 (New 1269)

Remove reference too 2006 study as it will become outdated. Modified-date removed.


292 (New 1269)

It is not made clear within this Policy that it is the City that determines significance of woodlands.The Natural Heritage Reference Manual contains MNRF’s recommended criteria for determining significance of woodlands, which requires only one criterion to be met for a woodland to be considered significant, e.g. size. It is not clear whether the criteria outlined in the City’s guideline document is consistent with the NHRM if consideration is given to High, Medium, Low criteria scores, rather than “yes” or “no” for meeting the Natural Heritage Reference Manual criteria.Also, without outlining specific criteria that will be used by the City to determine significance of Woodlands within the Official Plan policies, it is unclear whether this meets the requirements of the PPS. RECOMMENDATION: As per above comments regarding Policy 289, MNRF has suggested that the City’s process for determining significance of woodlands is not consistent with the Natural Heritage Reference Manual and therefore, is not consistent with the PPS. MNRF recommends that the City consider the guideline document and make any necessary updates that ensure that it meets the NHRM criteria.

No change - policy 1266 identifies the criteria for significance, and the City's guideline document references the MNRF's Natural Heritage Reference Manual.


292 (New 1269)

Scoring brought into the Official Plan. Remove or edit. Add text that the significant component(s) of the feature as identified by the guidelines will be included as Open Space Type. Add further refinement of the boundary will be completed as part of an EIS (if not already done) and all vegetation may not be included in the final removal of scoring refinement. No change - language and intent is consistent with the current

Official PlanCity Building Policies - Natural Heritage

293 (New 1270)

to 295 (New 1273)

PP.293-295 Corridors and Valleylands – similar to Significant River, Stream & Ravine Corridors section (p 298 and P299) should include a reference that these lands are regulated by the Conservation Authority having jurisdiction.

No change - Policy 1276 references conservation authority's role on potential alteration of stream corridors.


Page 87


293 (New 1270)

Corridors and valleylands are considered to be natural features, so it seems unclear to say that they “provide” natural features. It also seems problematic to include corridors and valleylands within the same policies. The Natural Heritage Reference Manual identifies the term ‘corridor’ as being synonymous with ‘linkages’ with regards to a natural heritage system. While the term ‘Valleylands’ is defined in the PPS as a natural area that occurs in a valley or other landform depression that has water flowing through or standing for some period of the year. RECOMMENDATION: MNRF suggests that the Policy could be revisedd as follows: Corridors and valleylands provide a number of important natural heritage values and ecological functions. They also overlap with a number of different natural heritage features, e.g. woodlands, wetlands, etc.MNRF also recommends that the City consider whether corridors and valleylands should be linked together into the same policies. Corridors (linkages) in regards to natural heritage systems do not receive protection under the PPS, while Significant Valleylands receive protection under Policies 2.1.5 and 2.1.8 of the PPS.



293 (New 1270)

Policy 293, third sentence: “A Valleyland [not “Valleylands are”] is defined as a natural area . . . .” !

No change - Wording is appropriate


294 (New 1271)

& 300 (New 1273)

The subtitle starting before Policy 293 is called “Corridors and Valleylands”, while Policy 294 states that Valleylands are delineated on Map 6 as Significant River, Stream and Ravine Corridors. RECOMMENDATION: MNRF recommends revising the subtitle to avoid confusion.

Modified - subtitles removed.


294 (New 1271)

Policy 294, first sentence: Insert “in” in front of “No. 1”. Modified - revised to address comment


296 (New 1274)

_5 This refers to park objectives. Does not belong in natural heritage evaluation. Remove this Policy.

No change - Language and intent is consistent with the current Official Plan. A naturalized/restored corridor that minimizes land use impacts and provides a physical separation or buffer between incompatible forms of development is part of the criteria for significant valleylands identified in the Natural Heritage Reference Manual (2010) in support of the PPS.


296 (New 1274)

_7 Refers to park objectives. Does not belong in natural heritage evaluation. Remove this Policy. No change - Language and intent is fconsistent with the current Official Plan. Under the restored ecological functions criteria for significant valleylands in the Natural Heritage Reference Manual (2010) in support of the PPS, policy 1274 would meet the standards for identification of significance.


296 (New 1274)

Items related to non-natural heritage issues should be in the parks planning section. These include item 5-visual amentiy, item 6-hazard land, and item 7-park opportunities.

No change - Language and intent is consistent with the current Official Plan. Under the restored ecological functions criteria for significant valleylands in the Natural Heritage Reference Manual (2010) in support of the PPS, policy 1274 would meet the standards for identification of significance.


297 (New 1275)

_1 Refers to trails and pathways. Does not belong in natural heritage evaluation. Remove this Policy and the provision for future pathway or access trails.

No change - Language and intent is consistent with the current Official Plan. See comment above and reference to the Natural Heritage Reference Manual (2010).


Page 88


297 (New 1275)

_2 Minimum width of significant corridors is 30m, but this is not based on any science. Remove reference to minimum width. The EIS should determine this for each site and land use proposed.

No change - Language and intent is from the current Official Plan. The minimum width of significant stream corridors is based on well-established scientific documentation/research that has accumulated over the last 2+ decades. The MNRF Natural Heritage Reference Manual (2010) Section 16.0 “Annotated Bibliography: Adjacent Lands and Buffers Research” contains numerous studies and reviews of the scientific literature on buffers and riparian habitat. Environment Canada, based on an extensive review of the scientific literature recommends that streams should have a minimum naturally vegetated buffer of 30 meters wide on both sides (or wider) from the high water mark. Further review of the literature identifies that buffers should be significantly higher depending on the desired goals for the area (i.e. if amphibians/reptiles or bird species are the primary concern or goal to preserve/enhance). The statement that the minimum corridor width of 30 meters “is not based on any science” is incorrect.


297 (New 1275)

P.297 – all river, stream and ravine corridors are regulated by the local Conservation Authorities. We suggest that the studies noted in paragraphs 1 and 2 will also be subject to the approval of the Conservation Authority having jurisdiction.

No change - Policy 1276 notes in consultation with conservation authority.


298 (New 1344)

It is not clear why a specific report is referred to within this Policy. It is also not clear why there are special considerations associated with this area. MNRF considers one of the Ecological Land Classification communities listed in this Policy to be wetland (Willow Mineral Deciduous Swamp). It should be a requirement for the wetland area to be evaluated for significance using OWES, especially if development/site alteration is proposed within that ELC community. RECOMMENDATION: MNRF requests clarification on the intent of this Policy and why there are special considerations associated with this area. It should also be clarified whether the swamp will be evaluated for significance if development/site alteration will be proposed within that vegetation community.

Modified - moved policy to clarify under Special Policies for Natural Heritage (1344)


299 (New 1276)

_3 Some stream corridors do not support permanent flow and should not be part of this consideration. Should be sure there is water before we do any meandering. No change - Language and intent is consistent with the current

Official Plan. Stream corridors (or valleylands) also include intermittent streams. Stream corridors are not limited to ones that contain permanent flow. For example, intermittent streams can provide significant contributions to fish spawning habitat, amphibian breeding habitat and nutrient input downstream. Conversely intermittent streams depending on location, flows, nutrient input, and substrates may negatively impact aquatic habitat further downstream and restoration/protection measures may be needed. Meandering of a stream is only one potential consideration for rehabilitation/restoration measures. At no point does this paragraph identify that all measures are required when action in conjunction with the Conservation Authority is undertaken.


Page 89


300 (Now 1273)

The subtitle under which Policy 300 as written is called “Alteration to Stream Corridors”. Policy 294 states that Valleylands are delineated on Map 6 as “Significant River, Stream and Ravine Corridors”. Is there a reason why the subtitle under which Policy 300 is not written as “Alteration to Significant River, Stream and Ravine Corridors” or alternatively, “Alteration to Significant Valleylands” (since the Policy is written specifically about significant valleylands? RECOMMENDATION: “of their ecological functions” should be revisedd to “and their ecological functions”.MNRF recommends ensuring that terminology is consistent throughout the policies associated with corridors and valleylands to avoid confusion and that subtitles are also consistent with the terminology used within the policies.

Modified - policy revised and moved; now 1273.


300 (Now 1273)

P. 300 – typo last line – “of” should be “or”. Modified - revised to address comment


300 (Now 1273)

Policy 300: Should say “ or [not “of”] their ecological functions.”! Modified - revised to address comment. Moved to after 1272.


300 (Now 1273)

Policy 300: suggests deleting the clause "unless demonstrated no negative impacts on natural features or ecological functions."

No change-is consistent with PPS.


301 (Now1277)

Policy 301: How will we create Upland Corridors? No work has been done on this. Only way forward is through stewardship and that requires education.

No change addressed in policy 1278.


303 (Now 1279)

This definition of significant wildlife habitat is confusing and not entirely representative of the definition in the PPS or the Natural Heritage Reference Manual. RECOMMENDATION: MNRF recommends using the definition of significant wildlife habitat from the Natural Heritage Reference Manual or the PPS to ensure that this is a clear and concise description of what is considered significant wildlife habitat.



303 (Now 1279)

P. 303 – suggest using the PPS terminology/definition for significant wildlife habitat. Modified - revised to address comment


304 (Now 1281)

As written, MNRF interprets this Policy to mean that planning applications need only to consider information from Natural Heritage Information Centre and refer to the Significant Wildlife Habitat Technical Guide. It is not clear that the City is requiring proponents to assess wildlife habitat in consideration of the criteria within the Significant Wildlife Habitat Technical Guide and Ecoregion 7E Criteria Schedules.Section 9.3.2 of the Natural Heritage Reference Manual provides a description of the process for identifying and confirming significant wildlife habitat. Therefore, MNRF recommends referring to the Natural Heritage Reference Manual within this Policy. RECOMMENDATION: MNRF recommends revising this Policy to read as follows:The significance of wildlife habitat will be assessed through the planning and development application process following the process outlined in the Natural Heritage Reference Manual. Applicants should evaluate the significance of wildlife habitat using criteria outlined in the Ministry of Natural Resources and Forestry’s Significant Wildlife Habitat Technical Guide and associated Ecoregion 7E Criteria Schedule. The following will be considered…



305 (Now 1282)

There needs to be a review to determine if this is appropriate in context or if it would be better placed elsewhere as part of development. Include “subject to the conclusions of EIS.”

No change - This policy means that of the significant wildlife habitat is not pert of another natural heritage feature that would be identified on Map 4, then it would be identified on Map 4 as significant wildlfe habitat.


306 (Now 1283)

P.306 – suggest using fish habitat definition in the PPS. Modified - revised to address comment


307 (Now 1284)

P.307 – replace “requirements” with legislation. Development and site alteration in fish habitat is also regulated by the Conservation Authority.

No change - conservation authority is referenced in policy 1283.


Page 90


308 (Now 1285)

Paragraph 308 – it is suggested that the City is planning to add SGRAs and HVAs through subsequent update to the Plan and will require protection of the hydrologic function of these areas through appropriate environmental study. This is confusing given the discussion on these areas referred to in the previous comments. Some standards or guidance may be advisable to define the studies and how the function may be protected.

Modified-revised for clarity and consistency with PPS.


308 (Now 1285)

Policy 308: Is there an organization to the three topics? Might be worthwhile considering one. Modified - revised for clarity and consistency with PPS.


308 (Now 1285)

These have been defined based on high level studies. Refinements to these areas can occur. Indicate existing areas identified can be refined.

Modified - revised for clarity and consistency with PPS.


312 (Now 1294)

& 313 (Now 1295)

P95 need to add to policies 312 and 313 re pollinator habitat Modified - revised to address comment


312 (Now 1294)

Policy 312: Needs more information here. Suggests text from Guelph regarding "Pollinator Habitat" Policy.

No change-policy 1295 modified


313 (Now 1295)

We would like to see stronger wording in Sec. 313, to go beyond simply saying opportunities for revegetating areas in the Natural Heritage System “maybe identified”to saying that replanting shall be aggressively pursued in order to help the City reach its canopy targets and environmental goals.



313 (Now 1295)

Policy 313: "community efforts" should also note "individual homeowner efforts". Modified - policy revised to remove "community efforts".


314 (Now 1289)

Is there a reason why this Policy states that “most”, not all, unevaluated vegetation patches have been included in Environmental Review Place Type? If not identified under Environmental Review Place Type, which Place Type are the remaining unevaluated vegetation patches included under?MMAH also questions why only “most” of the unevaluated vegetation patches have been included in the Environmental Review Place Type. RECOMMENDATION: MNRF suggests clarifying what Place Type the remaining unevaluated vegetation patches have been included under.All unevaluated vegetation patches should be placed under the Environmental Review Place Type until their significance can be determined.

Modified - revised for clarity and to address comment


314 (Now 1289)

p.314 – reference is made to “smaller patches”. What are the size criteria for these – less than 0.5 ha? Swamps and wetlands have been included in the list natural features/unevaluated vegetation patches. These features are regulated by Conservation Authorities and our Policy is no development in wetlands.



315 (Now 1290)

what is the significance of the change from 'delineation' to 'identification' No change - wording is in reference to maps


316 (Now 1291)

Change that unevaluated vegetation patches MAY be regulated to SHALL be regulated No change - current wording consistent with tree conservation by-law


316 (Now 1291)

This has created numerous complaints and problems and does not lead to good natural heritage planning in context with efficient land use. These small features may have very little to offer to natural heritage. Remove reference to automatic open space and look to retention of critical habitat zones and buffers or opportunities to consider in the overall plan elsewhere.

No change - language and intent is consistent with the current Official Plan


317 (Now 1292)

Policy is a great addition No change - indicates support for plan


Page 91


317 (Now 1292)

A vegetation patch could also potentially be a significant wetland, significant wildlife habitat or habitat for endangered and threatened species. RECOMMENDATION: MNRF suggests that this Policy should not just be limited to delineating these vegetation patches as “Significant Woodlands” but make the Policy more broad to include other natural heritage features that could potentially be identified. Suggested wording:… shall be included on the Open Space Place Type on Map 4 and delineated on Map 6 in accordance with the natural heritage feature that the vegetation patch is determined to be, including Significant Woodland, Provincially Significant Wetland, Locally Significant Wetland, Significant Wildlife Habitat, or Habitat of Endangered Species and Threatened Species



318 (Now 1293)

P. 318. - a protocol approved by MNR and OMAFRA will guide the City on how to proceed in carrying out works along Municipal Drains, under the Drainage Act, with additional environmental study and mitigation efforts required in order to help protect significant features, functions and wildlife habitat. Other Federal, Provincial and Municipal legislation may be applicable for new drainage proposals and must be considered prior to works proceeding.

No change - reference to agreement in the policy.


319 (Now 1296)

P.319 – should this be clarified that an EIS would be required to demonstrate that there is no negative impact?

Modified - Added new policy to define adhjacent lands, and moved previous policy to the Development and Site Alteration for clarity.


320 (Now 1300)

_1 p.320, item 1 - often natural heritage features coincide with natural hazard features so there may be situations where an existing development or use could not be expanded. Is it feasible to have a Policy whereby existing development and uses are encouraged to relocate to another place type? The wording of these polices seem permissive and contrary to the objective off keeping development out of natural areas.

No change - existing uses are permitted to remain, and any expansion subject to demonstrating no negative impacts.


320 (Now 1300)

_2 Sec. 320.2 (“Recreational uses associated with the passive enjoyment of natural features including pathways and trails provided that such uses are designed, constructed and managed to minimize their impact on the natural heritage area” — emphasis added) — There may be some areas where the construction of trails within a natural heritage area is simply too damaging to the natural ecosystem and should not be allowed. The current wording puts recreation above environmental protection in (all) OS lands, which is inappropriate given that our ESAs are typically zoned 05-5. The wording should be changed to reflect the fact that there may be sensitive open space lands where even “minimized” damage may be too much.



320 (Now 1300)

_4 Sec. 320.4 “The harvesting of trees in accordance with good forestry management practices.” — Should this not be forestry “best” management practices?

No change - policy consistent with industry standard wording.


320 (Now 1300)

_4 Policy 4 under 320 (May 22, 2014 draft Plan) should read “ The management of trees in woodlands in accordance with good forestry management practices or arboricultural practices”

No change-wording appropriate.


320 (Now 1300)

to 321 (Nox 1301)

Pg. 97, Policy 320 - text after 320 appears to be missing Policy reference numbers after “Development and Site Alteration”



320 (Now 1300)

This Policy needs to reflect “no negative impacts” not, “minimized” impacts on the natural heritage area. RECOMMENDATION: Policy should be revisedd to ensure consistency with the PPS.



Page 92


320 (Now 1300)

PSWs are included in the Open Space Place Type and as per Policy 2.1.4 of the PPS, development and site alteration shall not be permitted in significant wetlands in Ecoregion 7E.Therefore, regarding #1, the expansion of existing development and uses should not be permitted in PSWs. RECOMMENDATION: This Policy should clarify that the expansion of existing development and uses will not be permitted in Provincially Significant Wetlands when a Planning Act decision is required.



320 (Now 1300)

what are the appropriate studies referenced? How will it be demonstrated that there are no impacts? Why does recreation have to 'minimize impacts' while development may have 'no impacts'? Are parthways/trails considered to be alteration?

Modified - revised to state "no negative impacts"


321 (Now 1301)

to 328 (Now 1308)

PP 321-328 – Infrastructure - placing new or expanded infrastructure into ESA's and other elements of the Natural Heritage System should be a last resort and, subject to an EA process, when all other options have been proven impractical for a variety of reasons (not specifically because of financial concerns). Is the intent of an EIS related to an EA process simply determining mitigation/compensation measures? EIS documents address the science and other documents consider options beyond mitigation measures intended to protect the existing natural heritage system features and functions. Does the plan include mitigation and compensatory mitigation policies for non-City projects?

No change - policies 1301-1308 result of OPA 438 to the Official Plan and are proposed to remain in The London Plan


321 (Now 1301)

to 328 (Now 1308)

This section recognizes an ability to protect, improve and compensate for City-led works; this recognition should be extended to developers as well. This recognition should be extended to private sector development as well as City-led infrastructure works.

No change - development required to follow the prescribed process, regardless of proponent.


321 (Now 1301)

We understand that London City Council may prefer that infrastructure not be situated with the Natural Heritage System, however it may be recognized that a required provincial environmental assessment for an infrastructure project may reach a different conclusion.



321 (Now 1301)

With regards to Sec. 321 (“It is the preference of Municipal Council that infrastructure not be located within the Natural Heritage System.”) - in keeping with the growing recognition of the importance of green infrastructure in municipal policies and documents, this section should specify “grey” infrastructure so as to avoid suggesting that the NHS isn’t already a form of infrastructure itself. This would be consistent with the 2014 PPS: “1.6.2 Planning authorities should promote green infrastructure to complement infrastructure.”

No change - policies 321-329 result of recent amendment to the Official Plan and are proposed to remain in The London Plan


321 (Now 1301)

P.321 – suggest replacing “The maintenance” with maintaining. What other state would the Natural Heritage System be other than natural? Perhaps reword – It is important to protect the Natural Heritage System because it can assist in mitigating the impacts of climate change.

Modified-reference to maintenance of the natural heritage system removed.


321 (Now 1301)

Policy 321: Suggest changing title from "Infrastructure" to "Infrastructure and Green Infrastructure". Also suggest that city needs a Natural Heritage Master Plan.



322 (Now 1302)

& 323 (Now 1303)

It has been MOECC’s experience that the "public" may be confused between a provincial environmental assessment and an environmental impact study; therefore Policy 322 should exclude the reference to an environmental impact study. Policy 323 should delete the reference to the Environmental Assessment and clearly state that an EIS is a city document and is not to be confused with a study required by the Environmental Assessment Act.The distinction between these two documents must also be clarified in policies 363 and 365 (pg. 103)

No change - policies 1301-1308 result of OPA 438 to the Official Plan and are proposed to remain in The London Plan. Intent of the policies is to ensure that any future EIS requirements are addressed as part of an Environmental Assessment.


Page 93


322 (Now 1302)

change 'preferred' to 'only' to make section meaningful. No change - preferred alternative is a term from the EA process.


322 (Now 1302)

The phrasing in Sec. 322 seems strange (“New or expanded infrastructure shall be permitted within the Natural Heritage System only where it is clearly demonstrated through onenvironmental assessment process under the Environmental Assessment Act, including onenvironmental impact study, that it is the preferred location for the infrastructure”). Whatconstitutes preferred? Does it mean ecologically preferred, or just preferred in terms of cost or other criteria? Are trails considered infrastructure under this section, and if so, will there be any limits placed to the maximum length of trails through a natural area?

No change - preferred alternative is a term from the EA process.


322 (Now 1302)

P. 322 –the current wording is not strong enough with respect to directing new/expanded infrastructure away from the Natural Heritage System. We suggest New or expanded infrastructure may be permitted. “Shall” seems very permissive and contrary to not allowing development in the natural heritage system.

No change - policies 1301-1308 result of OPA 438 to the Official Plan and are proposed to remain in The London Plan. New policies added to "How to Use The London Plan" regarding the meaning of "shall".


323 (Now 1303)

use of wording "or portion of the NHS" is unclear. What does component mean? No change - refers to actual feature or portion of feature.


327 (Now 1307)

This appears to define mitigation as compensation. Whereas, MNRF often recommends that mitigation should also take into consideration measures that lessen/minimize an impact on a natural heritage feature, such as setbacks or fencing. RECOMMENDATION: Since compensation is not the only tool for mitigation, MNRF recommends this Policy is revisedd.



327 (Now 1307)

Policy 327, first sentence: I would prefer to see the mitigation statement being worded as “shall mean the replacement of the natural heritage feature removed or disturbed on at least a one-for-one land area basis”.



327 (Now 1307)

Page 97, Policy 327: “For the purposes of this Plan, mitigation shall mean the replacement of the natural heritage feature removed or disturbed on a one-for-one land area basis...” Please consider adding additional verbiage here to clarify thatthe proposed mitigation (one-for-one land area basis) does not need to be the exact same type of vegetation community as that which was removed and that mitigation can take place anywhere within the watershed (i.e. does not need to take place on the same parcel).

No change - policies 1301-1308 result of OPA 438 to the Official Plan and are proposed to remain in The London Plan. Actual location and form of mitigation would be determined though the EIS.


328 (Now 1308)

_2 Page 97, Policy 328 (2): Would this also be relevant to the “mitigation” referred to in Policy 327 (see comment No. 6 above).., can “mitigation” not be completed on a different parcel? If so, consider adding additional verbiage referring to “offsiteworks to restore” to Policy 327.



328 (Now 1308)

P. 328 - suggest that the City develop an "inventory" of locations which might be suitable for off-site compensation, developed in cooperation with other agencies (i.e. UTRCA) and committees of the City - (EEPAC for example).



331 (Now 1311)

Sec. 331. (“The City shall develop a program for the long-term acquisition of natural heritage areas.”) — Does such a program not exist already? And if it does, is there something more detailed about that program that could be included in here instead. (For example, specific targets for acquisition, etc.?)

No change - details to be provided in program, not the policies of The London Plan


334 Now 1314)

_3 Policy 334.3: Should note that education is through "Community based schools of sustainability or ecological literacy"

No change - policies apply to privately-owned lands.


334 (Now 1314)

_4 Policy 334, 4: “Encouraging" should be changed to “Encouragement of”. Modified - revised to address comment


Page 94


334 (Now 1314)

_6 Change wording from "adequate and appropriate" to "effective" Modified - revised to address comment. Deleted "adequate and appropriate".


335 (Now 1315)

Separate Policy into two sections - one for private and one for public lands No change - City cannot determine means of access or provide access to private lands.


335 (Now 1315)

P.335 - suggest that “Where necessary” be deleted from the beginning of the last sentence. No change - policy consistent with OMB decision wording (OPA 492)


336 (Now 1316)

Suggest new Policy at end of Stewardship section (after Policy 336), stating: need butterfly and amphibian corridors, pollinator gardens, renatualization in general. Allow community to do plantings with minimal regulation. Current by-law is cumbersome.

No change - stewardship policies are not program details.


337 (Now 1317)

Prohibit the creation of individual lots that include ecological buffers Modified - revised to address comment (1319_6)


337 (Now 1317)

New plan should include to section 15.3.6 of the current OP to identify the primary function of of buffers as zones against encroachment. Wherever possible buffers should be outside the significant area to ensure that they prevent encroachment

No change - extent of buffer determined through an EIS accepted by the City.


338 (Now 1318)

The Policy should reflect MNRF’s Natural Heritage Reference Manual for determining setbacks and ecological buffers.

No change - Addressed in the current Environmental Management Guidelines


338 (Now 1318)

Policy 338: The Natural Heritage Reference Manual has guidelines for buffers. Are City's guidelines consistent with the NH Reference Manual and the 2014 PPS?

No change - Addressed in the current Environmental Management Guidelines


338 (Now 1318)

Buffer guidelines are not appropriate and this opinion has been expressed by others. Science is only just starting to look a buffer requirements.

No change - extent of a buffer is determined through an EIS accepted by the City.


338 (Now 1318)

Buffer guidelines are not appropriate and this opinion has been expressed by others. Science is only just starting to look a buffer requirements.

No change - extent of a buffer is determined through an EIS accepted by the City.


339 (Now 1319)

_6 P.339 item 6 – recommend that the term “discouraged” be replaced with not permitted. The buffer should be part of the natural heritage system that is being protected and effectively represents the development limit. All lots should be located outside of the buffer.



339 (Now 1319)

_7 P.339 item 7 – suggest removing the term “public”. Modified - revised to address comment


339 (Now 1319)

P.339 – agree with item 5. that buffers be zoned with the appropriate zoning (OS5) such that no development can occur in them. What is meant by “standard setbacks”? The yard requirements of the adjacent development zone? Please note that if an EIS has been prepared for property that include lands regulated by a Conservation Authority (CA), the EIS will also have to be accepted by the CA having jurisdiction.

No change - extent of a buffer is determined through an EIS accepted by the City. Conservation authorities provide input as required.


339 (Now 1319)

Not all are appropriate in all situations. Add “some” or “all” to the sentence. No change - policy already refers to additional techniques that “may” be required.


340 (Now1320)

Not always needed or appropriate (lot creation versus buildings, parking lots roads etc. – for example in a condominium where the feature is protected through common agreements. Add “shall typically be set at the limit subject to conclusions of EIS.”

No change - City approval not required to amend condo agreements, so they could be changed over time.


341 (Now 1321)

_2. d. & g. P.341. item 2 d. and g. – any rehabilitation efforts would have to be undertaken in consultation with the Conservation Authority having jurisdiction.

No change - intent of policy is to identifying City priorities


341 (Now 1321)

_2.a. P. 341 Item 2.a. - typo – restore areas. Modified - revised to address comment


341 (Now 1321)

_2.a. Policy 341, 2a: Should say “ restore areas “ [not “area”] Modified - revised to address comment


341 (Now 1321)

_2.b P.341 2.b. – what about unevaluated wetlands? Pursuant to Ontario Regulation 157/06) made pursuant to Section 28 of the Conservation Authorities Act, Conservation Authorities do not permit development in wetlands.

No change - policies are related to management, restoration and rehabilitation priorities, not development.


Page 95


341 (Now 1321)

_2.c. P.341 item 2.c. – suggest removing the term “treed”. Modified - revised to address comment


341 (Now 1321)

_2.f. P.341 item 2f. – can this be reworded to state “to protect wildlife habitat”? Modified - revised to address comment


341 (Now 1321)

to 344 (Now 1324)

P99 Management, Restoration and Rehabilitation Priorities: Identify the creation of pollinator habitat is top priority

No change - issue is covered in identifying the protection and restoration or wildlife habitat, river stream, and ravine corridors; and naturalization areas


341 (Now 1321)

As commented previously, the term “critical” is not defined within the PPS, or within the Endangered Species Act, 2007 and is generally specific to SARA. RECOMMENDATION: Recommend revising to:…to protect significant wildlife habitat and restore areas that have been degraded, including habitat of endangered species and threatened species.



341 (Now 1321)

Paragraph 341 sets WHPAs, Groundwater Recharge Areas and Aquifers as management, restoration and rehabilitation priorities. This seems inconsistent with terminology accepted as designated vulnerable areas which would include SGRAs and HVAs. It seems this may be intended to be a broader reference than the designated vulnerable areas, however it is noted that aquifers are not mapped (and based on available information cannot realistically be mapped) and the recharge areas mapped in the Official Plan are considerably less areal extent than the SGRA and not consistent with SGRA mapping in the approved Assessment Report.

Modified - revised for consistency with Source Protection


341 (Now 1321)

Policy 341, suggest new subsection 'j': "Urban forests, stormwater ponds, other places with ecosystem processes and services are produced."



342 (Now 1322)

to 344 (Now 1324)

This arbitrary overlay has no status in the OP. The “Big Picture Meta-Cores” and “Meta-Corridors” and the “Big Picture” concept identified on Map 6, are for “reference purposes” only and are “not components of London’s Natural Heritage System”. They seemingly serve no purpose in the context of the Natural Heritage Policies contained within The London Plan. Remove overlay from Map 6 and reference to it in Policy 343.

No change - Language and intent is from the current Official Plan. They have a larger regional context and connectivity with systems within and outside of the City of London. The Official Plan has direction to connect to the Region and to encourage stewardship and restoration activities in these important areas


342 (Now 1322)

P.342 – recommend including a reference to the 2014 Middlesex Natural Heritage System Study.



343 (Now 1323)

Policy 343: need more teeth for meta-core policies otherwise there will be no action on this. No change - policies consistent with the current Official Plan, and these are identified as opportunities for stwardship.


345 (Now 1325)

P.345 – replace “principals” with principles. Modified - revised to address comment


345 (Now 1325)

Policy 345, first sentence: Should say “Council may request the preparation of conservation master plans. . .”



347 (Now 1367)

to 350 (Now 1370)

P.347-350 – should flood plain acquisition policies be in the natural hazard policies section? P1156 also make reference to flood plain acquisition. Should these be cross-referenced?

Modified - revised to address comment, moved to Natural and Human-made Hazards chapter (1367-1370).


351 (Now 1327)

previous OP says that the city "has" prepared guidelines, why is it change to "may" prepare guidelines in LP? Update if guidelines have been prepared

No change - wording consistent with other parts of Plan


351 (Now 1327)

Policy 351: concerned with reference to guidelines No change - policy consistent with intent of plan


Page 96


353 (Now 1329)

to 355 (Now 1331)

Need to establish the requirements of study under an SLSR. Many secondary plans are completed without detailed life science inventories and SLSR should have the same requirements. In para 354 add, “A SLSR shall provide an overview assessment of natural features.” In para 355 add, “the preparation of a more detailed EIS for these lands.”

No change - Language and intent is from the current Official Plan. Requirements of study for a SLSR are available from the City


356 (Now 1332)

awkward wording Modified - revised to address comment


356 (Now 1332)

356 is under subject status land, not EIS which starts with #357 No change - SLSR often precedes an EIS.


357 (Now 1333)

It should be noted that for some natural heritage features and areas, it is the responsibility of the Ministry of Natural Resources and Forestry to confirm the boundaries and evaluations, including wetlands, habitat for endangered species and threatened species, and areas of natural and scientific interest. RECOMMENDATION: Suggested revision:…to be reviewed and confirmed by the City, in consultation with relevant agencies, prior to completing the balance of the study.



358 (Now 1334)

why does it say Council may adopt guidelines, while OPA 438 recognizes that they exist? No change - consistent with the language used in the Plan. The wording recognizes that new guidelines may be prepared, or where guidelines have been prepared, they may be amended or revised from time to time.


359 (Now 1335)

add site alteration after development. Site alteration as defined in the PPS Modified - revised to address comment


359 (Now 1335)

It should be noted that the requirement for environmental study within 120 m of: Locations of Endangered Species or Threatened Species, Significant Habitat of Endangered and Threatened Species, Environmental Significant Areas (unless they contain natural heritage features that require adjacent consideration under the PPS, such as significant woodlands, significant wetlands, etc.) and Significant Upland Corridors goes above and beyond the requirements of the PPS.It should also be noted that the 30 m trigger distance identified for Locally Significant Wetlands and Woodlands also goes beyond the requirements of the PPS.Special Concern Species are considered Significant Wildlife Habitat and therefore the trigger distance for environmental study and area of adjacent lands should be 120 m.With respect to Environmental Review Lands, the significance of an unevaluated natural heritage feature needs to be determined before the adjacent lands width can be determined. RECOMMENDATION: revised adjacent lands trigger for Special Concern species or remove considering that it is included under the category of Significant Wildlife Habitat.Recommend revising the “as appropriate” with respect to Environmental Review Lands to “pending evaluation of significance”.

No change - Special Concern species are identified under the criteria for Significant Wildlife Habitat.


361 (Now 1338)

361 is a good addition No change - indicates support for plan


361 (Now 1338)

Change wording from "have regard to" to "be consistent with", to match current wording of PPS.

No change - policy is not related to PPS requirement


363 (Now 1340)

Section from current OP on 'avoid developmen and site alteration within the NHS' left out. Modified - revised to address comment


363 (Now 1340)

policies seem weaker that current OP section (15.5.1 vii) in that there is no clear direction re "adequately addressed"



Page 97


364 (Now 1341 and 1342)

or 358 - 362 P.364 – should this be moved to the EIS section (PP358-362)? No change - to be revised in next draft. Move 1341 to follow 1339, and 1342 remain in Environmental Assessment policies.

City Building Policies - Natural Hazards

366 (Now 1345)

Whole Chapter Hazardous Forest Types for Wildland FireWildland fire policies have been added to the new PPS, 2014. MNRF recommends the following Policy is added to the London Plan to ensure consistency with Policy 3.1.8 of the PPS regarding hazardous forest types for wildlife fire:Hazardous Forest Types for Wildland Fire are defined as forest types assessed as being associated with the risk of high to extreme wildland fire using risk assessment tools established by the Ministry of Natural Resources and Forestry, as amended from time to time. Development shall generally be directed to areas outside of lands that are unsafe for development due to the presence of hazardous forest types for wildland fire. Development may however be permitted in lands with hazardous forest types of wildland fire where the risk is mitigated in accordance with the wildland fire assessment and mitigation standards.

Modified - revised to add new policy consistent with PPS to the Forest City chapter (321).


366 (Now 1345)

Whole Chapter It appears that the policies for natural hazards have been mixed with human-made hazards. Accordingly, consideration should be given to renaming the Section – Hazard Lands and there should be two distinct sets of policies as per the sections 3.1 and 3.2 of the 2014 PPS and as was provided for in Section 15 of the current Official Plan. Furthermore as per Section 3.1.8 of the 2014 PPS, policies for hazardous forest types for wildland fire need to be included in the plan. The list in paragraph 97 should include human-made hazards.

Modified - chapter reorganized to improve clarity


366 (Now 1345)

Whole Chapter The policies in the Natural Hazards section looks good.! No change - indicates support for the Plan.


367 (Now 1346)

Paragraph 367– pertains to establishing the development limit. Should this be in the introduction or should there be a separate paragraph? Has this matter been cross-referenced in the natural heritage policies?



368 (Now 1347

to 406 (Now 1389)

MLHU supports the notion of restricted and limited development subject to rigorous environmental assessments in natural hazard areas to reduce any risk posed to human health and safety.



368 (Now 1347

Paragraph 368 - consistent with Provincial Hazard Policy, the UTRCA’s Policy is to locate and avoid natural hazards. We recommend that the wording from the introduction of Section 3.0 of the 2014 PPS be incorporated into the Plan.



369 (Now 1348)

& 370 (Now 1349)

Paragraph 369 & 370 – natural and human made hazards have been blended together - they should be separated.

Modified - objectives provided for "human made hazards"


369 (Now 1348)

Policy 369, third sentence: Should say “policies”, not “polices”. Modified - revised to address comment


369 (Now 1348)

Paragraph 369 – what is the intent of this paragraph? To protect public health and safety by directing development away from natural and/or human made hazards? The first sentence speaks specifically to natural hazards policies but then lists abandoned oil and gas wells which are human-made hazards. Are other sections of the plan being referenced because they cross reference hazard policies?

Modified - objectives proivded for "human made hazards"


Page 98

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Natural Hazards

370 (Now 1348)

_2 Page 106, Policy 370 (2.): “Provide for limited and controlled development on flood plain lands in accordance with provincial policies, where such development would be safe and appropriate, and would not reduce flood storage capacity”. As the Approval Authority, we would encourage the City to be mote specific here so that the City’s policies and intentions as to what type of “development” is permitted on flood plain lands is clearly articulated to the Conservation Authorities (CA), in order to avoid conflict between policies of the Approval Authority and the regulations of the CA’s and how they manage their “regulated areas”.

No change - Conservation authority is approval authority in floodplains


370 (Now 1348)

_3 Paragraph 370 – bullet 3 – makes reference to flood plain acquisition which is a key mechanism for managing flood susceptible lands and the risks associated therewith. Section 15.6.5 of the current Official Plan sets out the City’s policies for flood plain acquisition. We note that these policies have been moved to the Natural Heritage Section and suggest that a reference/link be provided to Hazard Lands Section of the plan.

Modified - revised to address comment. Floodplain acquisition policies moved to this section of the Plan (1367-1370)


370 (Now 1348)

_4 Paragraph 370 –bullet 4 – please consider listing this one first – identify natural hazard lands including riverine flooding and erosion hazards as well as wetlands. The next action after identifying or locating them is to avoid them or direct development away from them. The intent of this paragraph is similar to bullets 1 and 5.



370 (Now 1348)

_6 Paragraph 370 – bullet 6 – refers to climate change and infrastructure. Suggest that this objective be moved to the infrastructure section and that the PPS wording of Policy 3.1.3 Consider the potential impacts of climate that may increase the risk associated with natural hazards replace the proposed draft wording.



370 (Now 1348)

Paragraph 370 – what is the difference between bullets 1 and 5 (both pertain to minimizing the risk to public health, safety and property damage)? It is imperative to include wording which directs development away from natural hazard lands. A similar Policy should be included under the “Other Hazard Lands” section (p18, paragraph 423.)

Modified - point 5 amended to direct development away from natural hazards


370 (Now 1349)

Section370 seems to be missing a point on contaminated lands and natural methane lands. Modified - policy added to address issue related to contaminated lands.


371 (Now 1350)

Paragraph 371 – - please consider replacing the wording after 1937 observed flood event with which is estimated to occur once in 250 years.



372 (Now 1351)

Paragraph 372 – suggested revision - by restricting uses permitted in the floodplain… one zone flood plain concept Please refer to Figures 2 and 3 which illustrate these two Policy approaches.



373 (Now 1352)

Paragraph 373 – suggested revision - there are some well established communities where new development…due to flood plain Policy restrictions…. Please delete “as exceptions to the normal provincial flood plain standards” and replace regulations with policies.



374 (Now 1353)

Paragraph 374 – consider replacing “all flood plain lands” with all hazard lands including flood plain lands are regulated by the Conservation Authority having jurisdiction pursuant to the Conservation Authorities Act.

No change - policies refer to flood plains only


375 (Now 1354)

Paragraph 375 – suggested revision – delete “in these areas”. Also consider replacing the last sentence with Flood Plain lands are shown on Map 7.

No change - policy consistent with intent of plan


376 (Now 1355)

_1 Paragraph 376 – please revised bullet 1 – London’s flood plain is shown on Map 7 and is based on the Flood Standard of the Conservation Authority having jurisdiction. And bullet 2 – Detailed flood plain mapping is available from the appropriate Conservation Authority.



Page 99


376 (Now 1355)

Paragraph 376 – please update the reference to the technical manual which is Technical Guide River & Stream Systems: Flooding Hazard Limit prepared by the OMNR, 2002.



376 (Now 1355)

Policy 376: It should be clarified that the Flood Plain Planning Policy Technical Manual (1988) is a provincial publication design to interpret provincial flood plain policies, not a City document.



377 (Now 1356)

Paragraph 377 – suggested wording “except in a few cases where a two…”. Under the one zone concept, the entire flood plain is treated as floodway.



378 (Now 1357)

to 387 (now 1366)

The content of paragraphs 378, 379, 380 and 387 seems very similar with references being made to zoning and development. We recommend that consideration be given to combining/streamlining these policies/text. Also, only the UTRCA is referenced in Paragraph 387. If it stays it should be reworded that a proponent needs to obtain the approval from the Conservation Authority having jurisdiction.

No change - UTRCA is only conservation authority with 2 zone system


378 (Now 1357)

Paragraph 378 – please revised – a permit will be required. Please replace “Less restrictive zoning” with Appropriate zoning will be applied to lands within Special Policy Areas which is consistent with the specific policies for the area.

Modified - revised to include wording "consistent with"


379 (Now 1358)

Paragraph 379 – please revised development within the floodway will be restricted… Please revised bullet 2 to be consistent with UTRCA Policy as follows – Facilities which by their nature must locate near water or traverse water. Also bullet 3 – Ancillary facilities of an adjacent land use which are of a passive, non-structural nature and do not adversely affect the natural hazard or natural heritage feature or function. And bullet 4 – Municipal infrastructure including roads and utilities/services. Please note that the UTRCA does not support stormwater management facilities in the flood plain.



380 (Now 1359)

Paragraph 380 – Appears to repeat the intent/content of Paragraphs 378 & 379. No change - policy consistent with intent of plan


381 (Now 1360)

Paragraph 381 – please ensure that the listed uses are updated to be consistent with Policy 3.1.5 of the PPS. Please note that these uses are not permitted to locate in all hazardous lands/sites not just the floodway. Suggested wording – The following uses are not permitted in the flood plain:



382 (Now 1361)

to 385 (Now 1364)

Has any thought been given as to how appropriate guidelines built around the hundred yearstorm (or storm’s floodplain) will be given that a dramatic increase in such storms is expected to result from climate change? (For example, if what is currently a hundred year storm becomes a 10-year storm, should we be planning development based on our new “10-year storm” instead?) (See Sec. 382, 384, etc.). It would be good for the text to reflect any way in which such changing storm frequency (and damage) is being taken into consideration in the Plan.

No change - policy consistent with intent of plan and the policies of the conservation authority.


382 (Now 1361)

Paragraph 382 – suggest the heading be changed to Two Zone Floodway – Flood Fringe Concept consistent with the technical manual. Flood fringe areas are part of the flood plain and are not mapped separately. We therefore recommend that the last sentence be deleted.



383 (Now 1362)

Paragraph 383 – suggested wording In areas where the two zone concept is applied, the flood plain is divided into the floodway and the flood fringe.



384 (Now 1363)

Paragraph 384 – please incorporate the PPS definition for floodway and flood fringe. Bullet 2 includes duplicated text.. Please revised the last sentence – hydraulic floodway analysis.

Modified - revised to address comment. No duplicate text-describes two different conditions.


385 (Now 1364)

Paragraph 385 – pertains to the floodway. Should it be moved to the One Zone Flood Plain Concept Section?

No change - policy consistent with intent of plan, same wording as current plan


Page 100


386 (Now 1365)

_1 Paragraph 386 – bullet 1 – please add – the zoning for the floodway should reflect its prohibitive or restrictive use. Bullet 2 Flood Fringe – should also be zoned in conformity with the official plan designation. Please remove the word “safe” and replace with dry.



388 (Now 1371)

Paragraph 388 – please add specific flood prone areas of the ….. No change - policy applies to specific areas of the City located within the floodplain.


390 (Now 1373)

Policy 390: Is City serious about pursuing an SPA for West London? Nothing has happened since province commented to City on next steps in 1982, that is 32 years ago.



391 (Now 1374)

& 392 (Now 1375)

By using provincial language, the intent of this section should be clear. If the City’s intention is to consider new development that increases density in flood zones including ‘spill ways’ then it should be upfront with their plans and communicate this openly with residents.

No change - policies are consistent with PPS.


391 (Now 1374)

& 392 (Now 1375)

Even though it is illegal to build on floodplains, the City has discarded the threats by simply removing or shrinking the flood zones by flood proofing. In doing so, the City has dismissed the ecological importance of seasonal wetlands (severely threatened) and failed to protect its residents from known and predictable impacts of climate change.



391 (Now 1374)

& 392 (Now 1375)

If it is true that the Special Policy Area pertains ONLY to established areas and infrastructure then that should be clearly stated. Flood zones should already be well mapped and understood. It is difficult to understand where NEW flood areas would develop except from some sort of outstanding flooding episode.



391 (Now 1374)

& 392 (Now 1375)

In reading the section on Special Policy Areas, I felt that our conversation with City Staff was misleading. Nowhere does that section clarify that a Special Policy Area is LIMITED to maintaining EXISTING infrastructure. In fact the opposite is true. It clearly states in sections 391 and 392 that the City will consider NEW areas of development by flood proofing areas that are prone to flooding.



391 (Now 1374)

& 392 (Now 1375)

The city has also failed to recognize that ‘spill ways’ are intended to be buffer zones or transitional zones to keep residents safe. Instead the city has ignored these areas and preceded with questionable developments such as the unnecessary housing development on Beaufort Street along the Thames River.



391 (Now 1374)

& 392 (Now 1375)

Whenever possible, the purchase of floodplain lands should be encouraged to expand and restore unique habitat for sensitive species and allow for continuous uninterrupted large areas for wildlife and for residents.

No change - policies are consistent with PPS. Floodplain acquisition policies are intended to decrease the risk associated with development within the floodplain.


391 (Now 1374)

Paragraph 391 – consider replacing will allow with may allow. Modified - revised to address comment


394 (Now 1377)

Paragraph 394 – natural heritage(?) features Modified - revised to address comment


395 (Now 1378)

Policy 395, first sentence: Should say “reasonably”, not “reasonable”. Modified - revised to address comment


395 (Now 1378)

Paragraph 395 – cannot be reasonably applied to replace of reasonable Modified - revised to address comment


396 (Now 1379)

_11 Paragraph 396 – please revised bullet 11 - Site Alteration – such as the placement of fill, grading ….

No change - definitions specific to approved Coves SPA.


396 (Now 1379)

_9 Policy 396.9: Flood standards are changing fast, need conservative stance erring on side of caution and not using a meaningless statistic of standard flows/reverts.



396 (Now 1379)

Paragraph 396 – Essential Emergency Services and Institutional Uses definitions – please update to be consistent with new definitions in the 2014 PPS.



Page 101


405 (Now 1388)

Paragraph 405 – please replace “diking” with dyke system. Modified - revised to address comment


407 (Now 1390)

to 409 (Now 1392)

Please consider adding a heading to distinguish between the policies for riverine erosion hazards and wetlands.

No change - policies apply to both types of hazard


407 (Now 1390)

Paragraph 407 – Lands susceptible to erosion and wetland hazards…. Modified - revised to address comment


408 (Now 1391)

Paragraph 408 – please delete the last sentence “In areas of new development….. “. Have already addressed hazard avoidance and UTRCA Policy does not support “addressing riverine erosion hazards”.



409 (Now 1392)

_1 Paragraph 409 – bullet 1 – please delete “including possible impacts on upstream and downstream areas”.



410 (Now 1393)

& 411 (Now 1394)

Paragraphs 410 and 411 – Lands within Regulation Limit – please consider revising the wording as follows - All natural hazard lands including riverine flooding and erosion hazards as well as wetlands and the area of interferences surrounding wetlands are regulated by the three Conservation Authorities having jurisdiction in the city, in accordance with regulations made pursuant to Section 28 of the Conservation Authorities Act. This regulation requires landowners to obtain written approval prior to undertaking any site alteration or development within this area including filling, grading, construction, alteration to a watercourse and/or interference with a wetland. The Regulation Limit shown on Map 7 identifies the hazard lands which are regulated by the three local Conservation Authorities.

Modified - revised to address comment, new wording provided for policies


413 (Now 1396)

Paragraph 413 – please revised – the Conservation Authority having jurisdiction determines the extent of the riverine erosion hazard lands. These are shown on Map 7.



414 (Now 1397)

Paragraph 414 – please revised ….Limit for confined… Modified - revised to address comment


415 (Now 1398)

_2 Paragraph 415 – bullet 2 – please revised - The erosion access allowance is a six metre allowance which is added to the meander belt. It is required…..



415 (Now 1398)

Added section to OP includes meander belts plus 6m. For Unconfined systems, the 20x bankfull width is inappropriate for intermittent or ephemeral channels. 6m allowance on top of this is also not needed as there is access. Remove this Policy.

No change - policies reflect conservation authority regulations


416 (Now 1401)

Paragraph 416 – please revised ….. These features identified on Map 7 will be assessed…… Please note that remnant valley slopes are geotechnical constraints and do not form part of the regulated hazard lands in the City of London.

No change-policy refers to slopes outside hazard limit.


418 (Now 1401)

Paragraph 418 – suggest deleting … of this Plan as the Conservation Authority Regulation Limit…. Furthermore, the UTRCA does not permit development in wetlands. Development may be permitted in the area of interference subject to an EIS being completed. Please revised accordingly.

Modified - revised to include EIS requirement


418 (Now 1401)

Page 117, Policy 418: “Within regulated wetlands and their areas of interference, development or site alteration that are consistent with the underlying place type and zoning may only be permitted if prior approval is received from theConservation Authority having jurisdiction”, lithe Conservation Authority having jurisdiction already participated in the Planning Act approval processes relevant to the underlying place type and zoning, would this not be considered “prior approval”. Please consider adding additional verbiage to this Policy in order to avoid conflict between policies of the Approval Authority and the regulations of theCA’s and how they manage their “regulated areas”.

No change - addressed in Section 28 of CA Act


Page 102


419 (Now 1402)

Paragraph 419 – the Maximum Hazard Line is also shown on Map 6 but is difficult to read. Please incorporate the contemporary terminology. The regulated lands include riverine flooding and erosion hazards, wetlands and the area of interference that surrounds wetlands.

Modified - revised to include wording regarding regulated lands


420 (Now 1403)

Paragraph 420 – the heading is Geotechnical Assessments yet a range of technical studies are mentioned. Consideration should be given to consolidating bullet points 1-6.

Modified - wording changed to "technical studies"


423 (Now 1406)

Other Hazard Lands Section – suggest renaming this Human-Made Hazards consistent with the PPS.



423 (Now 1406)

Need to add natural methane areas to Section 423 as this is only contamination from human activities?

No change - natural methane not a human-made hazard


428 (Now 1411)

to 429 (Now 1412)

Page 119 - abandoned wells – consider including a reference to geothermal wells as well as requirements for new construction and abandonment.

No change - geo-thermal wells not identified as a human-made hazard.


428 (Now 1411)

Based on the requirements in Ontario Regulation 903 to decommission unused wells, MOECC staff suggest that the wording of this clause could be a bit stronger and clearer.Instead of referring to any wells an applicant may find, it may be more appropriate to require the applicant to take specific action to determine if there are any wells on the property. This change may seem minor but the existing wording could lead to an applicant saying no wells were found without actually doing an investigation.

Modified - revised to incorporate wording as suggested


429 (Now 1412)

Paragraph 429 suggests that drinking water standards for groundwater remediation should apply within 250 metres of a well. The basis for the 250 metre area is not provided however it is apparent that this is not adequate in many locations. This should be extended to the entire WHPA for municipal wells. Consideration should also be given to applying this requirement to a larger territory in areas which are highly vulnerable (HVA, SGRA).

No change - policy does not apply to municipal wells

City Building Policies - Natural Resources

430 (Now 1413)

& 431 (Now 1415)

Paragraphs 430 and 431 appear to simply tack on a reference to WHPAs and wellheads to a discussion on aggregate resources. We suggest that the discussion on WHPAs and drinking water be expanded to provide more context and also emphasis on the significance of source protection planning. Consideration should be given to developing a separate section for source water protection.

Modified-new policy 1414 added.


430 (Now 1413)

to 470 (Noew 1456)

Current resource extraction operations should be closely monitored to mitigate any air quality and groundwater issues. Any new resource extraction operations should be constrained within the City due to their known elevated adverse impacts and risks to human health.

No change - province licenses aggregate operations.


430 (Now 1413)

Whole Chapter “Kilally” should be spelled correctly as “Killaly”, after Hamilton Hartley Killaly (a former Londoner and MPP) for whom it was named. (This was pointed out in comments during the drafting of the Thames Valley Corridor Plan, and was corrected in the TVC Plan.)

No change - consistent usage in City documents


430 (Now 1413)

Whole Chapter The policies appear to be reasonable. No change - indicates support for the Plan.


430 (Now 1413)

Whole Chapter Question: is water part of Natural Resources section? If we think of water as resource because we drink it, we would act sooner to clean it.

No change - water is addressed in natural resources, policies proivded for wellhead protection, etc.


430 (Now 1413)

Whole Chapter The London Plan and associated planning policies need to incorporate policies to ensure that future land uses comply with Source Water Protection. I know that the current language makes broad references to the SWP however the mapping associated with the draft London Plan is incomplete.

Modified - new wellhead protection policies (1451-1456) added.


430 (Now 1413)

The term rehabilitate should be used in this Policy instead of remediate as it implies a contaminated site that needs to be cleaned up. RECOMMENDATION: Please remove the term remediate from text and replace with rehabilitate.



Page 103

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Natural Resources

432 (Now 1416)

Use of the term ‘recognition’ is not consistent with PPS Policy 2.5.1. RECOMMENDATION: As per Policy 2.5.1 of the PPS, MNRF suggests that the term ‘recognition’ should be replaced with ‘identification’



433 (Now 1417)

It is unclear why protection of municipal wellheads is being identified here. Policy 2.5.2.2 of the PPS indicates extraction shall be undertaken in a manner which minimizes social, economic and environmental impact. There is no need to introduce an example of an environmental impact within this Policy. RECOMMENDATION: Suggest removing, “and to protect wellhead areas to ensure high quality drinking water supply” from this Policy.

Modified - new policy added to address isssue, and to separate aggregate resources from sourcewater policies.


433 (Now 1417)

Bullet 9 of Policy 433 (and other policies in the Plan) appears to commit the city to undertaking a (provincial) source protection planning process. As the city's water supplies are presently covered by three Source Protection Planning areas: Thames Sydenham, Lake Erie and Ausable Bayfield Maitland, whose plans are not approved; MOECC presumes the Policy refers to additional work on the existing draft source protection plans to address MOECC comments and/or the city is looking at what needs to be done to integrate the source protection plans into the London Plan rather than an entirely separate source protection plan. This should be clarified. Also, MOECC are not certain if the source protection policies referred to in policies 469 and 470 are meant to be those of the Source Protection Plan in Clause 433.

Modified - revised policy 433_9 to read: "Implement Source Water Protection Plans as required …"


433 (Now 1417)

Paragraph 433 - lumps Source Water Protection and Aggregates together which seems counterproductive as they are mixed purposes. While wise use of aggregate resources are being acknowledged and allowed, the vulnerable areas are required to be protected. Furthermore, consideration should be given to restrictions on post extraction land use to limit development (such as industrial development) which poses a risk to the vulnerable aquifers left after aggregate extraction

Modified - new policy added to address isssue


436 (Now 1420)

Policy 2.5.4.1 in the PPS (2014) states that in prime agricultural areas, on prime agricultural land, extraction of mineral aggregate resources is permitted as an interim use provided that the site will be rehabilitated back to an agricultural condition. It goes on to state the specific circumstance that must be present in order for complete rehabilitation to an agricultural condition to not be required. RECOMMENDATION: OMAFRA recommends that the City incorporate the relevant policies of section 2.5.4 of the PPS in their Plan.



436 (Now 1420)

There is no discussion on how to correct this map. Need an additional paragraph on process to revised Map 7.

Modified - policy 1423 modified.


437 (Now 1421)

Add new Policy London is fortunate to have abundant aggregate resources available to them, but contractors are going further afield to get their aggregate. MNRF recommends that the ‘close to market’ piece be promoted. RECOMMENDATION: MNRF recommends that the City consider including a Policy based on Policy 2.5.2.1 of the PPS.

Modified - policy 1416 added to state that -"aggregate resources as close to market as possible"


437 (Now 1421)

Use of the term ‘operation of’ instead of ‘existing’ pits and quarries would cover off existing licensed sites under the Aggregate Resources Act (ARA) and the possibility of other sites (i.e. covered off under other approvals, exemptions under the ARA, etc.). RECOMMENDATION: Recommend replacing ‘existing’ with ‘the operation of’.

Modified - replaced "existing" with the term "operation of"


438 (Now 1422)

Since it is the change or proposed development and its impact on the pit or quarry that is being considered here, it is thought that this should read, “the potential impact of the proposed use on the pit or quarry and the future availability…” RECOMMENDATION: MNRF recommends changing the sentence to read:the potential impact of the proposed use on the pit or quarry and the future availability…



Page 104


439 (Now 1423)

When referring to conservation, the use of accessory aggregate recycling facilities within operations needs to be included in the Policy. Conservation of aggregates via recycling needs to be a separate Policy. RECOMMENDATION: The term ‘will’ should be substituted with ‘may’ and the term substantially’ should be deleted altogether.MNRF suggests replacing this sentence with:An amendment to The London Plan may be required to establish a new pit or quarry, or to expand an existing pit or quarry, in accordance with the policies of this Plan.



442 (Now 1426)

_2 While the existing London Official Plan indicates only a zoning by-law is required, an Official Plan Amendment and Zoning By-law amendment would be required. RECOMMENDATION: Suggest using the following statement as per existing Official Plan Policy: “…only a Zoning By-law amendment will be required to establish a new pit or quarry or to expand an existing pit or quarry.”

Modified - revised policy to state: “…only a Zoning By-law amendment will be required to establish a new pit or quarry or to expand an existing pit or quarry.”


452 (Now 1435)

MTO, in the past, has requested that portable asphalt plants to be permitted in all designations to facilitate its construction work.

No change - addressed under Policy 449


454 (Now 1439)

to 461 (Now 1444)

It is unclear what the difference is between the Byron Gravel Pits, Byron area and the southeast Byron area. If Byron is meaning west of North Street, then such notations should be deleted in its entirety as the area has already been developed and all sites licenced under the ARA have been surrendered. RECOMMENDATION: Please clearly identify what is being discussed in the policies.



454 (Now 1439)

This Policy contradicts with Policy 457, which states that the ultimate after use is likely to be open space and recreation. RECOMMENDATION: MNRF recommends ensuring that these policies are revisedd to avoid this contradiction.

No change - policy notes potential of both residential and recreational uses.


458 (Now 1444)

to 461 (Now 1444)

The term “will be” is not consistent with the PPS. “Shall be” should be used within these policies of the London Plan. RECOMMENDATION: MNRF recommends that the term “will be” should be revisedd to be consistent with the existing London Official Plan and be revisedd to “shall be” which is also consistent with the PPS.

Modified - revised for consistency with PPS.


459 (Now 1444_1)

Delete reference to the Ministry of the Environment in these two policies. The Ministry of Natural Resources has the lead responsibility for the regulation of aggregate extraction operations.

No change - MOEE reviews Certificate of Approval applications for noise and dust studies.


462 (Now 1445)

Kilally north lands - review UTRCA open space lands , change to future growth or OS. No change - issue addressed by specific area policies


465 (Now 1448)

& 467 (Now 1450)

Policy 465 and Policy 467: Change reference to "Petroleum Resources Act" to the newer "Oil, Gas and Salt Resources Act", which replaced Petroleum Resources Act in 1990.

Modified - updated to reflect current legislation


465 (Now 1448)

See proposed modification. RECOMMENDATION: Petroleum Resources Act should be replaced with Oil, Gas and Salt Resources Act, which is the current legislation.

Modified - change from Petroleum Resources Act to be replaced with Oil, Gas and Salt Resources Act, which is the current legislation


467 (Now 1450)

See proposed modification. RECOMMENDATION: Petroleum Resources Act should be replaced with Oil, Gas and Salt Resources Act, which is the current legislation.

Modified - change from Petroleum Resources Act to be replaced with Oil, Gas and Salt Resources Act, which is the current legislation


469 (Now 1452)

Paragraph 469 has the required wording but references the WHPA mapping rather than specific Significant Threat Applicability mapping. While it may be appropriate to reference mapping in the approved Assessment Report at this time, it would require a future update to reference the SPP mapping as noted in UTRCA comments, dated Sept. 29/14.


City Building Policies - Urban Forest

471 to 484 Note that there seems to be some inconsistency between the wording in the proposed Official Plan and the Urban Forest Strategy (possibly as the result of both being in development simultaneously).



Page 105

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Urban Forest

471 to 484 Recommend there be more consistency in the definition of the urban forest (sec. 471) between the Official Plan and the UFS, and in some of the “preamble” items (sec. 472-3 and 472-4). The section on the Urban Forest (pages 128-133) should also do more to make it clear that the Urban Forest Strategy is front-and-centre in terms of how these goals will be achieved.



471 Whole Chapter 484_4 Maintain better and monitor - Need to clarify what are included in 'park woodlands'. Significant woodlands should have a separate place type with a focus on preservation.



471 Whole Chapter It is recommended that in areas of restricted tree growth, it is better to choose smaller trees to increase survival than squeezing large canopy trees that could never reach their full potential. Choosing native trees that can reach full capacity are less likely to die and provide an ecological benefit to urban wildlife through the production of food and shelter. Examples are Burr oaks that have taps roots, not spreading roots, that can search for water down rather than out. Smaller flowering trees such as the threaten Hop Tree which is the only host tree for the endangered Swallowtail Butterfly. Native Crabapple trees or Cherry trees.

No change - the Urban Forest Strategy is better suited to address this level of detail.


471 Whole Chapter A recent approach by the city of Toronto to increase tree cover and survival by increasing the drip catchment radius (see photo in submission). and a permeable sidewalk that allows a slower absorption of rainwater.

No change - the Urban Forest Strategy is better suited to address this level of detail. Some issues addressed in green and healthy city chapters


471 Whole Chapter The Urban Forest section should be either integrated into the NHS section of Plan or at least placed next to it.

Modified - policies revised for clarification - greater distinction between parks and NHS areas


471 Policy 471: Urban Forest is mentioned as "an ecosystem", so suggests the woodland target is used. A woodland target can be found in the Conservation Authorities' report cards.

No change - targets are provided


471 How is this to be implemented? No change - policies 476 through to end of 484 provides the policies for implementation


474 We would recommend adding the word “healthy” before safe in Sec. 474 (“A thriving Urban Forest, such as that which we envision in 2035, will provide residents a safe and secure environment while preserving and enhancing environmental, aesthetic, economic, social, cultural, and recreational values.”)



475 _3 Given the 20 year time frame for the London Plan, we would like to see an item which says “Our woodland cover increases over time” added immediately after Sec. 475.3 (“Our tree canopy cover increases over time”), as per the Urban Forest Strategy (item 1.1.9 on p. 26).

No change - tree canopy cover includes woodland cover. Targets show increase over time.


475 _4 Sec. 475 could use some rewording, and establish “what are we trying to achieve”, particularly with regards to sustainability, growth (sec. 475-4) and targets (esp. sec. 475-3 which only says “Our canopy cover increases aver time”, which could prove to be setting the bar quite low — is this a 0.1% increase in canopy or a 10% increase in canopy? A specific target, higher than our current canopy cover and in line with the Urban Forest Strategy, is desirable).

No change - addressed by policies 479-480


475 _5 Sec. 475.5 (“We manage and invest in our Urban Forest as infrastructure and assets that appreciate in value over time.”) — we would recommend adding the word “important” before “assets”.



475 _5 We are glad to see mention made of the Urban Forest as infrastructure. Sec. 475-5 (managing the Urban Forest as infrastructure) should be expanded to explicitly say something along the lines of “and give it similar consideration to what is given to grey infrastructure during construction and other projects within the City”.

No change - Urban Forest is infrastructure that has equal weight and priority as other forms of infrastructure


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475 _6 Sec. 475-6 (“We establish policies that clearly define what trees will be preserved and what trees may be removed and replaced in favour of change and development”) needs clarification. Are the policies they refer to contained within the OP, or yet to come in the new ZBA or are they already in place in the form of guideline documents?



475 _6 Do all removed trees have to be replaced? Are buckthorn or other invasive or nonnative trees part of this? Consider revising this Policy to read as, “(…)6. We establish policies that clearly define what trees will be preserved and what trees may be removed and those which need to be replaced in favour of change and development.” If the City is going to establish policies to manage the Urban Forest. These policies should be part of the Official Plan.



475 _8 Sec. 475-8 (“Good forestry and aboriculture management practices are employed”) — where, and by who?

No change - high level wording that sets the context for the balance of the policies in the remainder of the chapter


476 & 480 - 482 MLHU supports that the tree canopy be further increased from the suggested 32% in Urban Forest Strategy to 34% long-term (2065) to be consistent and true to its “Forest City” title. The concept of right tree in the right place needs to be defined as invasive trees may impact the environment and thereby potentially impact the health of the nearby residents. MLHU supports planting of trees on private properties where street trees are deficient.

No change - indicates supports for the plan


476 to 484 Policies 476 through 484: All policies are commendable, especially all those outlined in Policy 484 with the exception of 484.5, to protect more, maintain better and monitor, and plant more trees.

No change - Policy 484_5 is intended to ensure that operational and inspection access is provided for City maintenance of the woodland


476 Sec. 476 - Says a UFS and UFS Implementation Plan will be established. It should say we have a UFS already, and from that the Implementation Plan will be crafted.

No change - intended to allow for updates to the Urban Forest Strategy over the life of The London Plan


477 _3 Expanding Sec. 477.3 (“Plant more - enhance the structure, function and value through planting and rehabilitation of sites.”) to include “so as to increase our canopy and woodland cover” (thus making it clear that this item extends to both types of plantings, as seen in 477.1 (“Protect more - protect existing trees, woodland ecosystems and other vegetation”).



477 Sec. 477—The first 3 points (“Protect More”, “Maintain and Monitor” and “Plant More”) are largely consistent with what section 11 of the UFS outlines, but why not change section 478 (engagement) into the 4 point? This would be more consistent with the UFS itself.



478 Sec. 478 suggests that the private-sector side of achieving these targets will be achieved through education and policies (ordinances, standards, and guidelines, etc.). Since most land in London is private, there will need to be a tremendous level of private-sector engagement in order to achieve the targets set out in sec. 480. Consequently, “planting programs” should be added to this list (education and Policy on their own will not be enough).



479 & 480 Policies #479 & 480: change to the adopted targets of 28% by 2035 (20 years) and 34% by 2065 (50 years)



480 Sec. 480 (canopy cover targets) — Correct year 2100 with 2065, and the target percentage percentage (currently written in at 32%) confirmed (as it was recently under review at PEC).



480 Where did this target come from? What is the goal of 32%? What analysis has been done? Any analysis to support this should be referenced.

No change - target was established as part of the comprehensive review leading to the Urban Forest Strategy. Council has adopted targets of 28% by 2035 (20 years) and 34% by 2065 (50 years), which are incorporated into The London Plan.


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481 Much of TFAC’s work on the Urban Forest Strategy has focused on the need to have clear woodland targets to communicate to Londoners how the City envisions canopy targets being achieved (if it means expanding or protecting forests, replacing them with standalone shade trees, or a combination of both), and to ensure that the protection of forests is, quantifiably, recognized as an important goal in London.

No change - Council adopted tree coverage targets


481 Sec. 481 —There is a disconnect with table #1 on page 20 of the UFS and this paragraph. Recall that in the place types, there is no longer differentiation between low medium and high density, it is just neighbourhood.

No change - Urban Forest Strategy will be revised to reflect the Neighbourhood Place Type tree canopy targets once The London Plan is in force and effect.


482 _3 With regards to Sec. 482.3 (“An inventory update and analysis of trees in boulevards, rural streets, manicured portions of parks and municipal properties, will be completed at least once every ten years, in support of the policies of this Plan.”) — we do not see why this should not be completed every 5 years as well, as this is already data the City collects (given that it is responsible for the purchase of all such trees).

No change - this policy sets the minimum, if resources allow it could be completed in shorter intervals.


482 Sec. 482: In addition to the “Tree canopy cover analysis”, the “woodland canopy” measurement and analysis referred to in the Urban Forest Strategy (item 1.1.9 on p. 26) should also be mentioned, as it is not just the quantity of tree cover, but also its quality, that Londoners are concerned about.

No change - The intent is to develop woodland targets. Woodland cover is a subset of tree canopy cover, so it will be captured as part of the analysis.


482 Sec. 482 (plans for analyzing data) —The 3 points here are consistent with what is shown in section 11 (pg 35) of the UFS. Would this be better contained within the strategic approach section (#484)? Or is there a reason why these points have been selected to be brought out?

No change - this Policy is part of the directional policies relating to the Urban Forest Strategy.


483 If we can include tree replacement, is there a way to provide the developer to fund monitoring through cash-in-lieu (similar to what is proposed in polciy 484-D, hold backs in subdivison of Dev Agreements, etc?)

No change - not considered for this OP review, may be in future reviews.


484 _1 Plant More: - 1 states that “The principle of planting the right tree in the right place will guide all municipal and private development-related tree planting.” Who will define what constitutes “the right tree in the right place”? What will the priorities be? Will the City be defining its own priorities, or deferring to someone else’s? Where this will be laid out (and how) should be made clear within the Official Plan, it being noted that how this is defined will have major implications for London’s Urban Forest.

No change - policies, guidelines, and standards will determine planting location


484 _1 Item 1 -- The opportunity to “scope” the tree saving plan, should be included, such that study does not have to include treed areas that are proposed to be conserved as part of the proposal.



484 _1 Protect More: What constitutes “large trees” or “significant numbers”? Is it appropriate to require tree inventories and preservation plans for small-scale projects?

Are buckthorn and other non-natives part of this inventory.



484 _1 and 482_2 Protect More: Remove the wording “outside of the natural heritage system” Modified - revised to address comment


484 _10 Plant More: What are the criteria? What is considered to be “adequate”? Shade, building cooling, what about solar rights?

Modify - Remove the words "an adequate level of"


484 _10 Tree planting is not applicable to all applications (i.e. – consents, minor variances). No change - This policy says that all applications will be "reviewed", It does not require tree planting in all instances


484 _12 Maintain and Monitor Better: We strongly support Sec. 484— Maintain Better and Monitor - 12, which identifies invasion by such pests as EAB and ALB as emergencies for funding and treatment purposes.



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484 _12 Plant More: We strongly support Sec. 484 - Plant More - 12, which requires the planting of trees on privateproperties where there are street tree deficiencies.



484 _12 Indicates draft plan conditions will include requirements for tree planting on private property. How is this to be implemented, who is responsible? It is difficult to enforce tree planting on private property. Also not sure what “associated soil requirements per gross building footprint” means. Provide greater clarity.

Modified - revised improve clarity


484 _13 & 484_14 Plant More:- 13 and 14 (dealing with the preservation of neighbourhood and street character and heritage landscapes through planting of specific tree species), we would recommend adding a caveat that where past plantings have made use of invasive species, these gradually be phased out to be replaced with the next closest non-invasive substitute species. (For example, replacing Norway Maples with native Sugar Maples or Red Maples over time).



484 _15 Plant More: While efforts to encourage higher canopy cover are supported, it may be difficult to implement such ambitious targets and mandatory measures for parking lots at the site plan stage and we would ask that this requirement be reviewed. It may also be helpful to consolidate all of the policies relating to canopy cover for parking lots under one section or Policy.



484 _15 Maintain and Monitor Better: We would recommend adding “Additional watering” to the list of possible techniques to improve tree survival in hardscape areas in Sec. 484— Maintain Better and Monitor - 15.

Modified - policy removed, to be addressed in Urban Forestry Strategy


484 _16 Plant More: revised wording of 484.16 to read “…native tree species and achievement of tree canopy cover targets.”



484 _2 Plant More: Do current lot frontages allow this for street trees? Will they shade the south facing side of house and if so, solar panels will not work.

No change - right tree in the right place principle to be applied


484 _2 Plant More: revised wording of 484.2 to read “…long term benefits and achieve tree canopy cover targets”.



484 _2 & 484_3 Item 2 and 3 – very much detail for Official Plans – can they be in implementation documents? Modified - reduced legth, detail of section


484 _2.a Protect More: Why measure 5cm trees when 10cm are all that counts? Modified - revised to address comment


484 _2.b Protect More: Area extent of replacement trees and requirement for growth should negate the need for replacement in any more than 2:1. Street trees should count. Suggestion would be 1:1 for trees to 20 cm dbh and 2:1 after that. If replaced with 5cm trees. Double this for whips as replacement.

Modified - included policy that guidelines will be developed for implementation


484 _2.b It is not reasonable to inventory all trees over 5 cm in diameter, especially since the compensation ratio is based on trees that are being removed that are over 10 cm diameter. This could result in an extensive amount of time and effort for no useful purpose. revised inventory requirement to be for trees 10 cm or larger in diameter.



484 _2.b Support the initiative. Where does the calcualtion of 1 tree >5cm per 10cm of tree removed? Need to ensure this can be defended if challenged.



484 _2.b Protect More: - 2b does a good job of detailing a strong tree replacement Policy, but how will the City ensure the survival of these replacement trees? (A lack of watering is an ongoing problem, and we would strongly suggest a watering contract separate from the planting one to ensure the trees are watered).

No change - various enforcement approaches included conditions subject ot securities


484 _2.c Protect More: This needs discussion with the development industry to establish dollar value. No change - will be implemented in collaboration with development community


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484 _2.d Protect More: What happens with the funds? Add language that requires the City to report out on an annual basis, how much money was paid into the “tree removal fund”, how much was paid out, and were the trees were planted.

No change - operational issue beyond the scope of Official Plan policy


484 _3 Plant More: The lack of mention of the issues concerning invasive species is a substantial omission from the Urban Forest Section of the current draft of the Plan, most notable in Sec. 484— Plant More - 3 (“Native species trees will be preferred for planting by the municipality, recognizing that nonnative species play an important role where native species do not survive and grow well in urban conditions orfor specific landscape objectives.”) There should be a clearly stated short-term goal of minimizing the use of invasive species in the Urban Forest, with a long-term goal of ultimately eliminating their use.

No change - invasive species management is part of good forestry practices referenced in the policies


484 _3 Note: only remove ones that are dead or dying (unhealthy) ADD: based on sound forestry practice.



484 _4 Maintain and Monitor Better: TFAC strongly supports Sec. 484— Maintain Better and Monitor - 4 (“Park woodlands will be managed for long-term sustainability and multiple woodland benefits, goads and services. Public access and recreation may not always have priority.”) This idea that access and recreational uses may not always have priority should be reiterated in Sec. 500 on Woodland Parks, especially where those parks contain sensitive ecological features.



484 _4 Plant More:—4 (“All street cross-sections will be designed to accommodate mature trees and allow for their long-term survival, growth and health through below and above-grade infrastructure”) does not specify the size of tree to be designed for:there is a big difference in designing streetscaped to accommodate lilacs versus maples. Is it allowable for all streets to be designed solely to accommodate lilacs?

No change - to be addressed in development standards


484 _5 Policy 484, 5 could allow unnecessary damage to and fragmentation of woodlands if an accessible landing area for woodland operations is permitted.

No change - intent is to make space available through good planning, not as an afterthought


484 _5 Possible re-write regarding reference to "heritage trees"? Modified - revised to address comment


484 _6 Maintain and Monitor Better: Need to acknowledge the potential impacts of roads along features. Many more impacts anticipated for this approach than rear lots next to feature.

No change - if there is science to prove this statement, mitigation measures can be incorporated to ensure the woodlands are not significantly impacted


484 _6 Species at risk - what legislation is referenced? Wording should be "identified as species at risk under Federal or Provincial legislation will be retained."



484 _6 Protect More: add the words “or removed” after the word “managed” Modified - revised to address comment


484 _7 Plant More: —7 states that (“Shade trees will be established and maintained to achieve an effective tree canopy covet along non-motorized mobility routes, such as sidewalks, bicycle lanes and pathways f....)”) — what constitutes a shade tree? We would suggest it should be of a minimum “medium” height (for example, we would not see lilac bushes nor callery pears as “shade trees”), and that it be so defined within the Official Plan.

No change - policy consistent with intent of plan; too detailed for policy


484 _7 Page 133, Policy 484 (7.): “A tree conservation by-law for private property will be established to prohibit the destruction of trees... unless and until such time as a tree cutting permit is obtained.. .this may apply.. .outside of the natural heritage system”. It is our respectful submission that attempts by the City to regulate the removal of individual trees, on private property, outside of natural heritage system is an infringement on private property rights.

No change - the tree conservation by-law does this already


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484 _8 Plant More: Who pays? Where is the space to do this? What about at commercial sites where the building is brought out to the road? Please consider identifying the “appropriate locations” where this may be required, in order to avoid the perceived subjective implementation of this Policy at a later date. Consider revising this Policy to read as, “Where possible and appropriate (…)”.

No change - the City Design Policies 144_1 to 4 - Street Trees and Landscaping identifies the appropriate locations


484 _9 Protect More: We are very supportive of a bonusing system for tree preservation and planting (Sec. 484—Protect More - 9), but would want to see the bar for this set high enough so as to ensure it has real impact where such bonuses are allowed.



484 _9 Who is responsible for preparation of treescape plans and when? Provide clarification regarding responsibility, when required (i.e. – is this a requirement for specific development applications), etc.



484 _9 Maintain Better and Monitor: revised wording of 484.9 to read “…will be used to establish…”. Modified - revised to address comment


484 Bullet 11 of this Policy speaks to the city formulating an Integrated Pest Management Plan (IPM) to supplement provincial (and federal) regulations. The ministry encourages the preparation of an IPM. While the ministry does not approve them, Staff is available for consultation. The city is required to be IPM certified (by the IPM Council of Canada) for pesticide applications for their 'public works' and would have specific reporting requirements through the Council.

Modified - revised to include "in accordance with and to…." after the word "by-law ". The requirement for IPM certification for pesticide applications is better implemented under the IPM Plan or under the Urban Forestry Strategy.


484 The current structure of Sec. 484 makes citing different points therein difficult, and may be worth revising, especially the way “Protect More” sits above “484’ but the other sub-headings (“Maintain Better and Monitor” and “Plant More”fall under it.

Modified - revised formating to improve clarity


484 Sec. 484 (“Protect More”, “Maintain and Monitor” and “Plant More”) — As it stands now, there is some correlation to this section and the UFS, but it is confusing. For example, in the Protect More section of the UFS, there are 6 strategic goals, and 19 action items, but in the OP, there are 10 separate points. We would suggest that the OP either simply list the strategic goals as they appear in the UFS, or perhaps better yet, delete this section entirely and make direct reference to the UFS itself, unless it is felt that there are some points here not currently contained in the UFS which are important to the Official Plan.

Modified - revised to improve clarity. Plan provides long term policies, UFS provides implementation tools


484 Protect More: Additional dialogue required to review landowner rights and objectives. No change - to be addressed in implementing by-laws


484 Need to better format numbering, as it will be difficult to reference specific policies in reports, etc. as there is duplication of numbers if there are no additional section breakdowns.

Modified - revised formating to improve clarity


484 Clarify if trees need to be identified as heritage attributes to invoke Policy, and whether reference is to public realm only



484 Measured at breast height – this form of measurement would vary - should be defined Modified - revised to improve clarity


484 Maintain Better and Monitor: 484.2 and 484.8 are similar in theme. Delete bullet 8. Modified - revised to address comment

City Building Policies - Parks and Recreation

485 to 504 Parks and recreational areas within the City mitigate the urban heat island effect. MLHU strongly supports the policies contained within the Parks and Recreation section as they provide direction needed to develop and maintain environments that support healthy lifestyles across the age spectrum, healthy neighbourhoods, and create a sense of place and belonging.



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Parks and Recreation

485 Whole Chapter The inclusion of Environmentally Significant Areas under “Open Space”along with City golf courses is inappropriate, because multi-use pathways are not permitted in ESAs, except in access zones at their entrance points. Significant Woodlands and Environmentally Significant Areas should be in a separate category, such as “Natural Heritage Lands”, NOT “Open Space Parks”, as Item 8 in the classification list.

No change - Policy 502 points to the Natural Heritage policies of the Plan. Policies 320 to 328 - Natural Heritage policies address recreational uses and infrastructure associated with natural heritage features to ensure that these uses are designed, constructed and managed to minimize impact on the natural heritage area. Policy 323 specifically states that and Environmental Imact Study is required as part of an Environmental Assessment and that if the impact results in the loss of the ecological features or functions of the Natural Heritage System the proposed works "shall not be permitted".


485 Whole Chapter Include a Policy requiring wheelchair accessible playgrounds. Modified - Direction 8 revised to include accessibility for everyone. Also, Policy 504_4 addresses this request, which requires that parks and public spaces will be designed to accommodate the City Facility Accessibility Design Standards.


485 Whole Chapter Balance of achieving design elements - residential development and form adjacent to parks No change - making a statement about striking a balance.


485 Policy 485: Our parks should be looked at as sustainability hot spots where the community can do typical things, plus grow and process food, later tend to animals (sheep, e.g.), have pollinator habitat and bee hives. Should also have a composting area and structures like gazebos. Blackfriars community garden is a good example.

No change - the policies under Food Systems, in particular Policy 745, supports a sustainable food system that contributes to the economic, ecological, and social well-being of our city and region


487 P137 Policy 487 references running which should be incorporated into other sections of the document assuming running is not purely for recreation or leisure.

No change - reference to running intended to convey an activity/idea


489 Policy 489: The wording should make it clear that any extension of the TVC Multi-use Pathway to complete the linkages will be kept outside the boundaries of ESAs.

No change - Policy 502 of the Parks and Recreation chapter points to the Natural Heritage policies, and the Natural Heritage Policies 320 to 328 clarify that the loss of the ecological features or functions of the component of the natural heritage feature, such that it would no longer be determined to be significant, shall not be permitted


490 and 492 The use of capital letters in the titling of Policy headings is inconsistent as shown in the examples noted.



491 _7 Prescriptive wording is an issue. There are suggestions on form of development that are unnacceptable and require adjustment.

Modified - changed to "plan for, and create, …"


491 _7 & 9 Specific text reference should be added to the cycling or multi-use path network Map 2 illustrating the infrastructure.

Modified - included reference to cycling network


491 P138 Policy 491 specific to parks and recreation, add cycling routes to content. Modified - revised to address comment


491 Policy 491: suggest adding a new subsection (subsection 12) stating "support the broader goals of the Food Charter"

No change -policies on the Food Charter is addressed under the Food System chapter


492 _1 It’s called the Parks and Recreation Strategic Master Plan Modified - revised to address comment


492 _12 We would also recommend adding “and woodland cover” after “tree canopy cover” in Sec. 492.12 (“Parks and open spaces shall be utilized to increase tree canopy cover in the city.”)

No change - tree canopy cover includes woodland cover.


492 _4 ….and recreation amenities Modified - revised to address comment


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492 _5 Add utility corridors to the list. Change the description to “continuous linked cycling system”. Modified - revised to add utility corridors. No change- for request to change description to continuous linked cycling system given that Policies 492_9 and 492_10 address this request.


492 _5 Policy 492_5 describes where the multi-use network can be located. Add utility corridors to the list

No change - list is not intended to be all-encompasing


492 _5 Consider revising this Policy to read as, “Where possible and appropriate (…)” No change - proposed change to wording unnecessary


492 _6 Request that the London Plan explain what is a pedestrian pathway versus a trail. When and how is dedication to occur, as per Section 51(25)(b) of the Planning Act? What part of right-of-way (road or sidewalk)? revised to read as, “In accordance with Section 51(25)(b) of the Planning Act (…)”.

No change - Issue addressed in Our Tools section


492 _6 Requirement for dedication of paths is not provided for in section 51.1(1) of the Planning Act. Therefore an alternate mechanism such as expropriation, purchase, donation, or bequest would be required.

No change - Section 51(25)(b) of the Planning Act is the mechanism for dedication of pedestrian pathways and bicycle pathways


492 _9 Demonstrates a strong linkage to the Bicycle Master Plan and is supported by the Committee. No change - indicates support for the policy, as written


492 _9 Policy 492_9 demonstrates a strong linkage to the Bicycle Master Plan and is supported by the Committee

No change - indicates support for the policy, as written

City building Policies - Parks and Recreation

492 _9 Policy 492, 9: The wording of the Bicycle Master Plan should make it clear that bicycles are not allowed in ESAs, and bicycle pathways will have to be placed outside of ESA boundaries.

No change - Policy 502 of the Parks and Recreation chapter points to the Natural Heritage policies which address this issue.


492 Policy 492: suggest adding a new subsection (15) that would allow parks to be used for food production as well as pollinator habitat - food forests managed by neighbours, processed locally and sold locally.

No change - addressed under Food Systems


493 493 Park Classifications - because park classifications are defined they must be applied consistenty in the LP. Creation of a separate natural heritage place type would mitigate the confusion.

Modified - policies re-written to clarify and distinguish natural heritage, woodlands and open space


493 Are parkettes and/or tot lots incorporated within Neighbourhood Parks? No change - refer to Policies 494 and 499. Neighbourhood Parks may focus on children and youth recreational needs, such as "tot lots", and Urban Parks are relatively small spaces that are to be focal points within neighbourhoods.


494 Although distance to parks has been stipulated at 800 metres, the City may want to consider noting that in greenfield developments or new large redevelopments that parks be located within a 400 metre radius or approximately 5 minute walk from residential, commercial, and employment areas.

No change - reducing the radius may not be affordable


498 _7, 867_9, 145_7, 146_2, 146_9

SE corner of Adelaide St N and Huron St - Requirements for parking at back and building locations near the street contradict business objectives to have parking near the front entrance.

No change - it is the intent that redevelopment of properties satisfy the vision and directions as set out in the policies of The London Plan

City building Policies - Parks and Recreation

500 & 501 Policies 500 and 501: Significant Woodlands should be separated from non-significant woodlands, in a Policy of their own.



500 Woodland parks (500) should be proivded the same protection as ESAs as described in 502 Modified - policies re-written to clarify and distinguish natural heritage, woodlands and open space


500 Policy#500 should read: “… but are retained for their environmental benefits, aesthetics, and….Woodland Parks may include a managed…”



501 to 503 ESA's are not parks. Policies for ESA's should be in a natural heritage section Modified - policies re-written to clarify and distinguish natural heritage, woodlands and open space


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501 The Municipality does not have the authority to take parkland beyond what is permitted in the Act. Is this section based on an interpretation of Section 51(25)(b)? Request that the City explain this process and the legislative authority to require these lands in accordance with applicable law.

No change - issue addressed in Our Tools chapter


501 NHS is not Parks. Open Space Parks (either ESAs or golf courses) do not typically include multi-use pathway systems. Is this the vision for the future? Hopes not. Notes that other policies referring to trails include 492.5 and 67.8. Also, in Policy 501, suggests adding "and ecological functions" after "protects natural features" (for PPS consistency).



502 Environmentally Significant Areas are identified in the Open Space and Parks section. The Committee recognizes the competing interest of cycling paths through these areas and the concerns to protect these important natural areas.

No change - indicates support for the policies, as written.


502 Policy 502 Environmentally Significant Areas are identified in the Open Space and Parks section. The Committee recognizes the competing interest of cycling paths through these areas and the concerns to protect these important natural areas

No change - indicates support for the policy, as written.


502 Policy 502: ESAs are not parks and should not be part of "Open Space". Modified - policies re-written to clarify and distinguish natural heritage, woodlands and open space

City Building Policies - Public Facilities and Services

502 Policy 502: There should be a clear statement that ESAs are distinct from all other City Parks, although they fall under Parks and Recreation management, and that management zones apply.



504 _1 States that “Rear lot development onto parks shall be discouraged”. Policy does not recognize cost of single loading roads and should provide more flexibility. Consider revising Policy to “Rear lot development onto parks shall be minimized and all parks will provide active, visible frontage from at least one public street.”

No change - the intent of the policy is to discourage, not entirely eliminate, opportunity for rear lot development onto parks


504 _2 504_2 parks and recreation amenity design - type of park is not specified, does Policy apply to NHS? If so, it is not consistent with preservation objectives in the LP

No change - Policy 502 points to the Natural Heritage policies of the Plan.


504 Add that the City’s assets will be acquired, managed and disposed in a way that ensures sound stewardship of public resources while delivering valued customer services.

No change - Policy 492_11 addresses the City's assets

City Building Policies - Public Facilities & Services

505 Whole Chapter Please accept this email as input from the London District Catholic School Board regarding the London Plan. We are very pleased to see that the plan considers schools, both elementary and secondary as essential infrastructure that supports neighbourhood development. As schools continue to evolve in their role, including providing child care and other services for families, it is imperative that municipal planning recognize them as essential community 'hubs'. We look forward to working with the City in the development of implementation mechanisms; including secondary plans, zoning by-laws, and internal process regarding site plan approval, severance, etc. I am confident that by working together we will be able to effectively plan for future school sites in London's cmmunities. I appreciate the excellent cooperation we have enjoyed with City staff in the development of new school sites to date.

No change - indicates support for the Plan, particularly Policies 507 and 510 that promote schools as important hubs to neighbourhoods.

City Building Policies - Public Facilities & Services

505 Whole Chapter Add new_ City-owned public facilities may be decommissioned allowing for potential redevelopment. The City will assess the public benefit of redevelopment or repurposing through a community engagement process.

Modified - revised to address comment. New policy added after 528.


505 Add recreation centres, arenas, Storybook Gardens, golf courses to list Modified - revised to address comment


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Public facilities and services

508 to 534 Public facilities and city pools are a component of the extreme weather alert system defined as cooling centres for the very vulnerable populations within the urban areas. Extended hours provide an important service to these vulnerable and socially marginalized populations.

No change - too detailed for scope of Official Plan


510 Support the network of neighbourhood hubs (community centres and other municipal facilities) large and small, that deliver recreation, municipal and community services. (remove word institutional)



514 We need to sustain these assets. No change - Policy 508 addresses the need to sustain these assets


515 Need to add the Corporate Asset Management Policy. Modified - revised to address comment


525 Speaks to co-location at City of London facilities – what about co-location opportunities at school sites.



528 Non-City owned public facilities may close, leaving important community sites for redevelopment. The City will assess need for the buildings and/or land and consider acquiring these sites, where there is an identified public benefit in doing so.

Modified - revised to address comment, issue addressed in Our Tools and City Design chapters


530 Emergency Services.... add a high level general statement about blocking of signal towers to make it part of the review process as well as other Plan review considerations.


City Building Policies - Civic Infrastructure

535 to 538 Impacts of extreme natural disaster events have cost cities billions of dollars through uninsured losses, as many municipalities insure very little of their infrastructure. The uninsured losses, along with the added expenses related to repairing and replacing infrastructure, leave the community vulnerable. To keep our citizens healthy and safe, we support the notion of developing cost effective civic infrastructure policies with embedded climate change approval engineering tools for all current and future projects.

No change - indicates support for the policies, as written


535 Whole Chapter Consider timing of civic infrastructure projects to minimize/avoid project delays (eg. Scope of project evolves to a bigger project in situtations where the services are so old that more work is necessary to rectify it, like this past summer on Victoria Street in Old North).

No change - issue addressed by Policy 544.


535 Whole Chapter Storm Drainage and SWM section (Policy 561): lawns should be discouraged as they use valuable water resources.

No change - not applicable to intent of policy.


535 Policy 535: Centralized versus decentralized infrastructure is big question. Will not have money to maintain centralized system, SWM should be treated on site or at neighbourhood level, bringing ecological thinking, closing loops and using everything more efficiently.

No change - the Storm Drainage and Stormwater Management policies address the City's practice, specifically Policy 563 clarifies that it is based on the system approach incorporated with the Subwatershed Study's implementation plan. Policy 564 also clarifies that servicng works are from an ecosystem perspective. Policy 567 further clarifies that stormwater management facilities are intended to be integrated into the design of neighbourhoods at a size and positioning that does not impede convenient mobility throughout the neighbourhood. Technical guidelines to assist in the development of Stormwater Management plans or studies and the design of effective measures is identified under Policy 576.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Civic Infrastructure

535 Change to drinking water distribution, expand definition to define what is civic infrastructure. Modified - revised to address comment


539 et al. MOECC staff fully supports the idea of planning for civic infrastructure and the intent of Policy 539 and those which follow; particularly 540, 543, 544. MOECC strongly supports the concept of longer term infrastructure planning and its integration with land use planning. As noted elsewhere in these comments, the last such longer term infrastructure planning MOECC are aware of occurred during the Vision 96 process. As they have noted on a number of occasions, most recently with respect to the Southwest Area plan, the city's recent experience in this regard has been a series of individual infrastructure projects without any observable long range planning. Consequently MOECC look forward to the city implementing these forward-looking policies.



544 Add "optimization of existing infrastructure will be considered" Modified - revised to address comment


545 SUGGESTION: revised to: “Development Charges will be established to recover costs associated with the growth portion of infrastructure required to accommodate growth and development, as established by the policies of the Development Charges Background Study and embodied in the Development Charges By-law.”



546 Revised to: “A Growth Management Implementation Strategy (GMIS) will be adopted on the basis of the Development Charges Background Study and capital budgets to establish a detailed phasing and financing plan for extending civic infrastructure within the Urban Growth Boundary. The GMIS will be subject to annual review to consider factors such as the pace of development and the health of the DC reserve funds. ”



547 Asks if this is a new Policy? Asks why the "will be considered premature" isn't a "shall" be considered premature? Suggests saying "within a five year period based on the then current Growth Management Implementation Strategy."

Modified - revised to clarify that services must be expected to arrive in 3 years


547 Suggest that “five(5)” be removed and replaced with “three (3)”.Also, add: ”The acceleration of infrastructure through a Municipal Servicing and Financing agreement to a period within three years would merit consideration of proposals as far as five(5) years into the future.



549 Policy refers to where there are "significant environmental problems". Questions what is meant by "environmental" in this context and what is meaning of "significant"? Asks if this is only pollution of ground and surface water or other features/functions?

No change - any significant environmental issue where servicing can assist


550 Change to or separate out into 2 policies: utility agency shall have regard for the policies of this plan… City will work with utility agency to establish a consultation program …. It is in our Policy but not necessarily in the Policy of the utility agency.

No change - policies provide objectives, not implementation program


552 Similar to 550 - more than just separation distances No change - policies provide objectives, not implementation program


553 and 554 These policies recognize environmental assessment processes. Assuming this is a reference to provincial environmental assessments (see comment on policies 322/323), MOECC thinks there is benefit to at least supporting the idea of coordinating civic infrastructure planning with required environmental assessments.

No change - Indicates support for the Plan. Policies 553/554 and 1295 are intended to coordinate civic infrastructure planning with required Municipal Class environmental assessments.


554 to 570 & 578 Policies 554 through 570, and 578: All these policies are especially commendable. No change - indicates support for the Plan


554 Paragraph 554 – please add ...and outside of natural hazard lands in accordance with the natural hazard policies of this plan.



554 Policy 554: after "locate all new civic infrastructure" suggests adding "(including green infrastructure)…"

No change - section does not preclude green infrastructure


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555 Policy 555: Suggests adding "and be decentralized" at end of Policy. No change

City building Policies - Civic Infrastructure

556 The plan was adopted so should probably be cited as Council adopted Corporate Asset Management Plan 2014,as of September 2, 2014.

No change - recognizing that the September 2, 2014 document may be revised over the next 20-years the current wording is intended to capture any Corporate Asset Management Plan that is adopted by Council over the life of The London Plan


559 _2 MOECC presume the Plan intends that planning for sanitary sewage services is encompassed by civic infrastructure planning as described in Policy 539 et al.They note that 559 Bullet 2 of this clause mentions the assimilative capacity of the receiving water body (presumably for the city's sewage treatment facilities- the Thames River) and the possibility of investigating "sustainable means of maintaining or improving water quality". MOECC would like to know what assimilative capacity investigation the city has done to determine existing conditions and whether "sustainable means of maintaining or improving water quality" needs to be studied? MOECC believes this kind of analysis ought to be part and parcel of infrastructure planning for sanitary and storm water management services and think the Plan should recognize the city's position in this.The completion and regular up-dating of an infrastructure/sanitary sewage servicing plan/s would negate the need for project by project expansions in response to development applications envisaged by Bullet 4.Bullet 9 could also identify and commit to completing the Pollution Prevention Control Plan as the primary means of remediating combined sewers and reducing overflows from the city sewage treatment facilities.



559 _2 Remove assimilative capacity … add new Policy to sanitary policies similar to 560_2 all development within UGB will be serviced by the City of London sanitary servicing system.



559 _3.a How will this be monitored? No change - monitoring will be implemented through the GMIS


559 _3.b States that this is a big deal. Asks if this means access to infrastructure? Asks if LDI has reacted to this Policy?

No change - is consistent with approach taken in the policies of the current Official Plan


559 _6 In all rural servicing either civic infrastructure in rural london with pointer to the other section of the plan


City Building Policies - Civic infrastructure

559 All areas growth must occur on full municipal or private communal systems unless it can be demonstrated otherwise. Individual on-site systems are not permitted as-of-right. RECOMMENDATION: The Policy should reflect that individual on-site wastewater systems may be permitted subject to the demonstration that municipal water/sewage services and private communal water/sewage services cannot be provided.

Modified - Policy 559 _5 explicitly states that within the UGB that new development will be permitted only if it can be connected to adequate municipal sanitary sewage infrastructure. Policy 559_6 applies to lands outside of the UGB within Rural London. Specific Rural London policies for individual on-site wastewater treatment systems will be incorporated into the Civic Infrastructure The London Plan.


559 Change to essential for public and environmental health Modified - revised to address comment


560 _1 Change "may" to "will" … water distribution master plan will be prepared… Modified - revised to address comment


560 _14 Bullet 14 should be revisedd as it is not "development" per se which must comply with the cited provincial legislation.



560 _17 Add new Policy: development shall be designed and, if staged, implemented so as not to create a regulated system under the safe drinking act.



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560 _4 It is not abundantly clear where the City’s emergency wells are located. RECOMMENDATION: Please clarify that these wells are in fact shown on the map as indicated in the Plan’s Policy subsection 4, as they relate to development and site alteration which may include agricultural uses.

No change - emergency wells are mapped on Map 7, labelled as "Emergency Municipal Water Wells"


560 _6 Bullet 6 should state that decommissioning of an abandoned water well must be done in accordance with provincial regulation. (0. Reg 903 to be specific).



560 _7 Policy 560.7: suggests that industries requiring large volumes of water be made to collect water off their roofs.

No change - can be addressed under Policy 555 relating to green technologies and construction methods


560 _9 If the City is intent on recovering costs of growth from growth, and since the City does not control prices, it is possible that some people may judge that the service is not being provided “at a reasonable cost”. This paragraph opens the door to criticism that the cost of services provided through DC rates are not “a reasonable cost”. We should switch emphasis from ”reasonable cost” to ‘acceptable standard + lowest cost possible’. SUGGESTION: Instead of“ The City will provide and maintain …..at a reasonable cost. “Insert :“ The City will provide and maintain …..at an acceptable standard and at the lowest cost possible.”



560 All areas growth must occur on full municipal or private communal systems unless it can be demonstrated otherwise. Individual on-site systems are not permitted as-of-right. RECOMMENDATION: The Policy should reflect that individual on-site water systems may be permitted subject to the demonstration that municipal water services and private communal water services cannot be provided.

No change - policies included for temporary servicing inside Urban Growth Boundary, no private on-site services permitted inside Urban Growth Boundary


561 to 578 P157 Stormwater drainage and stormwater management: Add section on creation of pollinator habitat around each old and new stormwater management facility.

No change - addressed under Green and Healthy City and Forest City


561 In the future, many non-single family residential developments (e.g., commercial, industrial, multi-family residential) will be required to have on-site private permanent stormwater management controls either replacing or in addition to major stormwater management facilities. The London Plan does not contain any Policy basis/Policy support for private permanent systems, which would appear to be necessary. SUGGESTION: Add a Policy(s) regarding SWM private permanent systems.



562 Paragraph 562 – replace environmental and ecological features and functions with natural heritage system



563 & 564 Paragraphs 563 & 564 – pertains to subwatershed studies and it seems to be implied that they are servicing/stormwater management studies. Subwatershed planning is a method of managing ground and surface water systems through engineering and land-use planning that is based on ecology and wise resource management. The focus of a watershed plan should be to protect and maintain natural heritage features and ecological processes while allowing urbanization to occur. Subwatershed plans should include the conservation/protection of wetlands and woodlands, the maintenance, or enhancement, of fish habitat, the conservation and restoration of ecologically functional natural features and corridors, the protection of hydrological and hydrogeological functions as well as land use planning and stormwater and flood plain management.



563 MOECC staff assumes that the reference to "the environmental assessment process" in this clause is a provincial EA as stated in Clause 565. This could be clearer.



565 Include to protect AND ENHANCE natural heritage features and functions, not only to protect. Modified - revised to address comment


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566 Use the PPS. "Significant components" is not defined. Modified - removed word "significant"


566 Paragraph 566 – please delete ….. “significant components of the” Natural Heritage System. Modified - revised to address comment


566 Should be revised as follows: "Stormwater Management Facilities function as the water resources/stormwater management sewage infrastructure and systems that will be designed in accordance with the water resources and stormwater management criteria and environmental targets identified in the approved Subwatershed Studies and updates and located in accordance with the accepted Municipal Class Environmental Assessment, Secondary Plan and/or Area Plan"



567 Policy 567: Suggest that SWM facilities be designed to foster ecosystem services, incl. pollination and food prod'n.

No change - addressed under the Green and Healthy City, and the Food Systems chapters


568 Wording is unclear. SWM facilities will be integrated with ESAs? No change - Policies 566 and 569 clarify the integration of SWM facilities with natural heritage areas


568 Paragraph 568 – what is meant by “if possible”? Which trumps the other – natural heritage protection or swm facilities? This Policy needs to be reworded to ensure that the natural heritage system is protected.



569 Should say stormwater infrastructure will be outside NHS unless there is no other option as determined through an EA.


City Building Policies - Civic infrastructure

569 Why are outlets an exception to this Policy? MNRF has concerns with respect to placing Stormwater management outlets within PSWs. RECOMMENDATION: MNRF suggests clarifying that Stormwater management outlets will not be placed within PSWs.

Modified - revised to clarify


569 MOECC staff has no issues per se with the intent to locate stormwater management/treatment ponds and infrastructure outside of natural areas. We think this Policy could be strengthened by excluding the use of natural features such as natural wetlands from providing primary stormwater treatment, from excluding stormwater treatment (ponds) from locating within watercourses and ensuring that treatment facilities are not located at sites subject to flooding. The rationale being that under provincial legislation stormwater is defined as sewage and untreated sewage is not to be discharged to the environment and therefore treatment facilities should not be located where there is potential to discharge untreated stormwater (sewage) to the environment.

Modified - new clause added to Policy 569 to reference Natural Heritage policies. The Natural Heritage policies 321 to 328 require Municipal Class Environmental Assessment, including an Environmental Impact Study, for new or expanded infrastructure within the Natural Heritage System. Policy 323 specifies that any impact resulting in the loss of ecological features or functions such that the feature would no longer be significant, shall not be permitted.


569 Paragraph 569 – what is meant by “It is a strong preference”? Request that this be reworded such that It is strongly encouraged that stormwater management ponds and stormwater drainage infrastructure with the exception of outlets to be located outside of the Natural Heritage System and Natural Hazard areas.



570 Paragraph 570 - Please ensure that the stormwater policies are consistent with the 2014 PPS (Section 1.6). These policies include that planning for stormwater management shall promote stormwater management best practices including stormwater attenuation and re-use and low impact development. [Policy 1.6.6.7e) }



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571 & 573 MOECC staff believes these policies would benefit from inclusion of a specific requirement for storm drainage and stormwater management plans, including those completed as a component of a secondary plan, to be consistent with adopted watershed/subwatershed studies. It is MOECC’s view that it is not sufficient in Policy 573 to only say that plans will be based on tributary areas as delineated in subwatershed studies. If there is no requirement to be consistent with Council-adopted subwatershed studies then the city is faced with any number of project-specific "plans" without an overall municipal structure.



571 _8 Paragraph 571 – bullet 8 – protect and enhance the functions of related natural heritage features – the only way this will happen is if swm facilities are not permitted in the natural heritage system and natural hazard lands. Is this the intent because we fully support this Policy. Please replace features with system.

No change - wording is as intended


571 Bullet 9 – consider rewording so that it notes “SWMPs shall be designed as amenity spaces and integrated into the park and open spaces wherever possible”



575 MOECC staff strongly believes that temporary stormwater management facilities should only be considered in the context of an overall storm drainage and stormwater management plan completed in accordance with the policies of the Plan.



578 Please remove the last part of Policy no. 578 that states "in order to reduce large scale ponds that impede neighbourhood mobility" as this is only one benefit associated with incorporating green infrastructure and other innovative Stormwater Management techniques.



579 _3 Securities? Check 17.2.4.ii)d) in current OP. Modified - revised to address comment


579 _4 "delegate" the operate. Modified - revised to address comment


579 _5 Policy doesn’t match 579_4. Modified - revised to address comment


579 _7 This Policy is a carry-over from the current Official Plan regarding the need for development to pay DCs even if servicing is provided through temporary servicing. Although the Policy is necessary and beneficial, it speaks to developers paying DCs, which is not normally the case. As a result, it is suggested that the wording be revised to speak to the party that pays DCs. SUGGESTION: revised to: Properties benefitting from temporary servicing will be required to contribute to the long-term servicing solution through the payment of Development Charges for development as prescribed in the Development Charges By-law.



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579 It continues to be MOECC's position and recommendation that consideration of temporary services only occur within the context of an overall (master) infrastructure/servicing plan as contemplated by various policies of the Plan.



579 Add rural servicing policies before liquid waste management. Modified - revised to address comment


579 Change "would like to discourage" to "shall discourage". Modified - revised to address comment


580 584 MOECC questions why there are not references to the more detailed provisions in policies 1108, 1109 and 1110 which deal with development of Heavy Industrial Place Types, and depending upon which Industrial Place Type is proposed for a solid waste diversion and/or recovery facility?

Modified - revised policy to point to Heavy Industrial Place Type


581 Solid Waste Management section (starting at s. 581): This section should identify a target of zero solid waste by 2035. Commenter's personal diversion is 80%.

No change - existing targets are appropriate


583 _2 Policy 583.2: Suggest collaborating with sellers of merchandise to minimize and eliminate packaging.

No change - 583_1 speaks to collaboration


584 The amount of land dedicated to the W12A landfill as shown on Map 4 is much larger than the area described in the City’s current Official Plan. RECOMMENDATION: Please see OMAFRA’s comments below as they relate to section 1266 of the Plan.

Modified - Map 4 revised to address comment


587 "Certificate of Approval" now called "Environmental Compliance Approval (ECA)" Modified - revised to address comment


590 The wording of this clause is convoluted and should be made clearer. MOECC presumes the basic message is that new development will not be permitted in proximity to active or closed landfill sites which generate methane gases and leachate because such emissions may adversely affect that development.



590 It would helpful to understand the area which these policies apply, as they relate to development and site alteration which may include agricultural uses. RECOMMENDATON: It would helpful to understand the area which these policies apply, as they relate to development and site alteration which may include agricultural uses.

Modified - revised to clarify. Incorporated a new policy that points to the policies in Rural London, and/or as shown on Map 4.


591 & 592 These clauses refer to a potential influence area around methane gas producing facilities such as active and closed landfills. There is no description of what a potential influence area is in either clause or elsewhere in this section of the Plan. There is mention of a compatibility study meeting MOECC guidelines. Guideline D-4 establishes a potential influence area around a landfill as 500 metres. What needs to be said is that the purpose of such a study is to delineate an influence area and in doing so it may recommend mitigation measures such as distance separation, buffering, and compatible intervening land uses. Also, the migration of leachate from an active or closed landfill can be as potentially harmful as the release of methane gas.



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Homelessness Prevention and Housing

596 to 629 Homeless people have poorer physical and mental health than the general population (Community Health Status Resource, 2012). Access to primary health care is fundamentally necessary to assist with their health needs. MLHU supports the requirement to include 25% affordable housing in secondary plans and larger residential proposals. To further support the needs of those living in poverty, it is recommended that this section include a Policy that requires affordable housing to be located in close proximity to primary health care services and modes of active transportation to access other amenities such as groceries.

No change - addressed under the Food Systems and Neighbourhood Place Type chapters

City Building Policies - Homelessness Prevention and Housing

596 Whole Chapter We are concerned that there is no recognition of the variety of forms of housing that local families demand. Requiring 60% of new housing in a Secondary Plan to be other than single family homes will successfully drive families to outlying municipalities. If you canʼt have your dream of home ownership with a yard for a growing family within London, then it can easily be found at the end of a short commute in Komoka, Ilderton, Mount Brydges, Strathroy etc.

Modified - revised to 40%


596 Whole Chapter Does the City comply with that directive now? Does the LP comply with that Policy? We will hold comments until a response is received.

No change - targets consistent with current plan


601 _7 Item 601_7. refers to a choice of housing types, it would also be helpful to note a choice of housing locations. At times social housing has been very much clustered in areas and the Plan should include goals of allowing those needing housing supports to be dispersed throughout the community. “Scattered” is mentioned in 629_.

Modified - revised to add reference to location in the Policy


602 _1 (eg) There is inconsistency through the Plan of referring to a Housing Strategy and a Housing and Homelessness Strategy, it should be the latter throughout



609 to 628 Specific exemptions to planning requirements such as height and density should be included. To address the limitations and historical impacts of existing land uses.

No change - affordable housing permitted as part of bonusing


611 Will all communities / neighbourhoods be required to include all of the listed housing types? What is the difference between a “community” and a “neighbourhood” as referenced throughout the London Plan?

Modified - terminology changed to neighbourhood


620 City will assist in administration of senior government programs…. Suggest it read: The City may assist in administration of housing programs of the federal and provincial governments



621 623, 624 The targets in 621_, 623_, and 624_ are a bit confusing when combined together. A graph or chart outlining the goals and where they overlap would be helpful.



621 This Policy references “low and moderate income households” as defined in this Plan and the PPS, however there is no definition in the Official Plan for low and moderate income households. The City should add a definition in the definition section, consistent with the definition in the PPS, 2014. The term “low and moderate income households” is used in several locations in the OP.

Modified -revised to clarify as defined by the PPS, and added to Glossary


622 This is confusing! This appears contrary to the Altus report, which identifies that 53% of future development will be in the form of single-detached dwellings. This Policy is overly prescriptive with respect to housing forms required within secondary planning areas. How does the City plan to implement this Policy?

Modified - amended policy to make splits more achievable and identify options such as secondary units that may help acheive goal in a different way


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622 States that secondary plan and larger residential development proposals will be “required to include a 25% affordable housing component through a mix of housing types and sizes. In keeping with this target, 60% of new housing units within a secondary plan, will be in forms other than single detached dwellings....” This Policy does not reflect the housing mix projections established by Altus, as they determined that over 50% of new housing demand will be for single/semi-detached dwellings. Since these forms cannot generally be accommodated within the infill areas of the City, the proportion of single detached dwellings in new secondary plan areas that are outside of the built-area boundary will need to be larger therefore a requirement for 60% to be non-single is unacceptable. Remove or reduce Policy requiring 60% of new housing in secondary plans to be non-single family.

Modified - amended policy to make splits more reasonable and identify options such as secondary units that may help acheive goal in a different way


622 Target of 40% affordable housing will be difficult to achieve. Modified - amended policy to make splits more achievable and identify options such as secondary units that may help acheive goal in a different way


622 Future secondary plans and subdivisions will need ensure that 60% of units be non-LDR (40% for subdivisions less than 4 ha outside of a secondary plan). These splits encourage more affordable housing types and ensure that the shift to a “neighbourhood” place type for both LDR and MDR does not mean that only LDR units will be constructed. However, since 40% of future residential growth must occur in the Built Area Boundary, there will be reduced HDR development on greenfield lands. In analysing recent subdivisions for LDR/MDR split, is 40% to 60% non-LDR a minor change or a significant departure from recent development proposals? This Policy has implications for DC Study growth allocations and infrastructure needs modelling for master plans (i.e., what should future assumptions be for the build-out of vacant lands?) SUGGESTION: Future secondary plans and subdivisions will need ensure that 60% of units be non-LDR (40% for subdivisions less than 4 ha outside of a secondary plan). These splits encourage more affordable housing types and ensure that the shift to a “neighbourhood” place type for both LDR and MDR does not mean that only LDR units will be constructed. However, since 40% of future residential growth must occur in the Built Area Boundary, there will be reduced HDR development on greenfield lands. In analysing recent subdivisions for LDR/MDR split, is 40% to 60% non-LDR a minor change or a significant departure from recent development proposals? This Policy has implications for DC Study growth allocations and infrastructure needs modelling for master plans (i.e., what should future assumptions be for the build-out of vacant lands?)

Modified - amended policy to make splits more achievable and identify options such as secondary units that may help acheive goal in a different way


623 It is not clear if this Policy is directed at the rental housing market, the ownership market, or both, and it should be clarified if it is intended to apply to both.



623 Policy states "Further to Policy No. 2 above…". Asks what #2 is being referred to? Modified - revised to address comment


624 Similar to other policies in the Homelessness Prevention and Housing section of the OP, the intent of this Policy is sound, however, there is uncertainty how the City intends to implement the Policy. The Policy requires that either the developer/proponent, or perhaps the City conduct income-testing, and screening of potential tenants to ensure their current accommodation costs exceed 50% of their gross household income. This should be clarified.

No change - will not be testing incomes as part of OP monitoring process. Addressed through housing programs.


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624 How is this Policy to be implemented? Is this for City-owned housing, or privately developed housing?

No change - this Policy is intended for both Housing Corporations and privately developed housing


627 States that “green development techniques will be utilized....” There is no definition of green development techniques, and Policy is too prescriptive. revised Policy to state “Green development construction and technologies are encouraged in the construction....”

Modified - green development is clarified under the Green and Healthy City chapter, as revised.Changed "Will" to "Should"

City Building Policies - Cultural Heritage

630 Whole Chapter Add to cultural heritage chapter: " Education & Engagement: Schools, tours, signage, plaques, awards, grants & incentives, neighbourhood involvement, celebrations, websites, books, archive digs, education about regulations."

No change - education not added


630 Whole Chapter Somewhere in the Cultural Heritage Section there needs to be a description/policy/criteria for evaluating the balance between protection and development on any proposal.

Modified - policies revised to ensure balance and comply with PPS and OHA


630 Whole Chapter Need to have a vision for restoring /building new buildings that look like heritage buildings - we should do more than just saving existing heritage buildings.

Modified - increased descussion regarding "fit" of new development


630 Whole Chapter Create a vision for downtown that doesn't necessarily need to mimic what is there now. No change - achieved by downtown master plan


630 Whole Chapter Need to capture a feeling of heritage - capture in our new neighbourhoods, that creates a theme or represents a history of London or Ontario (like a story book).



630 Whole Chapter Isn't a little late to take the save-our built heritage approach? We should restor, rebuild and replace. Think of Old Quebec. It is filled with faux heritage buildings. London has an excellent example: The Bowles Building. Another approach is that of Williamsburg in the States.

No change - plan supports a balanced approach consistent with the PPS and OHA


630 Whole Chapter Concern with intensification affecting Heritage Conservation areas. No change - sensitive development can work within HCD's

City Building Policies - Culturally Rich and Diverse City & Cultural Heritage

630 Whole Chapters Combine two chapters as one, label as culturally rich and diverse city using policies 630 & 631 No change - chapter structures updated to improve clarity. Two chapters remain


630 Policy 630 add the word artifacts after books… whether it's the furnishings in a living museum like Eldon House, Temp VII, weapons in the RCR Museum, a pioneer dair, bone dominoes from the Fugitive Slave Chapel site or projectile points excavated at the Lawson site, artifacts are tangible heritage elements that help tell the story and enahnce our understanding of our past.

Modified - added artifacts


632 Policy 632 In consultation with First Nations Grou, replace the words " how our region was first used by indigenous people, and how our city evolved over time" with "Human occupation of our city". Current wording suggests indigenous people are no longer involved in our city.

Modified - added "…how our city has been modified by human activity and continues to evolve."


637 Policy 637 remove the words "from time to time" and replace with "as necessary". Current wording is to vague.

Modified -revised to address comment


639 Policy 639 recommend using semi-colons or numbering 1-4 the places where a view or vista may be identified. Current paragraph is difficult to read

No change


639 Can the City require the protection of a view that is not designated? Will there be guidance on how to conserve? What extent of conservation is required?

No change


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Cultural Heritage

639 Uncertain why this section is included in cultural heritage Modifed - where a view or vista is identified as a heritage attribute of a property "included on the Register or identified in The London Plan, such view or vista will be conserved. A guideline document for the conservation of the view or vista may be prepared

City Building Policies -Culturally Rich and Diverse City

643 Needs clause on corporate asset management. Modified - 641 to include the term "assets"


644 Policy 644 London Advisory Committee on Heritage (LACH) is supportive of this Policy but questions the intent of what it is trying to achieve. How is the City intending to implement such protection?



644 Coordinate Policy with emergency management plan. Include protocols for archaeological discoveries. LACH is supportive of the Policy but questions what it is trying to achieve. How will such protection be implemented.

Modified - to clarify


645 Policy 645 delete the portion of the Policy starting with "by addressing…" London Advisory Committee on Heritage (LACH) questions the necessity of including the specific means by which to address impacts. Alternatively, change the section to say "by completing a Heritage Impact Assessment"



645 Suggest that this Policy confirms that new development and redevelopment on and adjacent to heritage designated properties and properties listed on the Register will be designed to protect the heritage attributes while meeting the urban design guidelines.

No change


645 Policy 645: regarding scale: no building should be higher than 10 storeys. No change


645 Of particular interest maybe the topic of CH Design – page 170 - Policy #645 – for the example of the Old Middlesex County Court House and the proposal by Middlesex County to construct a 30 storey building on the existing Middlesex Health Unit Building. Does this Policy conflict with images prepared by City Staff on the redevelopment of the same area?

No change


645 Add "The scope of the Heritage Impact Assessment is determined in consultation with the City and must include information relevant to the circumstances, including alternative development approaches and mitigation measures to address any impact to the cultural heritage resource and its heritage attributes. The City may require that a Heritage Impact Assessment be prepared by a qualified person to the satisfaction of the City."



646 States that “where important buildings or landscapes have been removed, the retention of architectural features that allude to....will be encouraged.” How are architectural features to be retained if they have already been removed? Is this meant to refer to retaining / reusing architectural elements of buildings or landscapes that are going to be removed? Provide clearer wording as to intent of Policy.

Modified - to identify significant elements for retention in advance of removal


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646 Add the following policies following 646: New Policy_ Relocation of cultural heritage resources is discouraged; all options for on-site retention must be exhausted before restoring to relocation.New Policy_ In the event that demolition, salvage, dismantling, relocation or irrevocable damage to a cultural heritage resource is found necessary, as determined by Council, archival documentation may be required to be undertaken by the proponent and made available for archival purposes.Archival documentation should be prepared by a qualified person and should include: architectural measured drawings, property history, and photographs, maps, and other archival material about the cultural heritage resource and its surrounding context.

Modified to add policies. Did not add details that are operational in nature


648 Add new Policy following 648 - _ Recognizing that some cultural heritage resources are not confined by geographical or political jurisdictions, the City will cooperate with neighbouring municipalities, other levels of government, conservation authorities, and the private sector to protect and conserve cultural heritage resources.

Modified - added new policy per comment


650 #4 should be a new Policy Modified per comment


653 PPS 2014 has updated the definition of cultural heritage landscapes:Cultural heritage landscape: means a defined geographical area that may have been modified by human activity and is identified as having cultural heritage value or interest by a community, including an Aboriginal community. The area may involve features such as structures, spaces, archaeological sites or natural elements that are valued together for their interrelationship, meaning or association. Examples may include, but are not limited to, heritage conservation districts designated under the Ontario Heritage Act; villages, parks, gardens, battlefields, mainstreets and neighbourhoods, cemeteries, trailways, viewsheds, natural areas and industrial complexes of heritage significance; and areas recognized by federal or international designation authorities (e.g. a National Historic Site or District designation, or a UNESCO World Heritage Site). RECOMMENDATION: MTCS recommends updating the definition of cultural heritage landscape for consistency with PPS 2014.

Modified - revised to incorporate correct definition, consistent with PPS


653 Revise section to state "In accordance with the Provincial Policy Statement, Council may identify areas of the city which may compose Cultural Heritage Landscapes. A Cultural Heritage Landscape is a defined geographical area that may have been modified by human activities and is identified as having cultural heritage value or interest by a community, including an Aboriginal community. The area may involve features such as structures, spaces, archaeological sites, or natural elements that are valued together for their interrelationship, meaning, or association. Such a cultural heritage landscape is valued by Londoners and is of significance to an understanding of the histories or a people or place."

Modified - revised to incorporate PPS definition


654 Use of term cultural heritage landscape is confusing Modified to refer to guidelines


655 Policy 655 revised subsection a) under point 2 - geographic area as follows "Area contains natural features of functions that make a significant contribution to its heritage character". Current wording is intended to address natural characterisitic of area, but isn't clear.

Modified to refer to guidelines


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655 It is unclear how the criteria will be applied, and if a property needs to meet one, or more, criteria in order to be identified as a cultural heritage landscape.It is unclear what the “Guideline for Identification for (sic) Cultural Heritage Landscape” refers to. Is this the document referenced in Policy 676? RECOMMENDATION: MTCS recommends these references are clarified.

No change - guideline will be prepared


655 Should the criteria for the evaluation of a CHL be included in the OP or a guideline document? Modified to refer to guidelines


656 Update Policy and add three new policies as folows: In cooperation with the Provincial government, the City will identify and designate archaeological resources in accordance with the Ontario Heritage Act.New Policy_ The City shall adhere to the provisions of the Funeral, Burial and Cremation Services Act as it pertains to archaeological resources.New Policy_ Archaeological resources may be included on the City’s Register. Data relating to these resources will be kept for the purpose of heritage planning and development review. Locations of archaeological resources will be kept confidential to protect against vandalism, disturbance, and the inappropriate removal of resources.New Policy_ In the event that human remains or cemeteries are identified or encountered during assessment, development or site alteration, all work must immediately cease and the site must be secured. The appropriate provincial and municipal authorities must be notified. Required provisions under the Funeral, Burial and Cremation Services Act, the Ontario Heritage Act, along with other applicable protocol or Policy must be followed. Where there are First Nation burials, they will be addressed in consultation with relevant First Nations communities. Licensed archaeologists may be required to assess and/or monitor the property and recommend conservation strategies.

Modified - new policies added


657 “Heritage zone” introduces a new term to the OP, which is undefined in the OP and elsewhere in provincial Policy. RECOMMENDATION: MTCS recommends defining this term or use another established tool for conservation.

Modified - revised to clarify that this is a zoning by-law reference.


660 , 669, 679 & 683 Policy 660, 669, 679, 683 - These policies addresses the need for a Heritage Impact Assessment where site alteration or demolition is proposed on lands adjacent to the City's cultural heritage resources. Nowhere in the plan Is the eeed for a HIA discussed on protected lands or lands identified in the register. LACH suggests wording similar to that found in Policy 645 (on and adjacent)

Modified - revised to use PPS language


660 This Policy is consistent with PPS 2005, but the new PPS 2014 s.2.6.3 has updated language:2.6.3 Planning authorities shall not permit development and site alteration on adjacent lands to protected heritage property except where the proposed development and site alteration has been evaluated and it has been demonstrated that the heritage attributes of the protected heritage property will be conserved. This is stronger Policy on development of adjacent lands and removes the reference to mitigative measures. RECOMMENDATION: This Policy should be updated for consistency with PPS 2014 s 2.6.3



661 to 663 Remove policies Modified per comment


663 & 672 Policy 663, 672 - Add the words to the end of the paragraph "and may require that notification be posted on the property where a permit has been received". LACH has previously requested of the City that this be made a requirement for permit holders

No change


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665 &674 Policy 665, 674 add the words to the end of the paragraph"; and the salvage of materials exhibiting heriatge value for the purpose of reuse." LACH frequently recommends such wording on tis recommendation to council and believes that it contributes to the concepts of sustainability. In addition, LACH request calrification from the City regarding what becomes of the documentation of lost heritage resouces?



665 The city can only encourage salvage if it has storage capacity . Clarification requested by LACH for what becomes of documentation of past heritage resources

Modified per comment


666 This Policy should identify that new development is not discouraged. Need language to direct how new development will be reviewed in heritage areas?

Modified 667(4) and included in 668


668 Policy 668 that subsection 1 be amended by adding the following words at the end of the paragraph "that contribute to the character of the district". LACH believes that there are examples of structures within all the of the HBD's that are out of character wit the broader district and could be removed and replaced by new structures which better contribute to the district. Subsection 2 in turn be amended by adding the word "redevelopment" after the word "infilling"



668 This statement should be updated to ensure consistency with 2.6.3 of the PPS and elsewhere in this OP. RECOMMENDATION: MTCS recommends substituting “heritage attributes” where it says “characteristics”. Additionally, where it says: “Development on land adjacent to designated Heritage Conservation Districts shall be encouraged to be sensitive…” MTCS suggests using language that is consistent with s. 2.6.3 of the PPS.



668 The Heritage Conservation Districts policies #668 establish strong framework to retain existing character of buildings and streets. Many communities see these policies as the best way to reduce the amount of change happening in the Neighbourhood Place Type and where these areas are location along Rapid Transit Corridors. The assembly of land and redevelopment of these corridors will be disruptive to the heritage conservation districts. Policies should be added to address this conflict if the Plan objectives are to be obtained.

No change - plan includes goals and objectives that may conflict. 1st chapter of plan explains this and indicates must be wieghed and balanced.


668 Remove last point Modified - revised to address comment


669 Similar to comments on Policy 660, this Policy is consistent with PPS 2005, but the new PPS 2014 s.2.6.3 has updated language:2.6.3 Planning authorities shall not permit development and site alteration on adjacent lands to protected heritage property except where the proposed development and site alteration has been evaluated and it has been demonstrated that the heritage attributes of the protected heritage property will be conserved.This is stronger Policy on development of adjacent lands and removes the reference to mitigative measures. RECOMMENDATION: This Policy should be updated for consistency with PPS 2014 s 2.6.3



669 Move Policy to after 673 Modified per comment


670 Policy 670 Add "Part V" before the words "of the Ontario Heritage Act for clarity Modified - revised to address comment


670 Move poliy down to below 672 Modified per comment


675 & 680 Policy 675, 680 LACH recommends removing the map and specific references to identified HCD's and ChL's as they will evolve over time. Recommend referencing resource where items may be found (Register, CityMap, etc)

No change


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675 LACH recommends that downtown be removed from HCDs No change - Downtown HCD approved by Council


675 Policy 675: add Wortley Village and Blackfriars to list of HCDs. No change - no final approval of HCD


678 Add new Policy after 678 New Policy__ An application may be made by a property owner to alter a property within a Cultural Heritage Landscape. The City may consent to or grant a permit to alter the property through the Heritage Alteration Permit process. In consultation with the LACH, the municipality may delegate approvals for such permits to an authority.



680 Identify CHLs on a map Modified - revised to address comment


681 to 686 Underwater cultural heritage is increasing in importance, both as a source of education and a source of economic development. RECOMMENDATION: MTCS recommends adding a statement that acknowledges the importance of this segment of archaeological resources and offers the following sample wording:“The City may require a marine archaeological assessment to be conducted by a licensed marine archaeologist pursuant to the Ontario Heritage Act if partially or fully submerged marine features such as ships, boats, vessels, artifacts from the contents of boats, old piers, docks, wharfs, fords, fishing traps, dwellings, aircraft and other items of cultural heritage value are identified and impacted by shoreline and waterfront developments.”



681 Policy 681 LACH seeks clarification from the City as to how this Policy will be implemented. Is the City intending to implement measures to facilitate preservatiion of archaeological sites and materials beyond what is required of by landowners and licensed archaeologists?

No change


682 & 1437 PPS 2014 and other provincial documents now widely use the term Archaeological Management Plan instead of Archaeological Master Plan RECOMMENDATION: MTCS recommends that, in updating the Archaeological Master Plan, the phrase “Archaeological Management Plan” be used in the future.



682 Policy 682 that the word 'update' be inserted following the word 'prepare'. LACH is concerned that the wording is too vague and that the current AMP has not been updated in over 18 years, despite the recommendation within the AMP itself that it be updated on a 5 year basis

No change - maintain has the same meaning as update


683 PPS 2014 section 2.6.2 contains updated language regarding conservation of archaeological resources. RECOMMENDATION: This Policy should be updated for consistency with PPS 2014 s 2.6.2.



683 Update Policy to state "Development and site alteration shall not be permitted on lands containing archaeological resources or areas of archaeological potential unless significant archaeological resources have been conserved to the satisfaction of Council"

Modified per PPS (2014)


685 New Policy New Policy_ All archaeological assessments shall be approved by the Province and a copy of the assessment report shall be provide to the City for comment to ensure that the scope is adequate and consistent with the conservation objectives of the City.

Modified per comment - new policy


686 Policy 686 - LACH recommends that a new Policy be added similar to this Policy, or that this Policy be expanded, recognizing the importance of consultation with other stakeholder groups (cultural, ethnic, religious) that may arise on a site-specific basis.

Modified - based on PPS wording


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686 This Policy raises questions about “When is it appropriate?” Has a protocol been established? And, if so, there should be some indication of what that protocol is. RECOMMENDATION: The effectiveness of this Policy is in question. The following wording is suggested,“The appropriate First Nations communities shall be provided notification in regard to the identification of burial sites and significant archaeological resources relating to the activities of their ancestors. If the City of London initiates the preparation of an Archaeological Management Plan, the appropriate First Nations communities shall be notified and invited to participate in the process.”

Modified - revised to use recommended language


686 Add new similar Policy or expand this one to include that "authorities shall consider the interests of Aboriginal communities in conserving cultural heritage and archaeological resources"

Modified nased on PPS wording

City Building Policies - Culturally Rich and Diverse City

687 _1 Change to "Strengthens culture to build economic prosperity" growth and entrepreneurship. Modified per comment


687 _5 Change to "Leverages London’s cultural resources, assets and public spaces". Modified per suggested wording change


687 Section title Title includes “Built, Cultural and Natural Heritage...” None of the following paragraphs have any reference to natural heritage, and it is not relevant to those policies. revised Section title to “Protect and Enhance Our Community’s Built and Cultural Heritage to Allow.....”



687 Whole Chapter How can we get a concert hall in the downtown to support a culturally rich and diverse city? No change - included in downtown plan


687 Whole Chapter Looks good in many ways, but what about a Performing Arts Centre and a Green Belt. No change - a performing arts centre is proposed in downtown plan. Timing is a question for Council to consider and determine subject to budget deliberations and other priorties. Urban growth boundary and rural london policies achieve the objectives of a greenbelt


688 & 689 Add: “Advance opportunities of attraction and retention of newcomers”.1. Strengthens culture to build economic growth and entrepreneurship (and attract newcomers)5. Leverages cultural assets. These assets include newcomers.

Modified - added to Section 687


691 _1 Change to "Create economic opportunity by Eelevate London’s profile as a regional cultural centre."



691 _2 Change to "Build upon our cultural strengths to attract and retain the best and brightest citizens labour force."



691 _3 Change to "Support cultural programming to create a city that exudes fosters innovation, vibrancy, creativity, and entrepreneurialism."



691 _5 Change to "Build awareness through celebration and promotion of London’s vast array of cultural programming, assets, resources and quality places"

No change


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Culturally Rich and Diverse City

691 _6 Change to "Plan for, enhance, conserve and maintain and enhance our cultural assets, resources and public spaces"



692 Change subtitle above 692 to state "Create Economic Opportunity by Elevate London’s Profile as a Regional Cultural Centre "



697 to 699 Remove policies and preceding subtitle. Modified - removed 679-699


698 & 731 Why "downtown" as location for these? UWO and Fanshawe take enough outside money and are doing it as part of what they do (hundreds of millions of research dollars from med school alone). The City doesn't have to do everything. Or is this an admission that the "entertainment district 'plan' " for downtown didn't work and we are trying to catch the next passing wave?

Modified - removed 698


700 Under subtitle preceding Policy 700 - "Strengthen civic engagement and appreciation of culture through consultation and ongoing education."

Modified - policy added


701 Change to "Develop incentive programs to facilitate cultural activities that will generate activity, excitement, profile, and vibrancy for the residents of and visitors to our city."



701 Is it the place of the Official Plan to develop incentive programs for cultural activities? Not sure this Policy is necessary / relevant to Official Plan.

Modified to "consider"


702 Change to "Protect the natural heritage environment and develop programming along the Thames to allow the green space amenities to exist for people to improve their physical health, mental well-being, and intellectual development"

Modified per commment


702 Policy refers to natural heritage environment and green space amenities. Not sure how this is relevant to cultural diversity and richness. Unnecessary Policy in this section.

Modified - see change to 701 above

City Building Policies -Culturally Rich and Diverse City

704 Under 'plan for, maintain, and enhance our cultural assets and public spaces": Add corporate asset management clause.



705 Remove Policy, covered in 713 Modified - policy deleted


706 Change to "Design and maintain public spaces and assets that showcase the public art program, creative spaces and gateway signage, and enhancements to cultural heritage resources." add Policy stating "Include the provision of cultural way-finding and gateway signage in the City of London Sign and Canopy by-law."



709 Change to "Allow Enable adaptive reuse of older industrial buildings to create spaces for new uses that support the development of the knowledge economy and creative people class."

Modified to "Encourage"


709 Policy refers to “knowledge economy and creative people class”. These are ‘buzz words’ and are too restrictive. Adaptive reuse can and should be available to / targeted more broadly. revised Policy to “allow adaptive reuse of older industrial buildings to create spaces for new uses that support culture and innovation.”

Modified per comment, wording changed to "encourage"


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Culturally Rich and Diverse City

710 Change to "Promote the joint use of facilities and community infrastructure, and facilitate collaboration across our communities. , to support centres for social innovation and enterprise. "



711 Change to "Develop incentive programs and bonusing opportunities for the public art program and creative innovative design, including “green” systems and “future ready” technologies, that serves as a community benefit, in conformity with the Our Tools policies of this Plan.



712 Change to "Identify prominent sections of the city and Develop concept plans for gateway signage features, cultural corridor enhancements, and public spaces for incorporating public art and creative design features including areas such as Downtown, Old East Village, SoHo, Transit Villages, Rapid Transit Corridor and Main Streets".



712 Who is responsible for developing concept plans for gateway features, etc. and when? Provide clarity regarding responsibility and when (i.e. – is this part of development application process)?

No change - policy direction is clear, can be implemented in many ways.


714 Remove Policy Modified - policy deleted


716 Who is responsible for developing and maintaining cultural asset mapping databases and when? Provide clarity regarding responsibility, intent.

No change


717 to 720 Remove policies and preceding subtitle. Modified - policies deleted


719 Does this Policy even belong in an Official Plan? And use of word "understanding" means Policy needs to explain an understanding of what and by whom?



720 Suggests new Policy 721: funding for community initiated projects such as food forests, gazebos, community compost facilities.

No change - not an Official Plan type policy

City Building Policies - Smart City

721 Whole Chapter Suggests changing "Smart City" section title to "Sustainable and Resilient Cities". No change - this is an industry-accepted title


721 Whole Chapter Need to include infrastructure for high speed internet access along with other services such as water and sanitary. Providing fibre optic connectivity would boost business

No changed - issue addressed in chapter


721 Whole Chapter Comment – some points are too general such as 730 which might be more of a “what are we trying to achieve” point above, others such as 724 Wi-Fi are very specific and should be left in the “How section”

Modified - changed statement on wifi, most parts of chapter are general


721 Whole Chapter Availability of data systems within the City: Having good technology systems at the city is more than providing tools for staff. In Housing and Social Services, we are very supportive of implementing advanced technology and a data tool but that is only one subset.

Modified - policies added regarding analytics tools


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Smart City

721 Whole Chapter Need better mapping of public access points to wifi and public computers or other devises are available or where support to access is available. This should almost become part of the Help Yourself Through Hard Times (information regarding Basic needs and services for London and Middlesex County). As more information and service is digital, the more we should have public info on where and how you can connect. Access to wifi is also a great equalizer between cultures and income populations. Eg. Ensuring there are free wifi zones with access points in key neighbourhoods and city facilities (like OW in the Community is doing).

No change - wifi mapping not available


721 Whole Chapter Needs to include mention of Intelligent Region (regional approach) that London is participating in through SWEA.

Modified - policy exists, revised to include word "intelligent"


721 Whole Chapter Is it worth creating a shared data store which includes not just City of London data? Modified - revised to address comment, policy added


721 In addition to new forms of information and communications a key element of smart cities is the employment of more advanced analytics and the subsequent improvement on problem solving and decision making



721 This analytics based enhanced decision making is the key link to better service delivery and cost avoidance



722 Policy 722:suggests that after climate change add "resource depletion, ecological degradation…"

No change - current policy consistent with intent


722 Add culturally after socially …. Sustainable city building initiatives. Global issues could include preservation of heritage and vibrancy of our community,



722 In addition to ICT infrastructure, business intelligence software will play an integral analytics role by providing the platform and tools through which enhanced decision making will be based



722 Technology becomes an input in the form of infrastructure and software, but also is an output in the form of opportunities for greater integration and improved understanding



722 This realization will be predicated on the analysis of the interplay among systems, identification of new relationships, use of this information to support better management, and the ultimate redesign of some service delivery elements



722 The concept of service interconnectedness and the opportunities to realize previously unseen relationships among service areas is fundamental to why a smart city undertaking is of importance

Modified - revised to address comment, policy added


723 _1 Statement is very broad and ambiguous – what does ‘connected’ mean? Physical, technological? As a Policy, it is impossible to implement. revised statement for greater clarity.

No change - Smart City implies technology connected

City Building Policies - smart City

723 _11 Build digitally connected region for southwestern Ontario (as a way to promote economic development and to be competitive)



723 _13 Consider rewording Policy to: Coordination of ICT infrastructure and software with business projects and undertakings



723 _4 Policy 723.4: suggests adding "cultural and natural heritage" at the end of this subsection. No change - not appropriate in this chapter


723 _4 Share real-time data on the operation and condition of city infrastructure and services would involve a significant investment in sensors and likely modeling software (Business Intelligence Tool)



723 _4 & 723_5 Share real time data related to infrastructure and mobile apps really belong in the “How Section” Are we trying to achieve the development of more applications?

No change - policy is a general statement about what we want to achieve. See "how to" section for information on delivery


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723 _5 Would it be wise to expand this beyond mobility? Share real time data to support analytics, inference and presentation options in a variety of formats suitable to mobile and other platforms.



723 _7 Develop digitally enabled transit (comment …. need to coordinate bus operation timing with printed schedules – other cities have routing apps so riders can see where the buses are on their routes)

No change - comment too detailed for official plan policy. There is a general policy to share real-time information


723 _7 Would it be wise to expand this to - digitally enabled services, such as transit, etc. ? Modified - revised to address comment, policy added


723 _9 Create mechanisms that engage citizens to provide immediate feedback (stop there in sentence as the rest is too specific)

No change - provides context for why feedback is sought


723 Add Facilitate access to by the community to more information about the quality of life and vibrancy of London for attraction and retention of citizens

No change - issue addressed in 723_1-3. Retention and attraction is addressed in economic policies.


723 Add – Develop flexibility for the creation of live work creative spaces and home offices No change - not related to Smart City chapter


723 Add consider a variety of alternative formats to meet the needs of all citizens – related to accessibility

No change - not related to Smart City chapter


723 Ensure information security is appropriately addressed and managed in all relevant smart cities actions



723 Reduce cost of service delivery through more efficient and effective work actions guided by better analytics and management decisions



723 Better alignment and integration of Business Strategy, Economic Strategy, Social Policy (etc) and Information Technology



723 Improve services through access to enhanced and more representative service delivery performance data



723 Support the creation of a technological environment conducive to investment and economic development


City Building Policies - Smart Cities

724 Does/should the municipality be provisioning this? We have had many discussions about this and there seems to be a fair bit of resistance and there is a cost.



724 Can the installation of Wi-Fi access points be required by the City? No change - as part of development, collaborative efforts can be made, where appropriate, to install technology for public use.


724 States that public Wi-Fi access “will be integrated into new developments and/or retrofits in the Downtown and Transit Village Place Types...” Who will be responsible for this? What are the costs? It is not reasonable for property owners / builders to be required to integrate public Wi-Fi access into private buildings. Policy should be clarified regarding responsibility or removed.

No change - to be addressed in the Smart City Strategy


724 Free public wifi is an often identified concept and with it comes questions if such an undertaking is in the mandate of the municipality and where such connectivity should be offered. Currently the City of London is already dabbling in this space (e.g. LondonLawn and COL Public domains). A broader Policy or position on the topic could be an additional deliverable beyond just the rapid transit scope.


City Building Policies - Smart Cities

725 & 733 This document has a long shelf-life - should be be using a specific infrastructure type when it may be obsolete? Could these be incorporated as one Policy? Apply a general Policy similar to the approach taken in Policy 734.

Modified - references to technology removed


725 As this a 20 year plan would it be more suitable in this recommendation and others to avoid the mention of specific technology and a generalized term such as “Industry Standard”.



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726 Transmission towers and satellite infrastructure is not relevant to all development projects. revised Policy to state that “Transmission towers...related to development projects, where necessary.”

No change - if a tower were not appropriate or not part of an application, this policy would not apply


726 Further understanding is needed on what is meant by transmission towers and satellite infrastructure

No change - defined by Industry Canada


730 to 732 & 739 In addition to access to information, it may be wise to also provide access to analytics and inferences. It is believed that the next generation of data users will not only expect the data, but also expect user friendly built in analytics tools and presentation opportunities (Build a Budget).



730 Policy states “Provide state of the art communication capabilities...”. Who is responsible? When? How? What is the cost? Policy is too broad – more of a strategy than a Policy. Needs to be clarified, revisedd or relocated in document

No change - will be defined in Smart City Strategy

City building Policies - Smart City

731 Add corporate asset management clause. Modified - revised to address comment, policy added


733 As opposed to copper and fibre – maybe infrastructure associated with industry best practices, something along those lines



735 Expand this beyond vendors to include education and research institutions. An example, Western is currently investigating a next generation green data centre



736 Add - 736 general training (e.g. videos etc.) is also required for the public and staff Modified - revised to address comment, policy added


736 Clarify who will interpret all of these data and inferences in the context of the related public service delivery if not those individuals.



736 It is addressed to some degree in 736; however, ITS believes the potential skills gaps transcend beyond training for ICT staff. This is of course important and a great deal of benefit can be realized, but why not expand the scope?



736 The training program should not end with bureaucrats – how can citizens be engaged in a similar manner? How can be promote creation, not merely consumption in this environment?



736 This realization of a Smart City is ultimately based on decision makers having the skills and comfort to analyze the data they receive back from the technology. A training program of this nature is essential to the Smart Cities undertaking



739 Policy 739: suggests making mapping systems available for citizens where they can map areas of concern (e.g. unhealthy conditions), but also things like fruit trees, farmers markets, or whatever else they want to map but having relevant to categories listed in the Plan.

No change - addressed in policies 723_1, 2, 3, 4, 5 & 739

City Building Policies - Food Systems

740 to 784 A strong food system is an important component of a healthy, vibrant city. MLHU commends the City of London for including this section in TLP.


City Building Policies - Food systems

740 Whole Chapter In Food Systems or Green City: Declare London as a pollinator sanctuary - support people to grow flowers, vegetables and flowering trees and bushes. The city should also plant flowering vegetation in its many spaces - parks and properties along the river and other areas where pollinators may find pollen and nectar.

Modified - added pollinator references in Urban Forest, Parks and Recreation, and Food Systems chapters


744 Policy 744: change last line "access to food" to "healthy access to food" Modified - revised to include "healthy food"


745 Policy 745: suggests change to end of Policy, from "city and region" to "city and bioregion" No change - policy is consistent with wording of plan


746 Policy 746: suggests change from "local and international food…" to "local, regional, national and international…"



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Food Systems

748 Policy 748: Suggest change from "high-quality retail grocery" to "high quality corner retail grocery"

No change - retail groceries are not necessarily at corner locations.


749 Policy 749: suggest change from "grow and sell food" to "grow, process and sell food" Modified - revised to address comment


753 _5 Policy 753.5: suggests changing "household and city-wide level" to "household, neighbourhood and city-wide level…"



753 _5 Notes that City no longer has provincial subsidy for distribution of household composters, so City has stopped supporting composting, despite this Policy.

No change - policy is consistent with plan


753 Policy 753: suggests new subsection stating "encourage organic methods such as agroecological, agroforestry and permaculture approaches with no or minimal chemical or energy inputs".

No change - policies addressed elsewhere in the Plan.


753 Asks if this these are even matters for land use planning? No change - policies consistent with vision of plan


754 How neighbourhood is defined in Plan is different than how public defines their neighbourhood. Understands that the purpose is to avoid socio-economic caused "food deserts" but isn't sure if this is being addressed in new planning applications for new subdivisions, for example.

No change - Neighbourhoods have been clarified as part of the City Structure Plan. The purpose of the policy is to "encourage" opportunities for food sources in identified food desert areas.


756 Policy 756: suggest changes so reads "…uses in all areas of London but especially in areas that have been identified as food deserts" (allows for home production, processing and selling).

No change - comment is not consistent with intent of the Policy.


759 Suggest a new Policy after Policy 759: something like, "Promote all forms of livestock farming and animal husbandry within the Farmland Place Type. Keeping of livestock and pursuing animal husbandry activities is discouraged in all urban Place Types."

Modifed - revised to improve clarity


760 _3 Policy 760.3: at end add "...and community groups". No change -reference to "participants" is inclusive of all groups.


762 Policy 762: also add community food forests integrated in with the gardens. No change - the Community Garden Strategy will identify the different components


762 States that “at least one community garden per neighbourhood” is to be established. Whose responsibility? When? Does this refer to existing or new neighbourhoods or both? It may not be feasible / necessary in all neighbourhoods, especially primarily single family with yards. Provide more clarification to Policy.

No change - issue addressed in Our Tools, Policy 1324


767 Policy 767: in addition to school yards, why not add "higher education" places, "hospitals" and "places of worship". (gardens have healing powers as well).

Modified - revised to encourage all community partners to integrate community gardens, where appropriate.


768 Policy states that the local food infrastructure is to be strengthened with “well-developed and well-financed networks and operations....” Whose responsibility? This seems to be more of a strategy than an implementable Policy. Suggests Policy needs clarifying.

Modified - moved under the section - "What are We Trying to Achieve?"


770 Policy pertains to greenhouses and final sentence states “ The operation of a City of London community garden program will ensure the efficient and effective service processes, and meaningful community development and outreach.” This sentence does not make sense in context with the initial one. Suggest revised or remove.



770 Greenhouses in civic gardens – what about change to amenities that support community gardens (remove word civic gardens...)



771 Is supporting before school programs a role that the City is or should be involved in, from the standpoint of the Official Plan? Not sure this is a relevant or implementable OP Policy for the City.

No change - policy sets a goal that everyone in the city has access to food (refer to Policy 744), consistent with the City's Food Charter.


772 Asks if support for educational programs on healthy eating means "financially supported"? Asks why, and asks if this isn't the role of the health unit who already gets money for this?

No change - policy sets a goal that everyone in the city has access to food (refer to Policy 744), consistent with the City's Food Charter.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - Food Systems

775 Is it the role of the City to establish “alternative food provision” such as food cooperatives? Not sure this is a relevant or implementable OP Policy for the City.

Modified - deleted word "establish"


781 Policy 781: suggest adding "inside and outside UGB" at end of this Policy. No change - Farmlands in the city are located outside of the Urban Growth Boundary.


784 Asks why Policy 784 is in "Food Systems" section? Suggests changing from "manage strategies" to "create and implement strategies to manage…" or "manage pests, disease…" Also suggests clarifying that "disease" is "plant diseases", unless the Policy means things like Lyme Disease, West Nile, etc.


City Building Policies - The Green City

785 to 817 MLHU provided input for the Community Energy Action Plan which will have long term benefits for Londoners and will contribute to our collective goal of achieving a healthy and sustainable environment. Other initiatives, such as reducing air pollution and aiming for up to 70% waste diversion, will spearhead the City toward achieving a Green City status.



785 Whole Chapter Green City and Climate Change important to our future (eg. heat island effect etc.). Any challenges from the development industry regarding this important issue?

No change - chapters consistent with vision in plan


785 Whole Chapter Suggest changing "Green Jobs" section to "Sustainable Jobs" No change - part of "plain language" approach to plan


785 Whole Chapter Suggest changing chapter of "The Green City" to "Sustainable City" or "Ecological City". Suggests "green" has too many meanings.

No change - part of "plain language" approach to plan


785 Whole Chapter Add specific reference to District Energy. Modified - revised to address comment.


785 Policy 785: "sustainability" should be mentioned in this Policy. Suggests this section spells out goals of Policy 835.11.



786 to 787, 790-791 We strongly support Sec. 786, 787, 790 and 791, which provide some local context and a base framework for looking at environmental issues and sustainability in London (particularly with regards to climate change adaptation).



786 Policy 786: suggest changing "green economy" to "bioregional economy". (suggests because believes future will be in local and bioregional economies).

No change - not consistent with plain language approach


786 In addition to resilience also mention building a safe and secure city with regards to climate change and extreme weather. Perhaps move this into the City Design section.



787 Policy 787: suggests two changes: 1. changing "our global environment" to "our local, regional, and global environments"; and 2. adding ne ending to Policy stating "Our economy only exists because it is embedded in a viable biosphere. All of our resources come from it and wastes return to it. Humanity is an integral part of the biosphere but cannot exist without it."

Modified - section rewritten to improve clarity


788 Policy 788: suggests following additions: 1. change ending from "be smaller, per capita, than most cities in the country" to "in line within the biospheric sustainable ecological footprint limit of 2 global hectares"; 2. add sentence that "London will be energy self sufficient at bioregional level, heating most buildings with geothermal or solar systems, generating electricity using solar/wind/biogas/hydroelectric"; 3. adding that "London will cut CO2 by 80% over 1990 levels"; 4. "London will diver 100% of solid waste by focusing on reduction, reuse and recycling"; 5. "London will grow 50-70% of vegetables by 2035 and be 90% self sufficient at bioregional level"; 6. All our watersheds will improve ecosystem health, aquatic and terrestrial"; and 7. "90% of all trips will be made on foot, bicycle or public transport."

No change - some targets could be incorporated into monitoring reports, not for Official Plan policy


789 Policy 789: add new action #9: "Community-based Schools of Sustainability". No change - current policy acheives intent


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - The Green City

790 How many measures are there and are they consistent measures? Nice stuff, but why is this in an OP? Especially hard to compare if city establishes own standards (Policy 801).

No change - part of the strategic and visionary compontent of the Plan


791 & 794 & 799 Policies 791, 794, and 799 are especially commendable. No change - indicates support for the Plan.


792 & 795, 803, 805, & 810

ACE advises that The London Plan include: specific wording that refers to the LIC programs in the body of the plan. (Such wording can be amended to particular points that refer specifically to city sponsored incentives that encourage home energy efficiency improvements.)

No change - addressed in policies 805 & 808. LICs are one possible tool


797 to 810 Green City section refers to the preparation of a Green City Strategy, climate change adaptation strategy and a Community Energy Action Plan. There would likely be considerable overlap in these documents. Should consider amalgamating these various items into one consolidated plan to minimize the number of plans and reduce redundancy.

No change - may be considered, intent is to identify areas for study


799 Policy 799: If this approach is to be taken seriously, need targets for indicators. No change - may be considered in a future study


801 How do you compare apples and oranges (if city establishes own standards to compare against other cities)

No change - not a measure of success, but possible future requirement for development


802 The idea of “Future Readiness” (with regards to solar energy) expressed in Sec. 802 is excellent, and should be extended to other areas if possible. In the case of the Urban Forest, this idea could be related to species selection based on ice storm events, acknowledgement of shifting species ranges, etc.



805 “Financial tools will be explored to consider incenting improvements to the environmental performance of existing buildings through retrofits.” Such financial tools could make use of Local Improvement Charge (LIC) incentives to assist property owners to improve home energy efficiency and clean energy retrofits. (The bold type being the amendment)



810 “…overall strategy to implement more environmentally friendly and affordable energy usage and enhance local air quality. …..implement such things as energy conservation, energy efficiency and good design, passive solar, waste heat utilization…..” The overall plan could enhance affordability to building owners by offering LIC incentives to implement energy efficiency and clean energy retrofit programs. (The bold type being the amendment)

No change - addressed in changes to policy 805


810 We would recommend consideration be given to the idea of the Urban Forest serving as an “alternative energy system” in the Official Plan (by providing cooling through solar energy), as per the definition set out within the 2014 PPS (“A system that uses sources of energy or energy conversion processes to produce power, heat and/or cooling that significantly reduces the amount of harmful emissions to the environment (air, earth and water) when compared to conventional energy systems.”) In keeping with this idea, strategic tree planting to maximize cooling should be added to the list of activities which could potentially be incorporated as a part of a Community Energy Action Plan in Sec. 810



812 The City can encourage this but the Green Energy and Green Economy Act prevails. RECOMMENDATION: Needs to ensure consistency with the Green Energy and Green Economy Act.



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanCity Building Policies - The Green City

812 Policy 812: Clarification is needed to make clear that wind turbines must only be located in Farmland Place Type consistent with NHS, Cultural heritage and nat'l hazard policies. Commercial wind turbines and "small wind energy conversion systems", the City should include a Policy allowing for by-law designed to cause installer of turbine to post bonds to a City trust fund that is designed to cover cost of eventual dismantling and rehabilitation of wind farm site.

No change - addressed in Green Energy Act


813 Policy 813: Suggests deleting "large scale" before "redevelopments" and adding new ending: "…including retrofits of old neighbourhoods. Potential placement of these systems could be boulevards and multiple houses connected."



815 States that opportunities for ground-sourced thermal energy use “will be explored” for large-scale redevelopments. This is too prescriptive. revised wording to encourage, not require exploration of such opportunities.



818 _3 Urban Thoroughfare should add cycling to complement the pedestrian realm. No change - emphasis is on movement of traffic and freight


818 _3 Policy 818_3 Urban Thoroughfare should add cycling to complement the pedestrian realm No change - emphasis is on movement of traffic and freight


818 to 819 criteria for road width - how does one determine road class in new subdivisions No change - roads classified based on desired character


818 to 820 Incorrectly numbered paragraphs. The ranges of right-of-way widths, for each of the various street Para. 818 to classifications, are significantly larger than those within the existing Official Plan. What justification is provided for the identified range of widths? What about alternative standards (i.e., reduced ROW widths)?

Modified - ranges revised


818 The following are descriptions of street classifications for Major Streets.1. Freeway (Planned Street Right-of-Way: 90-100m)Goals and Function:• Priority for vehicles and freight Movement• Move large volumes of vehicular traffic• Provincially managed corridor - remove this bullet RECOMMENDATION: Remove the provincially managed corridor bullet as a new Provincial Highway Policy should be included to address these issues.



818 With regards to policies pertaining to road widenings, we would like assurances that any future road widenings along Oxford Street West would occur in an equitable manner between lands on the north and south sides of the street so that future redevelopment opportunities on the Minto properties are not constrained by disproportionate land takings. Based on our review of the road allowance limits set out in the City’s comprehensive Zoning By-law, we note that Oxford Street West is classified as an Arterial Street with an ultimate maximum road width of 20 metres, measured from centre line. The London Plan identifies Oxford Street as a Rapid Transit Corridor with an ultimate road allowance of 40 – 50 metres (Policy 818, pg. 75). As noted above, if additional road widenings are required, Minto wants to ensure that this will be undertaken on an equitable basis and that efforts will be made to limit excessive road widenings in order to maintain a pedestrian focused environment.

No change - comment too detailed for Official Plan policy, to be addressed in design standards and other documents


818 A maximum Right of Way (ROW) should be indicated not ranges. Ranges indicate that streets can have differing widths which from a design perspective limits the ability in the future to accommodate all modes of transportation and urban design requirements.



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819 (page 75) There is no distinction between the Neighbourhood Connector and Neighbourhood Street except for right of way width. Neighbourhood streets should not be intended to have medium-large volumes of transit or vehicle movements, particularly when Civic Boulevards are only intended for medium volumes of vehicular traffic. Provide some differentiation between Neighbourhood Connectors and Neighbourhood Streets, or have only one classification of minor streets. Proposed wording for Neighbourhood Streets “Move low-medium volumes of cycle, transit and vehicle movements”

Modified - revised policy


819 (page 75) States that Neighbourhood Streets are to have a 20 m ROW. That does not provide flexibility for reduced ROW for window streets, streets that may have rear lanes, short cul de sac streets, and other situations where a smaller, more intimate street is proposed or appropriate. ROW needs to have more flexibility than strictly 20 m ROW.

Modified - revised range


819 _2 Minimum road width of 20m should be reduced. Modified - revised range


819 _2 Minimum road width of 20m is too wide and not necessary for low volume streets. It also does not encourage compact development.

Modified - revised range


819 what is the difference in function and facilities between the two Minor Street types? Why are they identical? Needs more distinction.

No change - chart identifies differences


819 20m minimum ROW width is inconsistent with intensification objectives. Modified - revised range

City Building policies - Mobility

819 Minimum road width of 20m is too wide and not necessary for low volume streets. It also does not encourage compact development.

Modified - ranges removed


819 All minor streets - A maximum value for the ROW range should be used not a range. Modified - revised to address comment


819 Policy 819 what is the difference in function and facilities between the two Minor Street Types? Why are they identifcal?

No change - chart identifies differences


820 (page 75) Last bullet point is awkwardly worded and confusing – it is difficult to determine what the goal / function is intended to be. Consider revising wording to clarify the intent of the goal or function.

Modified - last bullet removed

Urban and Rural London Place Types

821 Whole Part There are also questions regarding how the City plans to account for land uses within its land budget. The Plan currently permits flexibility within place types to allow for a mix of uses. While not necessarily an issue in limited scale, there are questions as to what the cumulative effects of this type of development could do to the City’s 20-year supply. This is also reflected in the “Commercial Industrial” and “Transitional Industrial” place types. There are questions as to the need for these place types within the Official Plan, how they are to be utilized, and how they are being accounted for in the City’s land supply. Further, there are policies that speak specifically to the “Tempo Plan” within the Official Plan. These lands fall within the “Farmland” place type yet permit a wide range of Industrial uses that do not appear to be part of the City’s industrial land supply and would not be consistent with the PPS’s definition of agricultural use.

Modified - Tempo Plan policies revised to address concerns

Urban London Place Types

821 Whole Part What is going to happen with the Hydro Lands - support for residential use No change - The lands are shown as Light Industrial and Green Space in the London Plan, reflecting their current use. The potential redevelopment of the Hydro lands site will be subject to further study and evaluation. The floodplain considerations will have a significant impact on the future developability of the lands


821 Whole Part The current zoning by-law is out of date. Spefically the types of retail uses listed are outdated and not common anymore (eg - video store). Zoning needs to be updated with a more generic "retail" use permitted.

No change - the Zoning By-law will be reviewed and amended to align with the Place Types in The London Plan


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types

821 Whole Part The River Walk in Detroit is a fabulous example of what can be done with a riverfront. It sure beats the concrete beach idea that is currently being pushed for the Hydro Lands.

No change - The planning of the Thames River corridor through the centre of the City is being considered as part of the “Back to the River” project. The lands are all within the Green Space place type in the London Plan


821 Whole Part Service Business versus Retail services - need more clarity around these uses to differentiate between them.

Modified - glossary to be expanded to include additional terms


825 Table 10 lists the planning and design considerations related to use, intensity and form. No change - commentary on proposed policy.


828 Policy 828: maximum heights are too high. (Restating comment regarding Policy 12) No change - heights consistent with intent of plan

Urban London Place Types - Downtown

829 Whole Chapter Brownfields along the Thames River in the core should be reserved for restoring the riparian zone to allow for increased users and avoid travelling deer from entering the downtown core.

No change - natural heritage and hazards policies UTRCA regulations regulate development in accordance with PPS


829 Whole Chapter If the London Plan intends on building ‘in and up’ and increase density in the core then it must increase green space proportionately because restrictions on private outdoor space must be compensated outside of the residences. Otherwise, the result will be tense, crowded neighbourhoods with no relief from each other, and no place to walk outside of a busy corridor. Please note, this is not ‘cafes’ and tree-lined streets. Open green spaces are for everyone regardless of their income, places to walk and not be idle and engage in alternative activities not associated with urban ‘spending’. Green spaces in the core must be large enough to accommodate the density levels.

No change - open spaces exist in core, plans for improvement are contained in Downtown Master Plan


829 Whole Chapter Unsure whether downtown needs to be expanded or not, however finds that lands adjacent to downtown should be permitted to have increased heights to allow for more transition to neighbourhood areas.

Modified - central london permits greater height opportunities.


829 Whole Chapter Lands immediately adjacent to Downtown should be treated like the transit village place type with regards to building heights and permitted uses. This would ease the transition to taller buildings downtown.

Modified - revised central london heights and densities, need to respect character of core neighbourhoods


829 Whole Chapter Boundaries b/w Place types where roads is division - transition policies - need to be more clear. No change - policies allow for reasonable transition as appropriate locations are identified.


829 Whole Chapter - consideration for maximum parking? Modified - parking minimized where appropriate - eg: shared parking is encouraged


829 Whole Chapter The Downtown Master Plan should be a part of The London Plan (like a Secondary Plan). Modiifed - plan revised since downtown plan adopted by council, included as a guideline document


829 Whole Chapter Need for different housing choice in Downtown. No change - policies consistent with vision of plan


834 Policy 834: suggests after "our recreational network" adding "and the natural heritage system…" No change - policies consistent with vision of plan


835 _11 Policy 835.11: asks where the "environmental sustainability goals" of the Plan are spelled out? No change - issue addressed in Green and Healthy City policies


835 _3 Urban design guidelines encouraged in the Downtown This should be extended to the whole city. Guidelines should include references to building materials to strengthen connection to existing development

No change - issue addressed in City Design chapter


835 _5 P200, Policy 835_5, include bicycle parking, carshare, bikeshare under public parking plan for downtown.



835 _6 Policy 835.6: suggests changing "development Downtown" to "development of Downtown" Modified - revised to address comment


835 _8 The city will "lead by example - investment, urban design Modified - revised to address comment


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types - Downtown

835 Policy 835: A number of "subsidiary plans" are proposed. Cannot the key policies of these be included in the London Plan? Is it wise to leave so much future planning work that future councils may not agree to fund? Do the number of subsidiary plans call into question whether we can afford complexities of the new planning processes anticipated by the London Plan? Is it reasonable to expect a resident or developer to sift through numerous guidelines and shouldn't reading the London Plan be all that's required for understanding planning Policy?

No change - guideline documents and programs will implement the policy.


835 Add reference to downtown heritage conservation district plan Modified - revised to address comment


835 Insert an asset management best practises clause. Modified - revised to address comment


836 _4 Surface parking lots will not be permitted Modified - revised to address comment


837 _2 What about desirable land uses (on site daycare, bicycle parking, affordable housing) Modified - revised to address comment

Urban London Place Types - Downtown London/Transit Village

837 _4 Reconsider parking requirements in the Transit Villages and other nodes to match dowtown, use reduced requirements to attract development. See Edmonton's 2011 study for example.

No change - policy consistent with vision of plan


837 Policy 837: Why is the bonus height for Downtown Place Type 30 storeys? This seems arbitrary unless fire dept has a limit for fire safety. Reason for height limit should be stated.

No change - not desired for most intensification in a small number of buildings


838 _1 & 838_2 Guidelines are written as general recommendations, not as rigid Policy. revised these policies to ensure that guidelines are not treated as Policy.



838 _10 Policy 838.10: suggests creating some totally unsigned streets downtown, suggests this leads to highest level of safety.

No change - not intended direction, signs to be controlled by sign by-law


838 _4 Is it appropriate to require a wind assessment for all projects? Should this be revisedd to only require wind assessments for projects exceeding a specific number of storeys or building height? Consider revising this Policy to only require a wind assessment for projects exceeding a specified height or number of storeys.



838 _4 Wind assessment for all projects? Even smaller 2-4 stories? Is this to address the winds on the streetscape? Perhaps revised wording to “may be required”?



838 Policy 838: suggests new subsection saying "all planning and development applications will be evaluated by Urban Design Peer Review committee"

No change - already addressed in plan


838 Policy 838: suggests new subsection saying "energy will be provided through district distribution (waste heat/geothermal/solar)".

No change - issue addressed in Green and Healthy City policies


838 Policy 838: suggests new subsection saying "waste collection" No change - issue addressed in Green and Healthy City policies


838 Policy 838: Asks what the UDPRP is and what the justification is for it. Suggests it means staff do not trust development industry's ability to propose good projects. Suggests the London Plan should identify policies about need for, membership of, and extent of role of the UDPRP. Suggests this is needed to ensure unfettered abilities do not frustrate unnecessarily the review of legitimate and worthwhile development proposals.

No change - Urban Design Peer Review Pannel was created by Council to provide peer advice on design matters


839 This bounded area should be illustrated in the City Structure Plan. Modified - revised to address comment. Included on place type map


839 The Downtown boundary cuts through Centennial Hall site and this causes confusion for re-development. The site and maybe the parking lot to the north should be included in the Downtown area.

No change - boundary respects higher intensity opportunity south of Princess, and allows for lower intensity uses adjacent to the neighbourhoods to the north and east


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types - Downtown

839 A map should be incorporated to illustrate the boundaries of the Downtown. Modified - revised to address comment. Included on place type map


839 New Policy: "The Downtown boundary was established for planning purposes to contain the highest intensity and widest range of uses in the city to minimize impacts abutting low density residential neighbourhoods and to serve as a focus for the city's incentive programs to focus revitalization efforts.



839 Use a map to describe downtown in addition to the policy written in the text. Modified - revised to address comment. Included on Place Type map


840 Suggest adding another criteria: "impact on financial reserves and operating budgets as a result of existing incentive programs applying to a wider area".

No change - adding lands to boundary does not compel an expansion to program boundaries


841 Whole Chapter The “Planning and Development” policies for each place type should refer specifically to Policy 1324 and make it more clear that 1324 (4) and (5) are intended to assist with the required review of “fit” and “impact” rather than being an entirely separate and redundant review. All of the criteria in the relevant sections should also be presented in the same order.

Modified - subject policies moved to Our Tools part

Urban London Place Types - Transit Villages

843 and 852 Transit Village Place Types are only identified for 3 locations in the City. This is insufficient for a long-term plan. Suggests additional Transit Village Place Types should be identified. See attached map for suggestions.

No change - four transit villages identified, intent is to focus on specific rapid transit corridors first.

Urban London Place Types - Transit Village

843 Whole Chapter concept of how they are developed- who builds it, what does it consist of, where is it located (which corner)

No change - plan provides informaiton - use and form to be consistent with place type, developments are built by private sector


843 Whole Chapter public process for community to be involved through ZBA - as long as the neighbours are notified of potential change.



843 Whole Chapter Byron - shouldn't we consider this a a possible Transit Village? Fits the definition/concept. No change - four transit villages are appropriate for next 20 years, intent is to connect rapid transit to downtown


843 Whole Chapter More Transit Villages and name them/give them a name. No change - four transit villages are appropriate for next 20 years, intent is to connect rapid transit to downtown

Urban London Place Types - Transit Village/Rapid Transit and Urban Corridors

843 Whole Chapter Concerns with feasibility of intensification in existing shopping centres due to parking requirements and business models.



845 If concentration of commuter employment is downtown, per other parts of the Plan, it will be hard to have transit villages with lots of employment to support more than just one way commuting to employment nodes like UWO, hospital and downtown. Maybe Fanshawe fits, but if it puts more space downtown there will be less at east end. Especially with limitations of Policy 849.4.

No change - the Environmental Assessment for Rapid Transit will determine route.


846 Northeast corner of Fanshawe Park Rd E and Richmond Street - planning applications for minor changes which would require changes to form or intensity to the existing legal uses, and even those minor changes that would not require changes to form or intensity, appear to require an Official Plan Amendment. There are no policies for guiding minor or major changes to the existing land use; but, there should be .

No change - addressed under Our Tools, Policy 1386 to 1394.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types - Transit Village

846 Northeast corner of Fanshawe Park Rd E and Richmond Street - The London Plan Policy 846 states the time frame expectations for implementing the ‘Transit Village’ policies. Transit Villages are “expected and encouraged to undergo a great deal of change and intensification within the first phase of the implementation of the (London) Plan.” Policy 847 on ‘How Will We Realize Our Vision’, Policy 849 on ‘Intensity’, Policy 850 on ‘Form’ and Policy 851 ‘Transit Stations in Transit Villages’ focus on transit, transit supportive development and the pedestrian environment with no regard for existing uses. Policy 853 ‘Planning and Development Applications’ requires compliance with policies from the entire plan and particularly “the degree to which the proposal conforms with the ‘Transit Village Place Type’ policies.” The London Plan Policy 846 states the time frame expectations for implementing the ‘Transit Village’ policies. Transit Villages are “expected and encouraged to undergo a great deal of change and intensification within the first phase of the implementation of the (London) Plan.” Policy 847 on ‘How Will We Realize Our Vision’, Policy 849 on ‘Intensity’, Policy 850 on ‘Form’ and Policy 851 ‘Transit Stations in Transit Villages’ focus on transit, transit supportive development and the pedestrian environment with no regard for existing uses. Policy 853 ‘Planning and Development Applications’ requires compliance with policies from the entire plan and particularly “the degree to which the proposal conforms with the ‘Transit Village Place Type’ policies.”

Modified - deleted the last sentence in 846. Intent is to support rapid transit, recognizing the relationship between land use and transit.


846 An expectation of significant re-development for transit villages is recognized by this Policy of the Plan. Perhaps it is worth noting that secondary plans will be created to identify development potential for transit villages and to provide a capacity analysis to be used for future growth planning? SUGGESTION: Perhaps add additional verbiage regarding secondary plan analysis on development potential and future capacity for transit villages.

No change - addressed in policy 847(9)


847 _11 Policy 847.11: After "Design guidelines…", suggests adding "with pictures and diagrams of best designs," may be established…

No change - too detailed for official plan policy


848 1299 Oxford Street East (Oxbury Mall) - mixed uses are the prefered development, which is not consistent with the owners intent to maintain exclusively commercial land uses

No change - policy permits use while allowing more flexibility


849 _1 What economic and market analysis has been completed to confirm that a minimum of four storeys is achievable?

No change - reference is not to floors, but to equivalent height


849 _1 1299 Oxford Street East (Oxbury Mall) - change wording from "will" to "are generally encouraged to", add that "existing developed sites may include a variety of built forms and heights"



849 _2 1299 Oxford Street East (Oxbury Mall) - change wording from "will be required" to "is encouraged"



849 1299 Oxford Street East (Oxbury Mall) - minimum height is 4 storeys and there is requirement for internal road network. This does not allow the owner to revitalize the site in its existing form. This form of development may not be appropraite for the Oxbury mall site






Page 144

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types - Transit Villages

850 _12 If want bike and car share to work then need to encoruage facilities, not just the programs, unless intent of shared parking facilities is for car and bike share. Doesn't read that way and will require zoning changes. Also need to encourage building showers, perhaps through bonusing. Should include minimum shower facilities in zoning to go with minimum (or max) parking. The only reference to showers for bikes is in the Green Industrial Development section. We won't have Vancouver's weather so to promote AT need to provide incentives for the builders (gives example of Pacific Centre - downtown Vancouver mall - and G&M article on showers/bike storage for end of trip).



850 _13 Policy states “lot assembly is encouraged”. Policy is not something that can be implemented by City and could lead to individual property owners taking advantage of would-be purchasers. Suggests removing.



850 _2 1299 Oxford Street East (Oxbury Mall) - change wording from "conform with" to "have regard for"

No change - design policies permit flexibility





850 _5 Do “direct connections” mean sidewalks and pathways?Who builds Transit stations? What do they look like?Are they stand alone or part of a development through bonusing?

Modified - policy revised to remove reference to connections.





850 The theme for the Plan encourages intensification in mid and high rise buildings in Transit Villages and along Rapid Transit and Urban Corridors. This form of housing requires much deeper lots than exist along these corridors. Generally the plan identifies several minor policies #850 for assembly. This is a deficiency in the Plan policies and should be addressed to allow\encourage land assembly the amount and form. This will become a significant issue.

No change - Transit Village Place Type relates to some large and deep lots


850 1299 Oxford Street East (Oxbury Mall) - applications required to comply with the City Design section. The prescriptive wording (will, shall, etc) should be revisedd to allow for all considerations to be included such as market, servicing, context, development costs, etc.)



850 Policy 850: suggest new subsection stating "Orient for solar and plan for district energy, using waste heat, solar and geothermal systems."

No change - issue addressed in City Design and Green and Healthy City chapters


850 Policy 850: suggest new subsection stating "Shared community places for markets." No change - markets can be accomodated within existing policies


852 Criteria should allow for addition of Transit Villages as well as expansion of Transit Villages. Additional criteria that should be considered are a review of existing LTC routes / usage so that expansions / additions are in areas that will support or enhance current routes outside of the “Primary Transit Area’.

No change - need for more than 4 transit villages is not anticipated within the term of this plan


853 _6 why is the onus on the applicant? Policy 853_6 Should be the City that undertakes on the role and timing of it.

No change - requirement is for the applicant to demostrate how the proposal fits within the future development context.


853 _6 The applicant should NOT be required to do the concept. This same Policy occurs on page 226 for RT and Urban Corridors, and page 232 for Shopping Areas.

No change - requirement is for the applicant to demostrate how the proposal fits within the future development context.


Page 145

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types - Rapid Transit and Urban Corridors

855 to 889 Each day, significant numbers of our students make their way to Fanshawe via transit. As a result, the City's transportation system is of vital importance to us. The College supports the City's vision for a rapid transity system that is reliable, frequent and cost-effective. However service near Fanshawe, should provide relief for, not be a the expense of, existing high capacity transit routes, including capacity-challenged routes serving the college.


Urban London Place Types - Rapid Transit and Urban Corridors

855 to 889 The College feels that, given on-campus transit terminals, any future developments must consider pedestrian safety. The College very much looks forward to working the the London Transit Commission to develop and make decesions on any potential nearby terminal/stops.


Urban London Place Types - Rapid Transit

855 Whole Chapter Consider Subway and Light Rail transit rather than buses and transit prioritization signals. No change - London plan allows either, transit Environmental Assessment underway to look at options


855 Whole Chapter Rapid Transit Corridor should expand to Argyle Mall and be linked to the Airport. No change - may be considered in a future phase.


855 Whole Chapter Protected bike lane to connect to Downtown/Thames Valley Parkway. No change - to be addressed in bicycle master plan


855 Whole Chapter Not enough focus on cyclists. Concerned over RTC and conflict with cyclists. No change - to be addressed in rapid transit EA and bicycle master plan


855 Whole Chapter additional analysis required for segments, to ensure all achieve the overall LP objectives. Excluding areas such as 'South Wellington' defeats the purpose of the designation.

Modified - removed "preserve" on Wellington Road


855 Whole Chapter Include a dash line along the corridors within the transition area of the Neighbourhood so that residents know or can expect some form of development activity.

No change - policies describe where development can occur


855 Whole Chapter Generally supportive of the range of uses in the Urban Corridor Place Type. No change - indicates support for the plan

Urban London Place Types - Rapid Transit Corridor and Urban Corridor

855 Whole Chapter Commercial Properties at Cherryhill Village - 101 Cherryhill Blvd and 301 Oxford St - Minto supports the Rapid Transit Corridor designation on their commercial properties however they would like to see some additional flexibility introduced into the policies to allow for a wider range of building heights and a limited amount of additional uses that would be suited to these types of locations.



855 Whole Chapter Commercial Properties at Cherryhill Village - 101 Cherryhill Blvd and 301 Oxford St - We request that the height provisions for this designation be similar to those within the Transit Village designation. This would allow for up to 15 stories and the opportunity for bonusing up to 20 stories. Given the limited extent of Rapid Transit Corridors in The London Plan, we would encourage policies that will allow for greater intensification along these important transit routes, especially in areas such as this where there is already an existing supply of transit supportive development.



855 Whole Chapter Commercial Properties at Cherryhill Village - 101 Cherryhill Blvd and 301 Oxford St- We think it would be appropriate to include some flexibility to permit a limited number of single storey buildings and drive –throughs within the Rapid Transit Corridor to allow for the broadest range of uses along these important connecting routes and to recognize that some of these uses are appropriate along major corridors.



Page 146


858 We commend the City and the London Transit Commission for including in their vision for London a rapid bus transit (RBT) system. Western student leaders have repeatedly stated that one of their highest priorities is having a more reliable bus system. Western’s concern is that a BRT system not come at the expense of already capacity-challenged routes.



859 _4 & 859_5 Are these two policies not contradictory? Is #5 needed? No change - policy #5 allows for specific opportunities for intensification near rapid transit stations


859 _7 Glossary provides a definition for “transit-oriented”, but not “pedestrian-oriented”. Need to provide a definition for both to ensure their consistent application. revised the LP glossary to include a definition of “pedestrian-oriented.”



860 to 862 policies for the assembly of lots is critical to the success of the corridors. Edits are provided to clarify that 1) lots assembled with lots in the corridor will be considered to be within the corridor; 2) that the purpose of assembly needs to be justified on the basis of use, intensity, and form; and 3) requirements regarding automobile access are adequately addressed in the our tools chapter and need not be repeated (Policy edits provided in comments)

Modified - revised wording incorporates some concepts listed


860 Bishop Hellmuth HCD - This is the proposed note to remind you to make the southern end of the Bishop Hellmuth HCD a special preservation segment along the Urban Corridor on Oxford Street. I and my neighbours very much appreciate this as our proximity to the corner of an Urban Corridor and a Rapid Transit Corridor will still make us somewhat vulnerable.

No change - these properties are within the Bishop Helmuth Heritage Conservation District, which includes appropriate protections.


860 Refers to properties that are within Rapid Transit and Urban Corridor place types. There is insufficient size / depth in many locations, as well as gaps along the corridors, to allow for practical implementation of the policies. Place types should not be defined so precisely on the maps. Policies in 861-862 need to be reworded to recognize that boundaries are general and must be flexible to allow feasible development opportunities in conformity with the place types.



860 860_ Map 4 - Place Types, graphically depicts properties that are included within the Rapid Transit Corridor and Urban Corridor Place Types boundaries. In general, These properties have been included within the Corridor Place Type because they abut one of the following street classifications: along a designated corridor:1. Rapid Transit Boulevard2. Civic Boulevard3. Urban Thoroughfare



861 & 862 unclear if use of word "corridor" is referencing the place type or used more generally. Confusion is possible.



861 & 866 The theme for the Plan encourages intensification in mid and high rise buildings along Rapid Transit and Urban Corridors. This form of housing requires much deeper lots than exist along these corridors. Generally the plan identifies several minor policies #861 and #866 for assembly. This is a deficiency in the Plan policies and should be addressed to allow\encourage land assembly the amount and form. This will become a significant issue.

Modified - revised language regarding interpretation of the boundary.


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861 861_ In some instances, Through an interpretation of the Place Type boundary, it may be desirable to allow for the assembly of additional lots, located outside of the Corridor, together with a lot that is located within the Corridor as identified on Map 4. This interpretation will may allow the opportunity for development of a greater area size and depth that is more consistent with the form of development envisioned for the Corridor.

Modified - revised wording to address some items listed


862 _3 Assembling properties – provide clarification how deep into a n’hood considered acceptable? Add a Policy that is proportionate to the scale & mass of building. Policy 862_3 – “reasonably” difficult to manage if property selling at too high a price.

Modified - revised language, intent is to standardize depth of lot


862 Policy 862 - Alternate wording to “encroachment” – implies a negative connotation. Change the interpretation made by staff?

Modified - wording removed


862 862_To avoid the The interpretation of the Place Type boundary will not need for an Official Plan amendment, provided it ensures while still ensuring that the interior portion of neighbourhoods are protected from the encroachment of higher intensity forms of development that are intended for the Corridor. The following criteria will be used to guide the interpretation of the boundary of the Corridor Place Type boundary beyond that which is shown on Map 4:1. A boundary interpretation shall only be made by Council concurrent only with the review of a zoning amendment application so that considerations of planning impact and compatibility can be addressed. Such zoning amendment applications will be reviewed in accordance with the Planning and Development Applications section of this chapter. An Official Plan amendment will not be required. 2. The zoning amendment application shall demonstrate the need for the assembly of lots abutting the lands within the Corridor and planning justification for the boundary interpretation to achieve the development form and building height intended for the Place Type. 3. If the site is located on a corner, the proposed front face of the building shall be oriented to the Boulevard or Thoroughfare, and shall not be oriented to the more minor “side-street”. 4. The interpretation of the Place Type boundary shall not result in the creation of isolated remnant lots, outside of the Corridor Place Type, that cannot be reasonably assembled with other parcels in the Place Type to develop in accordance with the long term vision for the Corridor. 5. The evaluation of a development proposal will have consideration for how automobile access and circulation will be managed to mitigate impacts on the neighbourhood.



866 _4 States that lots will be of sufficient size and configuration.... Mapping should be less precise in order to designate a reasonable depth for typical intended development forms.

No change - policies include that there is flexibility in interpretation


867 _1 & 867_2 If applications conform to the City Design policies, they should not be required to go to UDPRP as well. Furthermore, some applications ( e.g. – consent, minor variance) do not need to / cannot necessarily conform to City Design policies.

No change - panel to review all applications on arterial roads, guidelines allow flexibility


867 _3 Policy 867.3: reference to "cycling" should identify dedicated bike lanes along major corridors like Oxford, Richmond, etc).

modified - revised to address comment


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867 _4 Western agrees that transit stops need to be conveniently located and coordinated with the proposed rapid transit stations. With regards to clause four, however, Western has a unique understanding of transit patterns on campus and locations for transit stops within University property should be determined by the University in consultation with the London Transit Commission.


Rapid Transit and Urban Corridors

867 _8 Based on our review, we object to the following draft Policy in the 'Rapid Transit and Urban Corridors' section: (867.8) Drive-through facilities (DTF) will not be permitted within the Corridors. We question the rational and justification of a DTF prohibition along Urban Corridors and Rapid Transit Corridors and request details on the studies that have been relied on for justification. Currently, the brands which we represent have more than twenty resturants with DTF within these corridors. It is unacceptable for these resturants to be prohibited and a prohibition based approached again being proposed.

Modified - revised to allow for drive-through facilities subject to location requirements


867 _8 SE corner of Adelaide St N and Huron St - concerned about loss of permissions for drive throughs. Consider adding design criteria instead of an outright ban



867 _8 These Corridors are generally comprised of Auto Oriented Commercial Corridor land uses which are the primary focus for drive-through facilities (e.g., Wharncliffe Road, south of Emery Street; Wellington Road, south of Commissioners Road). revised this Policy to retain opportunity and flexibility for drive through facilities.



867 _8 States that drive-throughs will not be permitted on Rapid Transit and Urban Corridors, however, Urban corridors are the most likely candidates for drive-throughs with the least impact on sensitive uses. Suggests removing Policy or allow drive-throughs with certain conditions / impact analysis study



868 to 879 The ‘Special Segment’ areas do not appear to be shown on any map. As a result, it would be difficult for a user of the Plan to be aware of the policies for these specific areas. Suggests special segment areas should be shown on map.

Modidied -addressed in special policies map


871 P223, Policy 871, note ‘neighborhood’ is spelled differently to other references throughout the document.



872 & 873 It would be useful if reference to the parent Section numbers could be provided. Need to clarify what are the parent permitted uses as those listed in Para. 864 are for both Regional Transit Corridor and Urban Corridor. Consider revising this Policy to provide the appropriate paragraph reference for permitted uses.

Modified - revised to removed term "parent"


874 _1 This Policy needs to be more flexible. Does it only apply to designated heritage buildings, in accordance with the Ontario Heritage Act?

Need to examine the Cultural Heritage policies.



874 _3 Regulatory signage would not meet these rules. Modified - revised to improve clarity

Urban London Place Types - Main Street

874 Policy stating that development should be consistent with the nieghbourhood would be stronger if a list of materials was included

No change - comment too detailed for Official Plan policy


875 _2 What criteria would be used to determine if “moderate redevelopment” is “appropriate”? Suggest Policy needs to provide clearer guidance or criteria.



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875 Not sure what attributes along Wellington Road South (from Alexandra Street to Weston Street) provide “ (…) a distinctive sense of arrival to the City (…)”, such that they should be preserved. In order to support Rapid Transit within these corridors, redevelopment opportunities in both areas should likely be promoted. The permitted uses outlined in Policy 876 for the Richmond Street corridor segment are largely the same opportunities that exist today (office conversions and residential uses in new and existing buildings) and have existed for quite some time.

Modified - deleted special segment policy


876 Policies are very vague – they state that the parent Permitted Uses will not apply but only indicate that some other uses (residential, office conversion, small-scale retail and mixed use) “may” be permitted. What ‘will be’ permitted? Suggest further clarifying needed.

No change - use of "may" is standard language throughout the plan


877 and 878 Policies are confusing / contradictory with those in Section 866/Table 12 (i.e. – minimum height at certain intersections is 4 storeys, with maximum of 12. However, 877.3 states that new buildings “will be of the same scale as that which is prevailing within the streetscape”. I do not believe that is typically 4 storeys at present. Suggests revising/rewording needed.

No change - general place type policies do not apply in special segment

Rapid Transit and Urban Corridors

882 _2 We acknowledge the 'Transitional' policies (section 882.2) which suggest Drive-through facilities (DTF) may be permitted when located in the rear or interior side yard within specific limited sections of Dundas St, Wellington Road and Wharncliffe Road South which are designated as Rapid Transit and/or Urban Corridors. However we question how a DTF is an acceptable use in these areas yet prohibited elsewhere along the same corridors. If a DTF can be permitted in these 'transitional' areas through tools like site design criteria and zoning provisions then there is no reason why they can't be permitted elsewhere along these corridors.

Modified - revised for consistency throughout plan


882 _2 SE corner of Dundas St and Clarke Rd - the wording of this Policy should be modified to allow for some flexibility. The requirements for space and turning radii for a drive-through are quite specific andmay require some site design considerations based on individual property factors.

Modified - policy delete, issue addressed in general corridor policies


885 _1 “Organizing Structure of Large Blocks for Future Redevelopment”. This is going to be quite difficult to implement. A requirement to design a private site, to a municipal standard, in the event parts of the private site become public in the future. What design standards for engineered infrastructure (transportation elements, water, sanitary / storm sewers, etc.) would be employed? This Policy was removed from the SWAP Plan and should be removed from the London Plan.

No change - policy requires drive aisles, not public streets


885 _2 This Policy needs to be more flexible. Parking between smaller buildings should be discouraged and limited to provide some flexibility in design. Consider revising this Policy to “discourage” parking between smaller buildings.



887 _2 Given the Policy, why is a large segment of the Urban Corridor outside of the Primary Transit Area (Dundas St E)?

No change - policy recognizes an existing condition


888 _6 The applicant should NOT be required to do the concept. Modified - revised to allow flexibility

Urban London Place Types - Shopping Areas

890 Whole Chapter Suggestion that shopping areas will transition to mixed use nodes is presumptuous, and provision of 'future streets' is unnecessary. Possible conflict between development according to permitted uses and provision of future roads.

No change - plan does not require redevelopment, allows flexibility for future land use transition


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types - Shopping Areas

890 Whole Chapter Plan better for big box retail and it appears to be a lot of future retail in the Plan. No change - plan includes more flexibility for mix and redevelopment of commercial uses


890 Whole Chapter SE corner of Fanshawe Park Rd W and Hyde Park Rd - previous approvals (noted in section 4.3.6.6(2) of current OP) are not carried forward.these should be included in LP


Urban London Place Types - Shopping Area

894 & 899 Acknowledge future opportunities for new or expanded Shopping Areas No change - significant new commercial opportunities exist to meet forecasted demand


894 & 899 952 Southdale Road West - Development of a shopping centre is supported by a market study. It is likely that there is demand in other areas for commercial space. More moderate language should be included to permit new shopping areas.

Modified - map change to include in Neighbourhood Place Type


894 The plan should permit new or expanded shopping centres where supported by a market study. No change - significant new commercial opportunities exist to meet forecasted demand


895 _2 and 895_7 Policy 2 is somewhat contradictory with Policy 7. Suggests removing subsection 2 No change - policies are consistent with intent of Plan


895 _3 Each of these Place Types have specific City Building and Place type design policies which dictate the type of development pattern and form intended for these Place Types. The Form policies usewords such as “will” or “will conform”. Our client’s concerns with the Draft OP are with respect to how the detailed Form Policies will be implemented.

No change - intent of policy is to permit flexibility


895 _3 this intended flexibility is inconsistent with the prescriptive nature of the other policies in the London Plan

Modified - revised other policies in section to allow flexibility


895 _5 & 897_2 High rise forms should be permitted in shopping areas, similar to the rapid transit corridor place type.

No change - highrise development is directed to primary transit area


896 _1 Shopping Areas permit a “broad range of retail …” but item 6 places limits ranges of use. Historically, “retail uses” have been not permitted in commercial corridors and areas that are not designated shopping centres. Is this changing? Should there be criteria outlining where retail will be permitted etc.??

No change - policy includes standard language, identifies that not all sites are appropriate for the full range of uses


896 _5 What if non-residential uses already exist/are proposed on the abutting interior Neighbourhood Street/Connector? Suggests clarifying/adding more flexibility.



896 _5 How is this impacted by the requirement for access to flanking streets? Modified - revised to improve clarity


896 _5 In the context of this Policy, we are unclear as to whether site plan modifications or planned development of future retail will continue to be permitted where the site abuts a Neighbourhood Street or Connector. We suggest that use of the phrase “will generally” instead of “will” seems more appropriate in many instances and is in keeping with the intent of Policy 895_3,



897 _2 6 storey limits (with bonusing) may be too restrictive in some areas where greater intensity would be appropriate to support existing / planned shopping. Suggests increased height.

No change - intent is to direct high density development to preferred locations (downtown, transit village, main street, etc.)


897 _3 Underground parking at shopping centres is often not economically feasible. Why place structured parking adjacent to interior/rear yards? It would likely have more negative impact on adjacent residential areas. It would be better along the high-traffic portion of sites and would also help mitigate noise. Suggests removing/revising.

No change - structured parking can impact pedestrian streetscape.


898 _1 & 898_2 States all planning development and applications will be reviewed by UDPRP and will conform to City Design policies. Not necessary for consents, minor variances, etc. Suggests revising.



898 _3 How does this Policy achieve the PPS goals for the efficient use of land and compact urban form? What is the width of the proposed driveways? Consider removing this Policy.

Modified - not for future municipal streets, allows for future redevelopment to support PPS and intensification policies


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types - Shopping Areas

898 _3 considering the typical width of a drive aisle for a commercial development is approximately 7 metres, it would be onerous for a property owner to provide a width that is in keeping with municipal right-of-ways (i.e. 18 metres). Use of 'will' is of concern

Modified - not for future municipal streets


898 _4 sites are outside of the primary transit area and developed as auto-oriented commercial plazas. Have issue with requirement for entrances facing street given this context. Would limit leasability of units as 2 entrances would be required



898 _5 This Policy does not provide sufficient flexibility. Consider revising this Policy to read as, “Parking shall be discouraged between these smaller buildings and the street,” to provide some flexibility.



898 _8-9 We request further clarification fromthe City of London regarding the expectations for the potential provision of parkettes and abundant planting and trees

No change - Parkett opportunities to be explored, tree planting in accordance with the Forest City policies of the plan


898 _9 Policy 898.9: suggest that all parking areas have permeable surfaces and tree canopy. No change - issue addressed in Forest City policies


898 Policy 898: suggest new subsection stating "all buildings should have integrated solar and geothermal systems, greywater systems etc"

No change - issue addressed in Green and Healthy City policies


899 The justification requirements outlined in Section 2.3.6.1 (b) of the PPS (2014) are not reflected in the list of criteria for evaluating expansions of the Shopping Area Place Type. RECOMMENDATION: OMAFRA recommends that a 5th bullet be added to this section which states that: where the expansion is proposed in the Farmland Place Type, it shall only be permit where all of the following are demonstrated:1. the land does not comprise a specialty crop area;2. the proposed use complies with the minimum distance separation formulae;3. there is an identified need for additional farmland to be designated to accommodate the proposed use; and4. alternative locations which avoid the Farmland Place Type have been evaluated, and where no reasonable alternative locations exist, a location in the Farmland Place Type with lower priority agricultural lands was selected.

No change - the Shopping Area Place Type applies to the geographic area of London within the Urban Growth Boundary, and is not intended to be applied as a Rural London Place Type. In addition, the Rural Neighbourhood Place Type Policy 1248_1, clearly states that the expansion of the Place Type will not be permitted.


901 _6 The applicant should NOT be required to do the concept. Modified - revised to allow flexibility


904 & 1017 Sunningdale North Planning Area - There is a suggestion that Villagewalk will be classified as a "Main Street". This conflicts with the policies for high density uses and confuses the development of the neighbourhood.

Modified - Main Street remved from policy


914 _6 Asks what this connection of Main Street to transit, NH areas and recreational facilities would look like? Notes this isn't mentioned in more detail. Asks if planning to build Main Streets to and through NHS? Asks what LTC says about connecting Main Streets to transit, given role of Transit on streets?



914 _7 Coordinating and facilitating connections between organizations is not really a role/Policy applicable to the OP.



917 _1 & 917_2 States all applications are subject to UDPRP and City design. Should not be applicable to consents, minor variances, etc. Should pertain to site plans primarily and potentially ZBAs.


Urban Londong Place Types - Main Street

920 change wording to "The Our Tools section provides additional criteria" No change - policy consistent with intent of plan


921 8th bullet Change social meeting place to gathering places Modified - revised to address comment


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types - Neighbourhood

921 Whole Chapter Residential Properties at Cherryhill Village - It is desirable that existing permissions set out in the current Official Plan are recognized and carried forward within the proposed Policy framework of The London Plan. These buildings not only represent long term investments but provide ideal opportunities for revitalization.

No change - Property is within remnant high density overlay

Urban London Place Types - Neighbourhood

921 Whole Chapter Residential Properties at Cherryhill Village - The policies pertaining to the Remnant High Density Residential designation are too limiting and do not recognize the valuable contribution these areas have made and will continue to make to the wellbeing of the City. The lands surrounding the Cherryhill Mall are bounded to the north by a major rail line, additional medium and high density residential uses to the east and west and a major arterial road/transit corridor to the south. As such, this is a separate and distinct neighbourhood, already developing as part of a successful transit oriented mixed use area, and one that is not connected with the other ‘Neighbourhoods’ Place Types in the surrounding communities.



921 Whole Chapter Residential Properties at Cherryhill Village - We have concerns that The London Plan identifies the long term vision for these lands at a much lowerdensity and built form than what currently exists and could, therefore, severely limit opportunities for redevelopment and reinvestment. It is noteworthy that Oxford Street is identified as a future Rapid Transit Corridor. The London Plan states that high rise apartment buildings are to be directed to theDowntown, Transit Village and Rapid Transit Corridors to create a viable and cost-efficient transit system.These lands are located within close walking distance to transit routes including those along Oxford Street, Platts Lane and Proudfoot Lane. High density residential uses will support an enhanced rapid transit system. Based on our review of The London Plan, the proposed designation of these lands as “Neighbourhoods” Place Type does not fully support key goals of regenerating the City’s urban neighbourhoods and directing intensification to those areas that will support rapid transit.



921 Whole Chapter Residential Properties at Cherryhill Village - We request that the balance of the residential properties should be designated as either Rapid Transit Corridor or Transit Village in recognition of the important role they play in the realization of complete neighbourhoods and transit supportive development. We do not feel that the conversion to lower density residential uses is the best utilization of these lands especially since the site has successfully operated as a high density residential neighbourhood for many years.



921 Whole Chapter childcare centres in neighbourhoods - include in both new and regenerating areas No change - allowed under community facilities


921 Whole Chapter Schools/closing of schools - impacts on the Plan No change - schools described as neighbourhood hubs in public facilities chapter


921 Whole Chapter 921 - clarify what is meant by 'green spaces' - is it NHS, open space? Parks and recreational opportunities includes woodland and open space parks? Need clarification

modified - revised to improve clarity


921 Whole Chapter The Children and Parent Resource Institute at 600 Sanitorium Road is not permitted in that designation. Either the neighbourhood place type should be expanded to permit a childrens mental health facility or the designation of the property should be changed.

No change - Use is permitted


921 Whole Chapter Walk-in clinics are not necessarily located in best locations. Modified - clinics added as a permitted use in neighbourhoods


921 Whole Chapter Re-evaluate roads that were changed from secondary collector in the current OP to "connector" in The London Plan (eg. Waterloo & Colborne north of Oxford Street - should be considered Neighbourhood streets not Neighbourhood Connectors)



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types - Neighbourhoods

921 Whole Chapter definitions for terms such as 'fit', 'coompatibility', etc required No change - terms require an assessment in the context of policies of the plan


921 Whole Chapter concern what it doesn't address is how proximity to transit and pedestrian oriented development. Apply Policy like Transit Corridors - within XX distance walking distance of transit stop.

No change - need to balance intensification with impacts on neighbourhood. Plan objective is to direct intensification to appropriate place types and corridors


921 Whole Chapter higher intensity uses exist on N'hood streets in Old South which makes for a better mix and dynamic community. Table 13 uses does not allow for redevelopment opportunity on N'hood streets.

No change - tables 13-15 provide intensification opportunities at appropriate locations in neighbourhoods


921 Whole Chapter parking requirement would not need to be the same (expect that it should be less) for commercial (e.g. pub or restaurant) in a neighbourhood because the expectation that people would walk to the place.

No change - plan speaks to desire to ensure there is no over-parking


921 Whole Chapter Need some examples, cases and demonstrations to better understand these policies and tables.

No change - not applicable to policies


921 Whole Chapter Appreciate that secondary dwellings are not contemplated in NCN - troubled by the fact there is no cap on dwelling conversions such as 2 that you might see in other areas.

Modified - Limit of 2 units added in NCN, except in central London


921 Whole Chapter Identify what changes we can expect by area. Not everything everywhere, particularly regarding Near Campus Neighbourhoods. Incorporateinto Plan key messages about intensification eg. That the range of uses/heights/gfa doesn't automatically mean that it will be allowed on individual properties. Incorporate pictures - e.g. not this - more like this.



921 Whole Chapter What are the characteristics of strong neighbourhoods? How do we know when it has reached that state? Planning districts don't necessarily reflect strong neighbourhoods.

No change - plan provides same policy framework in NCN to address this issue

Urban London Place Types - Neighbourhoods - Near Campus Neighbourhood

921 Whole Chapter Our overriding goal is to avoid more Broughdale like areas where the intensification tipped the balance from long term residents to short term residents.

No change - comment connsistent with intent of NCN policies


921 Whole Chapter Intensification is a concern for Near Campus Neighbourhoods. We have been given to understand that intensification will come in a variety of types under the London Plan. Much also depends on the street classification. We were told that staff would be looking at the appropriateness of the street classifications currently in the draft London Plan.



921 A great deal is made of "neighbourhood character", but this is not included on the list of "key elements of our vision for neighbourhoods". Consider including.



921 List of key elements of vision includes "parks and recreational opportunities…". Comments that this is the common use of 'park', hence the ongoing confusion with Open Space Parks and other uses of the term park. Asks if this means Woodland Parks and Open Space Parks? Notes that there is a park classification system now, so shouldn't use work 'park' and then use 'green space' in the next bullet on the list. Needs to be consistent. Terminology also confusing, if next bullet is "green space" and in other places it's "open space" or "Natural Heritage System".



921 Policy states that "In 2035 our neighbourhoods will be vibrant, exciting places to live…". Comments that some of the city's neighbourhoods already are vibrant, exciting places to live.

No change - agree with comment, however vision is that all neighbourhoods will be


921 Policy 921 has a bullet on the list of key elements of vision stating "employment opportunities close to where we live." Asks how is "close" defined (especially in light of MDS and not wanting factories close to residential and only wanting big office space downtown)?

No change - applies to employment opportunities, does not apply to all types employment uses


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921 Final bullet should also include opportunities for cycling trails in natural settings. Suggest adding “and cycling” between ‘walking’ and ‘trails’



924 _1 Asks what does this mean? Consider further explanation or simplifying language? Modified - revised to address comment


924 _12 Asks what "integrated with adjacent neighbourhoods" means? How would you not integrate an adjacent natural area? Or does this refer to trails?



924 _12 Does not specify ‘significant’ components of the natural heritage system. Statement needs to be qualified as it is too broad. Suggests adding ‘Significant’ to beginning of sentence.



924 _12 This Policy is too prescriptive.

What constitutes the “natural heritage system”? Is this significant features as provided in the PPS or anything natural?



924 _13 Asks when parameters for infill will be established? Questions if "parameters" are different than "Guideline documents"? Questions how "parameters for infill and intensification" will provide for all of the things listed. And what if a place is already dynamic, lively and engaging place to live? Do you plan to change that?

Modified - new section added re: guidelines to be prepared for intensification projects


924 _13 When / how will “parameters” for infill and intensification be established? Need additional clarity to Policy, or provide parameters in the OP.



924 _13 states that: The parameters for infill and intensification will be established to respect existing community character and offer a level of certainty, while providing for strategic ways to accommodate development to improve our environment, support local businesses, enhance our physical and social health, and create dynamic, lively, and engaging places to live.



924 _13 The nagging question is will the "parameters for infill and intensification.." noted in 924.13 be in place prior to the adoption of the London Plan by the Province and the OMB and what will be the involvement of the GNC neighbourhoods in the creation of these "parameters?"



924 _2 Suggests that this really should be limited to new neighbourhoods rather than ones with established character.

No change - affects existing neighboruhoods with regards to intensification, to ensure the form and location is appropriate


924 _3 Without character statements for neighbourhoods and planning BEFORE applications, this is a license for problems (affordable and low cost as hot-buttons), and this may be contrary to 924.1 which identifies neighbourhood "identity" as a key vision.

No change - a mix of housing is encouraged, neighbourhood units are large and will support this policy goal.


924 _3 This Policy states that low-cost and affordable housing will be planned/integrated into all neighbourhoods. Asks if this means if a neighbourhood doesn't have affordable housing now, if the London Plan forces it? Also notes that in the Plan intensity is only "encouraged". Asks do you get affordable and low cost housing without intensity, other than Habitat for Humanity?

No change - policy result of provincial requirements. Note that many forms of development can generate affordable housing opportunities.


924 _3 What constitutes “low cost” housing in comparison to “affordable”? How can you mandate low cost and affordable housing into ALL neighbourhoods? Suggests Policy reworded/revisedd.



924 _3 What is the meaning of “low-cost affordable housing”? This Policy is not flexible. Is it appropriate? How is this Policy to be implemented? Some additional clarity here from an implementation standpoint would be helpful for all.

No change - intensification opportunities will satisfy this policy. Note that it will be integrated in neighbourhoods per the plan


924 _5 Appropriateness of mixed-use/commercial all depends on definition of "neighbourhood". Table 13 gives the opportunity to put a convenience store at the intersection of every Neighbourhood Connector and Neighbourhood Connector. Why?

No change - consistent with plan objectives (complete communities, energy efficiency, active transportation, etc.)


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924 _6 What does "planned for" mean in this Policy? Does it mean the London Plan will permit it or do you mean for new (planned) neighbourhoods? Also asks what are the forms of "live-work", noting there are only 3 references to it in the whole Plan and only one with any detail (in Policy 1019). Asks if the intent is to re-do existing residential areas?

No change - intent is to allow for more live-work opportunities in new and existing neighbourhoods


924 _6 Cannot mandate ‘live-work’ forms of development in neighbourhoods. Suggests changing wording to ‘’are encouraged’ instead of ‘will be planned for’.

No change - "planned for" does not equal mandated. Some minor wording changes included to policy.


924 _7 Under the Neighbourhoods chapter, p242, Policy 924_7, add cycling mobility as well as pedestrian mobility in reference to street network design.



924 _9 Asks: What is meant by facilities for ‘urban agricultural systems’? Does a rear yard qualify? Suggests revised/remove Policy.

No change - rear yards could qualify


924 _9 It is not clear what an “urban agricultural system” is; how this Policy is to be implemented? To what extent these “systems” are to be integrated into neighbourhoods?Why it is a prescriptive requirement?

No change - includes community gardens, gardening clubs, food and plant sharing and food sales in parks


924 Policy 924: suggest new subsection stating "Energy systems will be governed by the Community Energy Plan".

No change - community energy plans not contemplated in London Plan


924 No mention of child care as a critical component of neighbourhoods Modified - revised to address comment


925 _3 This Policy guts the OMB decision on 260 Sarnia. While you increase density on the 'major street', you change the character of the neighbourhood for homes behind it. So instead of back lot to back lot, it's back lot to parking lot.

No change - OMB decisions related to assembly and consolidation of properties, existing Official Plan policies would also allow


925 _4 Does this mean every "corner lot"? It cannot mean that. No change - Tables 13, 14 and 15 provide details


925 _5 Why is greater intensity permitted fronting onto parks? Doesn't this make access to/from park more dangerous for kids playing there? Or do you only mean certain kinds of "Parks" based on the proposed classification system? Need to provide clarity to community and the industry about terms.

No change - Parks create opportunities for focal points and community hubs


925 _6 Regarding the "balanced" approach and neighbourhood stability: there is much more unpredictability in this Plan than in previous Plans.

No change - London Plan identifies areas where various intensities, uses and forms are permitted in Nieghboruhood place type


926 _1 Need to clarify the reference to "Zoning on individual sites may not allow for the full range of permitted uses shown in Table 13".

No change - means the London Plan will include a full range of potential uses, but not all will be permitted on every site


926 _1 Asks if Z-1 will be changed, too. Asks that if one applies to amend the OP do they just ask to change the street classification? But if street classifications based on traffic then how will applications be evaluated? Or will this mean fewer OPAs and jut more rezoning's? Also asks won't business want parking? Or is the city seeing a whole host of new convenience stores?

No change - New zoning by-law will follow London Plan. Street classifications are not based on traffic volume


926 _1 Policy should also state that range of uses may also be greater than specified in Table 13 based on existing zoning. Suggests revising.

No change - policies regarding non-conforming uses included in plan (1389-1394)


926 _2 Again, use of "may". Suggests it should be "shall" or "will" prepare policies/guidelines. Modified - policies added to indicate guidelines for intensificaiton will be prepared


926 _2 Guidelines OK, if guideline development and revision process is modified to allow for greater consultation and appeal opportunities.

No change - guidelines require amendment to London Plan.


926 _3 Asks who decides on the "appropriate range" of retail, office and service uses within a neighbourhood. States that generally the City does not dictate this.

No change - Council determines this through Zoning Amendment applications


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926 _3 Regarding the "retail, office and services that have minimal impacts/is appropriate/compatible fore neighbourhood context": Questions how you determine the impacts when criteria are primarily on building form only (see Policy 954); Questions what is "neighbourhood context" and asks whether this is just "neighbourhood" (if so, simplify the language) or whether it means "complete" neighbourhood? Also suggests a simplification of the Policy's wording, so it ends with: "...Place Type will have minimal impacts and will be appropriate and compatible to the neighbourhood."

No change - later policies in chapter address questions


926 _4 Policy 926.4: Suggests that Medical/Dental clinics should be permitted, as well as homeopathic and alternative medicine services.



926 _4 Why are medical/dental offices & clinics not permitted? Suggests removing Policy. Modified - policy deleted


926 _4 medical/dental offices are not permitted. These uses are in keeping with the neighbourhood character and should be permitted.



926 _5 Suggest changing "the below policies" to "the policies below", and asks if what is referred to is the "Form Policies" of 939.3. And, if is referring to 939.3 only, asks if that is the sole control? Stating that it's the Form Policies are a subjective fit, not even a review by the Urban Design Plane? Concerned about how a proponent demonstrates fit if the criteria aren't laid out in the Plan?



931 This Policy imposes a minimum distance separation distance between group homes. Could the City please provide some land use planning rationale for imposing this condition?In the absence of land use planning justification, this would appear to be in conflict with the Human Rights Code.

Modified - removed separation distancepolicies for group homes


932 This Policy imposes a minimum distance separation distance between correctional and supervised residences. Could the City please provide some land use planning rationale for imposing this condition?In the absence of land use planning justification, this would appear to be in conflict with the Human Rights Code.

Modified - clarified intent is to avoid over-concentration and ensure good distribution throughout city.


935 Policy 935: Suggests the following community facilities be added to the list in this Policy: "community gardens", "other community buildings such as gazebos and simple buildings that allow the community to work and play together".

No change - community gardens covered by items on current list.


935 Page 246 – Community Facilities – should there be separate detailed policies on schools and their importance to Neighbourhoods – notwithstanding their jurisdiction under the School Boards.?? What input has had the Boards?

No change - schools are encouraged as community facilities


935 Add the co-location at school sites and reference child care (not day care) No change - daycare was used as a term that is no age-specific; consider adults and seniors needing daycare


938 _3 & 940 Residential intensification in neighbourhoods coupled with secondary uses for Connector & Connector, the Plan is BUSTING neighbourhoods. The only "balance and predictability" is the "general" comment of Policy 938.3, noting intensity will be appropriate based on the zoning by-law. However concern is that the zoning by-law is to implement the Official Plan, not to "manage" the OP. Also asks why "parking" is not in the list of zoning regulations mentioned in Policy 938.3.

No change - policies provided to ensure intensificaiton includes appropriate form, intensity, and land use


939 _1 Refers to “all” applications conforming to City Design policies. May not be relevant to consents or minor variances, etc.

No change - policy applies to all applications including those for consent and minor variance


939 _2 It is not always possible to design for NO noise walls, as they are often required for the flanking lots. Suggests Policy should be reworded.

Modified - wording revised to address comment


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939 _4 Very restrictive Policy re: no front yard parking for certain uses. Need to ensure that Neighbourhood Connector streets allow for on-street parking when associated with mixed-use, retail, etc. uses.

No change - policy is consistent with the plan, it is important to avoid front yard parking in Neighbourhoods


939 Policy 939: Suggests pilot projects for composting, livestock, bee keeping. No change - not an Official Plan policy, operational/implementation item.


940 to 943 The London Plan does not provide City Council with sufficient tools within the plan to support its intensification intentions against pushback from home owners who are not welcoming to different forms of housing entering their neighbourhoods.

No change - policies allow greater flexibility/choice and predicatability.


940 However, in putting forward a proposal, there is no evaluation of intangibles (character, quality, vibrancy, etc), only building form and placement. Nor does Plan contemplate guidelines for evaluating how a proposed intensification will be "undertaken well". Is there an Urban Design Panel review for such projects? See Policy 954, as only compatibility and fit and form being evaluated. The rest of character, quality and sustainability has no criteria set out in the Plan. At the same time, the Plan makes it easier to add intensification with less input from neighbourhood (see Policy 951, scoped site plan approval). And as there is nothing additional about site planning in the NCN section, the Plan is also making it easier for intensification without neighbourhood input there, too, despite telling residents that part of the NearCampusNeighbourhood OPA would deal with site plan issues.

Modified - issue addressed in policy 954 - urban design brief, site plan requirements


940 Refers to "undertaken well to add value to neighbourhood rather than undermine their character, quality and sustainability." What is meant by "add value"? This doesn't mean financial value, so what does it mean? Leave it out if has no meaning or can't explain.

No change - add value can include quality development,or providing new housing types in a neighbourhood


942 Policy 942, Forms of Residential Intensification – this Policy states the following: “Secondary Dwelling Units – an additional subordinate residential dwelling unit within existing residential building or within a structure that is ancillary to an existing residential building.” This appears to be a definition for secondary dwelling units which is different than the definition provided in the Definition section of the OP, and therefore the Policy should either be removed, or revisedd.



942 The Plan should allow for small scale infill projects that are accepted and approved with less review and process. Many small investments on many sites will have a broader distribution of the transportation impact and land use impact. Better distribution of intensification and less pressure on the municipal infrastructure.

No change - plan allows for flexibility and also ensures predictability, scoped site plans provide for itnensificaiton


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types - Neighbourhoods - Near Campus Neighbourhood

942 This Plan creates a variety of opportunities for intensification. The following list spans from a very “light” and discreet form of intensification to more visible and obvious forms. All are important to realize our goals of purposeful, sensitive, and compatible intensification within ourneighbourhoods:• Secondary Dwelling Units – an additional subordinate residential dwelling unit within existing residential building or within a structure that is ancillary to an existing residential building. (NB: proposed to be prohibited in the GNCN)• Converted dwellings – the conversion of an existing residential dwelling to accommodate two or more dwelling units, without making substantive changes to the exterior of the building. (NB: it is unclear if there will be a limit or not in the NCN)• Adaptive re-use of non-residential buildings, to accommodate new residential dwelling units.• Lot creation – severing one lot into two or more lots.• Infill development – developing one or more new residential units on vacant lots.• Redevelopment – the removal of existing buildings in favour of one or more new buildings that house a greater number of dwelling units than what currently exists.



943 This is the only place in Plan that the term "primary strategy" is used. Concerned that the Plan is not clear that all forms of intensification have primacy over every other Policy in the plan, because of "primary strategy" terminology.

Modified - revised to "important strategy"


943 Concerned whether this Policy is consistent with PPS 2014 s.1.1.3.3, noting that London Plan Policy 943 uses a lot fewer words (PPS states appropriate locations, where it can be accommodated taking into account existing building stock or areas…availability of infrastructure/public service facilities... ensure a balance in public interest with orderly urban growth ...focused but balanced approach to intensification)

No change - policy is consistent with PPS and Planning Act. Provides clarity regarding intent of plan.


943 It is a primary strategy of this Plan to support all of these forms of intensification, while ensuring that they are appropriately located and fit well within their neighbourhood.

Modified - revised to "important strategy"


944 This Policy provides yet another definition for the term secondary dwelling units, and therefore the Policy should either be revisedd to be consistent with the definition in the Definitions section of the plan, or deleted from the OP.



944 Secondary Dwelling units where they are owner occupied #944 are a reasonable Policy for the Near Campus Neighbourhood. Much of the transient housing issue has been addressed with the construction of large projects on Richmond Street and new student housing on campus.



945 _13 How does the City ensure / enforce that secondary dwelling units have an owner occupied primary unit?

No change - licensing, by-law enforcement to ensure.


945 _3 945_3 is counter to the position long-held by the London Housing Advisory Committee that since owner-occupied is a requirement, the Near Campus Neighbourhood requirement is not necessary.

No change - this area has incurred substantial intensification already. There are sufficient opportunities outside near campus neighbourhoods.


946 Converted dwellings should not be subject to site plan approval, given that the Policy states there will be no substantive alterations or additions. revised Policy to require site plan approval only where substantive changes are being made to the exterior.

No change - site plan necessary to address changes to parking, amenity space, and other on-site issues


946 This seems prohibitive and onerous to small-scale property owners. No change - site plan necessary to address changes to parking, amenity space, and other on-site issues


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947 Conversion of non-residential to residential buildings should only require site plan approval and a public site plan process for substantive exterior renovations or significant addition of units that might have parking / traffic impacts.

No change - site plan process is appropriate for adaptive re-use that changes the use of a building.


949 _2 It is nearly impossible to have a rear-lot development that would not have front doors facing at least one rear yard. Policy needs to be reworded to provide greater flexibility. Opportunities for screening, landscaping, etc. can be used to address privacy issues.

Modified - revised wording to include "should be avoided"


949 rear lot/flag shaped lots – is this not intensification? No change - "flag lots" may constitute intensification, intent of policy is to provide for extra consideration for such configurations


951 _2 How are road widenings to be addressed? No change - addressed in Mobility chapter


951 Site Plan Approval can be cost prohibitive with grading and drainage, road widening, surveys, development agreement, legal fees, etc.

Is it appropriate to require the standard site plan approval process for all intensification projects? Would it not be appropriate to allow for the basic or administrative processes for a converted-dwelling where there are no external changes proposed?

No change - scoped site plan processes achieve this objective


954 _1 Policy 954 refers to an Urban Design Brief, but the UD Brief Policy (Policy 150) does not deal with character. It is built form only. If that is what is meant, then just stay "existing built surroundings," otherwise are setting people up for disappointment. Also for Policy 954: how will you measure "sensitivity"? Where are the Guidelines or Parameters? Who reviews them? Will the neighbourhood association have any say? Or is it also just about the built form, which is also fluid?

No change - policies provide direction for Urban Design Briefs for intensificiation proposals within neighbourhood place types


954 _1 Is this appropriate for small-scale projects? Should this apply to all applications, such as an application to create a converted dwelling where there are no external modifications? Onerous requirements such as this may deter ‘mom and pop’ property owners.

No change - see scoped site plan approval process


954 _2 Is 954.2 meant to be the complete list? If not then identify it, otherwise may not be able to use any other criteria. Again with this Policy, what is meant by "surrounding"? Is surrounding the Planning District or some other boundary for 'neighbourhood'?

No change - says "such matters as", indicating the list is not intended to be complete


954 more detailed N’hoods may not clearly understand how it is all going to play out – what is it going to look like when the application comes in? Fine in situations that are City-led projects, but how deal with for privately-led applications.

No change - policies ensure that intensification is appropriate given the neighbourhood context


954 Urban design brief should not be required unless new buildings or substantial exterior alterations are being proposed. Suggest revising.

No change - a scoped site plan approval process is in place for such instances


955 to 959 clarification required as to whether this is a temporary situation (959 does not provide certainty) No change - policies state that it will be reviewed over time


955 to 959 1959 and 1997 Oxford St. West. And the parcel in between 1997 and 2085 Oxford Street West. - one site which is site plan approved for two buildings, but only one has been constructed to date. Any possibility of seeing this site down-graded is a non- starter. Perhaps you can come up with site specific language, or acknowledge that existing site plan approved sites will be allowed to be carried through as currently approved.

No change - property is currently medium density residential, proposed neighbourhood


955 to 959 Need some examples, cases and demonstrations to better understand these policies and tables. Craig Linton has some comments that he will present. What would the effect be of simply deleting this section? Has it been quantified. ??

No change - overlay is the best method to carry over high density opportunities from old to new plan


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955 to 959, Table 11, 598-608 Springbank Drive - "remnant high density residential" lands should have bonusing permitted



955 Should have reference to a means to providing a wide variety of housing choices in all areas of the city, as there are undoubtedly many areas of the city outside of those specifically mentioned in this paragraph that are entirely suitable for high density development.

No change - high-rise development planned to be focused in designated areas, not neighbourhoods


955 It is misleading to refer to these areas as being “from 1989 Official Plan”, as it makes it sound like the locations / designations have been in place and not acted upon for many years. In reality, some of these designations are relatively recent (i.e. – since 2000 for Old Victoria, Andover, RiverBend. Suggests changing wording/ description.

No change - reference is the best label for previous Official Plan


955 reference a means to provide a wide variety of housing choices throughout the city - there are many places in London suitable for high density not shown on Map 3

No change - London plan allows for apartments in many locations throughout the city., including neighbourhoods. Highrise development is planned to be located in designated areas.


956 Last sentence (For these lands, the place type represents the long-term vision for each of these areas to 2035) is worrisome. It sets the tone for the remainder of the paragraphs in this section. It opens the door for eliminating the HD uses from these areas.

No change - intent of policy is to allow for carry-over and also transition to the new plan


956 Map 3 does not appear to be an overlay of anything. No change - designation is an overlay to the place types


956 last sentence is worrisome as it opens door for eliminating high density areas by 2035 No change - intent of policy is to allow for carry-over and also transition to the new plan


957 Not carrying forward all HD designations is problematic. There could be densities allowed under the 89 OP which are not contemplated within the new place type designation. This would have to be looked at on a case by case basis. Point #2 is confusing. Saying buildings of 6 storeys or less are best reflected by the neighbourhood place type – what does this mean? To me, this says, they want to see medium-rise types of development, and could reflect a down grading of density from the 89 OP, and ultimately limit redevelopment potential.

No change - appropriate high density resienital designated areas are carried over in the remnant high desnity overlay


957 cocnerned that not all high density areas are carried forward. There may be areas with high density approved under old plan where only low density can go under LP. Point 2 is confusing - what does it mean that buidlings up to six storeys are best reflected by the neighbourhood place type?

No change - appropriate high density resienital designated areas are carried over in the remnant high desnity overlay


958 _1 1. Not permitting new/expanded HDRD could turn out to be unwise planning in some cases, No change - policies of applicable place type willl apply to lands not in overlay.


958 _2 2. The clause should read “Where lands are identified as Remnant HDR on Map 3, planning and development applications will be approved based on existing rights of use and zoning”. The word “may” allows the city to reject applications based on current use if they do not conform to the new place type designation the subject lands fall into.

No change - comment is not consistent with intent of policy


958 _2 the word 'may' allows planning to reject applications based on use if they do not conform to the new place type. Change to 'will'

No change - applications are considered individually on their merits.


958 _3 3. Eliminate this clause altogether. It simply erodes the notion of respecting existing rights of use and zoning.

No change - policy indicates that the preference is redevelopment in accordance with the place type.


958 _3 delete Policy - it erodes the notion of respecting existing rights of use and zoning No change - policy indicates that the preference is redevelopment in accordance with the place type.


958 _4 4. This clause should read “Development will be permitted…” The use of “may also” erodes the notion of existing zoning.

Modified - wording revised to remove "also"


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958 _4 clause should read "development will be permitted". Use of "may also" erodes the notion of existing zoning

Modified - wording revised to remove "also"


958 _5 5. Why will bonusing not be permitted? This is contrary to the desire for excellence in new developments, regardless of their location.

Modified - policy revised to permit Type 1 bonusing.


958 _5 bonusing should be permitted, exclusion of bonusing contradicts the desire for excellence in new developments regardless of location

Modified - policy revised to permit Type 1 bonusing.


958 _6 6. Eliminate this paragraph entirely. Again, it erodes the notion of what is currently permitted, and effectively pre-supposes a decision on a future ZBA the applicant may apply for.

Modified - wording revised to include standard language as applied elsewhere in plan.


958 _6 delete Policy - erodes notion of of what is currently permitted and pre-supposes the decision of a future ZBA that may be applied for.

Modified - wording revised to include standard language as applied elsewhere in plan.


958 _7 7. Eliminate this paragraph entirely. As in 958_6. Modified - policy deleted


958 _7 eliminate Policy, same as above Modified - policy deleted


958 _8 8. Are you referring to specific policies already established, or are you referring to new policies that may come in as part of the London Plan, Secondary Plans, or the new ZBA? This is confusing. If the reference is to future specific Policy areas, then this erodes the notion of the rights afforded by the existing HD land use.

No change - policy refers to and respects specific policies at the end of chapter that may affect some areas in the overlay.


958 _8 unclear if these policies already exist or will be prepared. If it is a reference to a future Policy it erodes the intent of the existing land use permissions

No change - policy refers to and respects specific policies at the end of chapter that may affect some areas in the overlay.

Urban London Place Types - Neighbourhood - Remnant High Density Residential

958 598-608 Springbank Drive - London Plan will diminish permitted height and density. Active ZBA application on site.



959 emphasis on evaluation - 5 years may not be enough, add evaluation criteria. Note - keep existing zone on lands

No change - plan will be monitored in 5-year review intervals.


959 Eliminate this clause entirely. It allows removal of these existing uses over the course of time which are currently permitted, and should remain in place until the applicant agrees to a change in land use designation or zoning.

No change - comment not consistent with intent of policy


959 Eliminate Policy. Land use permissions should remain until applicant decides to change them by a OPA or ZBA

No change - comment not consistent with intent of policy


960 _2 Change "conforms with…" to "conforms to…" Modified - revised to address comment


960 _3 Subsection mentions "impacts", but none are listed. Suggest listing. Also mentions "surrounding": how far afield is "surrounding" determined to be?

No change - specific impacts are included in Our Tools


960 _4 Refers to "fits within the context of, adjacent properties and the surrounding neighbourhood". How is context evaluated? All that is seen in policies is "form". And again, clarify what's defined as surroundings and what's neighbourhood or planning district.

No change - an urban design brief is required to include a review of character.


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962 to 986 In recent years, Fanshawe added extensively to its on-campus residential capacity, constructing more residential beds than any other Ontario college. Our residential services include extensive operational oversight, security and programs that support a premier learning, student life and career preparation experience for our students. We recognized that neighbourhoods surrounding the College should be a healthy mix of housing types, incuding those applicable to students for long and short-term periods. Residential intensification by means of mid-rise and high-rise forms of development needs to be considered in a proactive, methodical manner so as to preserve and maintain the stability of existing concentrations of low-rise development properties nearby. It must also continue to complement adjacent properties while avoiding any unintended consequences that may result in undesirable changes to their character, functionality and aesthetic quality of these neighbourhoods.



962 to 986 Consider limiting house conversions to a maximum of 2 units in some areas. Could limit conversions west of Western Road/Platt's Line

Modified - converted dwelling policies now apply to central London, where permitted in zoning by-law.


962 to 986 Consider limiting building height along Sarnia Road. Concerns that heights of 6+ storeys will impact existing detached dwellings.

No change - Plan states that 6 storeys is a maximum and may not be permitted in all areas.


962 to 987 Section 3.2.3.2 of current OP not carried forward to new London Plan. No specific policies on dwelling conversions.

No change - covnerted dwellings are permitted, subject to policies re: fit, character, etc.


963 This is the only Policy that actually specifies what a neighbourhood might be, and it points out (under Policy 964) that they are not homogenous. So is concerned that it will be difficult to determine fit within the "context" of the neighbourhood.

No change - focus on character, not homogeneity


964 This Policy provides no certainty whatsoever for those who live there. What is different in each NCN neighbourhood is not defined, nor if planning approach/tools will be consistently applied within each "unique" neighbourhood. If this is the case, then there should be secondary plans for each near Campus neighbourhood area before any intensification is undertaken.

No change - policy indicates that development proposals will be reviewed with sensitivity to specific neighbourhoods


966 Asks how the "balanced mix of long-term and short-term residence" can be tracked (asks if 50:50 is balanced, hopes it isn't. Also asks if "balanced" is per neighbourhood within NCN or across the whole NCN area).

No change - operational issue to be addressed in GNCN strategy review.


966 Asks how it's proposed to "provide strong sense of social connectedness among neighbourhoods"? Suggests this bullet be deleted.

No change - vision developed with community, to be achieved through various means


966 Asks how the engendering of respect for the neighbourhood and all those that live in it can be done through land use planning?



966 Bullet notes "help to recruit the best and brightest student, staff and faculty". Questions if we have any idea as to what draws the best and brightest and if land use planning in Near Campus area has anything to do with that attraction?



966 Notes that "reasonable quiet enjoyment of private property" is a by-law issue, not land use planning.



966 Notes that this is the first time "residential amenity" appears in the Plan. No change - vision developed with community, to be achieved through various means


966 States that "exude vibrancy, culture, creativity, interest and dynamism" are unmeasurable and jargon.



966 Suggests deleting the final bullet in list, suggests that anyone can "enjoy unique culture, entertainment and recreation opportunities relating to higher education institutions", and this is not just for near campus neighbourhoods' residents.



966 Suggests listing some examples of how the NCN will "be diverse and inclusive from many different perspectives"



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966 This Policy should be more flexible and apply only to “significant” or “designated” heritage resources, “where appropriate”. Consider revising this Policy to read as: “(…) Cherish, conserve and protect (significant or designated) heritage resources, where appropriate.”

No change - process for heritage designation in cultural heritage chapter


967 Western continues to be concerned about encouraging higher density and believes that, as a general principle, the near-campus community should not be exempt from density restrictions that pertain to other London neighhourhoods. In recent years, Western has built more residential beds per student than any other postsecondary institution in Ontario. Most recently, we opened a $91,000,000 residence with over 1,000 beds. We have concerns with the suggestion of rezoning the area around the University to allow highintensity housing, which will not provide the kind of extensive supervision and program supports that are an essential component of our residences and that help ensure the safety and academic success of students. Neighbourhoods that surround the University should be a healthy mix of housing types that provide good quality housing for students, while retaining the residential nature of neighbourhoods. Western continues to support the idea of secondary dwellings on properties in the near-campus neighbourhoods, as long as there is also the requirement that the owner live on site.

No change - it is consistent with the vision of the London Plan that high intensity development occur on major corridors and in transit station areas. Intensification within established neighbourhoods should be limited.


967 967 has a number of bullet points, some of which pint in different directions, e.g. 3rd bullet is balanced mix of residential structure types and last bullet is providing affordable housing in appropriate locations. Questions whether affordable housing Policy in NCN is different from other areas of city? If it is the same, then asks why it is repeated here? Also, suggests that the assumption is that all student housing is 'affordable', but asks if a different measure including home ownership is used for "affordable" in the NCN area? Concerned if definitions for this area are different than others.

No change - expresses desire to balance the objectives


968 _ 10 Asks when does development become ad hoc, in the absence of a secondary plan? Suggests that without a secondary plan there is no planned approach for intensification.

No change - policies establish clear direction for appropriate intensification


968 _1 This subsection identifies area has "already absorbed significant amounts of intensification". Questions who defining "significant" and what constitutes significant, and who will be measuring it?

No change - Council makes ultimate determination when an application is submitted. Policies establish considerations for review


968 _9 Notes that conversions are not included along with the mention of "forms and additions". Suggests adding "conversions".

No change - policy relates to form, not land use


968 Policy 968 mentions "preferred forms". The preferred forms are not explained until Policy 970. Suggests cross-referencing policies 968 and 970.

Modified - wording revised to include "as defined by the policies"


968 Title above Policy 968 is "Encourage Preferred Forms of Intensification". Asks why it is only "encourage" when intensification is an identified primary strategy of the Plan?

No change - wording is appropriate


970 Policy 970 starts with "In general, the preferred forms…". Suggests that "in general" is a 'weasel' clause and should be removed.



970 Asks what is the "interior of neighbourhoods". Asks if this includes Connectors? "Interior" needs to be defined.

No change - defined in 976


970 reference to "appropriate Place Type" is pretty meaningless as pretty much all NCN is in the Neighbourhood Place Type, except Institutional. Suggest rewording so intentions are clearer.

No change - NCN includes numerous place types such as Downtown, Urban Corridor, Rapit Transit Corridor, Transit Village, etc


970 Use of "substantial" amount of intensification: substantial is a subjective term. No change - Official plan terms are subject to interpretation


971 Suggests mapping the "appropriate locations for mid-rise and high-rise" in NCN, so that people know better what's coming. Believes some locations, if it was mapped, would prove to be internal to the NCN area.

No change - policy framework clearly shows where and in what form intensification may occur


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972 _1 Questions about neighbourhood connectors - the intensity of development permitted at these locations.

No change - permitted uses in accordance with Table 13


972 _1 Don't understand not having as cap on number of units in converted dwellings? i.e. 2 No change - policies consistent with vision of plan


972 _1 Is the cap of 2 units is a lowering or watering down of the current standards? We're interested in essentially limiting these.



972 _1 Subsection 1 is a new Policy within the GNCN without any direct consultation. Why? This was never discussed over the 3 years it took for NCN OPA nor when before the OMB. Why now?



972 _2 Good, but why are you leaving in mixed-use buildings and tri-plexes in area beyond central London? And why not take out street townhouses as permitted secondary uses on Neighbourhood Streets within the NCN area? Finsbury would not be a good location for Street Townhouses, for example.

No change - street townhouses not permitted on neighbourhood streets in NCN.


972 ensure that the near campus neighbourhood is protected from a Policy in perpetuity that would permit conversion of detached dwellings to multiple units, and define the boundary of the near campus neighbourhood on a map.

No change - NCN area shown on Map 8, some converted dwellings may be appropriate


972 Fix number of units for converted dwellings for Near Campus Neighbourhoods. Modified - maximum is 2 units except in Central London


974 States that this Policy is confusing to the layperson. Questions if "intensity" equals "intensification? If yes then Policy 974 is unnecessary and frankly misleading, as increasing usability increases density of an area or site or property.

No change - intensity does not equal intensification


974 The first half of this Policy is contradictory to the second half (i.e., “refers to the increase in the usability of an existing dwelling (…) but does not include the development of a property, site or area at a higher density.Does this definition only apply to the Near Campus Neighbourhoods?

No change - Intensify is different than intensification. If there is an addition to a building where no units are added it is not considered intensification and density is unaffected, though the intensity increases.


976 _5 Not sure what respite means in this context? Consider rewording. Modified - revised to address comment


976 _6 How does one demonstrate no negative impact on amenity? In other places it's referred to as "outdoor amenity spaces", and in Policy 966 it includes "character". (But that is in Vision so is it or is it not part of specific policies?)

No change - amenity may be indoor or outdoor


976 _7 This Policy should be more flexible and apply only to “significant” or “designated” heritage attributes and resources, “where appropriate”. How do you compare adjacent sites? What are the criteria? Consider revising this Policy to read as: “(…)The proposal demonstrates that all (significant or designated) heritage attributes and resources of the subject site or adjacent sites are conserved, where appropriate.”



976 _8 How is "positive and appropriate precedent for similar development proposals" going to be determined? Will be subjective each time. Should be different for each Near Campus area as you have earlier said they are not homogenous. Therefore suggest saying "...similar locations within the area."

No change - policy includes "similar locations"


976 This Policy imposes mitigation measures on residential development on for areas within the near-campus neighbourhood place type. These measures are not imposed on other residential place types. Could the City please provide some land use planning rationale for imposing this condition?

No change - based on detailed planning study and comprehensive public consultation and subsequent OMB Hearing. Information provided to Province.


979 _6 Should allow the variance to be heard on its merits, but they will be permitted if other Policy exists that conforms (i.e., Old North 40m ROW width).

Modified - revised language to "discouraged"


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982 Currently, Fanshawe's campus master planning considers natural and landscaped environments for outdoor gatherings and interactions within Campus lands. The College is already experiencing space and capacity challenges on its current campus lands to build the facilities necessary to deliver its educational, research, athletic/recreational and residential requirements. As a result, outdoor elements, such as urban parks, are, by operational necessity, a lower priority.

No change - this is understood


982 Outdoor areas to congregate and interact including plazas, squares and forecourts are key elements of campus planning, including on the periphery of campus adjacent to near-campus neighbourhoods. Western’s campus however, has a finite amount of space and we are already experiencing space and capacity challenges to build the kind of teaching, research and residence facilities that need to be located on campus in the future. For that reason, more large-scale elements, such as parks and urban parks, are not a priority for the limited buildable land available within the University.

No change - this is understood


985 _2 Asks which other "area specific policies" will apply? Does this mean the area specific ones from Bostwick East (Policy 987) to Woodfield (Policy 1054)? Also confusing is Policy 926.2 which provides for area-specific neighbourhood policies or guidelines that may be prepared. In this case does area specific (not in Caps) mean "area specific neighbourhood"?

No change - reference is to speciufic policies at the end of the Neighbourhoods chapter


985 Policies 985 and 986 in the London Plan note that the NCN and more specific policies "will" take precedence over general policies of the Plan. Note that this is a change from the current OP where they are written as "shalls" instead of "wills".

No change - use of will and shall is explained in first chapter


990 No longer relevant as a result of OPA, ZBA and SWAP. Suggests removing. Modified - policy deleted


994 Southdale Road has been reconstructed in the Bostwick East planning area so Policy is no longer relevant. Suggests removing.



1006 and 1008 Old Victoria Community Planning Area - Policies1006 and 1008: These policies are especially commendable.



1021 Policy 1021: Suggests applying the "Village Commons" concept to all areas of Neighbourhood Place Type.

No change - refer to City Design policies


1030 to 1031 Special Policies for Uplands North area should provide for a main street form of commercial/mixed use areas that promotes the New Urban ideas in the previous proposal for Applewood.

No change - policies carried from previous plan, which were developed through secondary plan process


1031 Uplands North Community Planning Area- As a university, Western places a high value on conservation as can be seen with the recent re-zoning of environmentally sensitive areas of Western’s Gibbon’s Lodge property. Gibbons, however, remains private property and the University has concerns with the Plan’s proposal to secure required easement agreements along the Sun-Canadian Pipeline easement.

No change - policies carried from previous plan, which were developed through secondary plan process


1033 to 1039 There are also some specific policies for some areas within the NCN such as for St. George Grosvenor (Policy #1033-1039) as well as the NCN policies themselves (starting at 962 primarily).

No change - plan explains inclusino of specific area policies


1038 References to reconstruction of St. Mary's Hostpital are not required as it no longer applies. Modified - revised to address comment


1038 We may not need the policies for the offices relative to St. Mary’s hospital renovations? Modified - revised to address comment


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1040 to 1048 Talbot Mixed-Use Area - The problem of irresponsible property investment interests jeopardizing the health and security of students and long-term residents will only intensify by permitting the conversion of housing stock into offices along the residential streets making the area more vacant at night year round, putting people at risk and paving over the last of the backyards creating a harsh and less attractive neighbourhood for those individuals that prefer to live in the core.

No change - Near campus neighbourhoods strategy addresses these concerns


1040 to 1048 Talbot Mixed-Use Area - This neighbourhood has a high ratio of renters, more so than any other area within the Richmond Row corridor. By eliminating housing stock, the city also eliminates housing choices for those individuals that want to live in the core, have no car, do not want to live in a highrise and cannot afford private housing. It pushes low income people out of the core. Referred to ‘gentrifying’, larger cities have learned the negative consequences of ‘roping’ or pushing out low income folks into areas that are not serviced and isolated.

No change - Near campus neighbourhoods strategy addresses these concerns


1040 to 1048 Talbot Mixed-Use Area - If your goal is to convert this neighbourhood to a commercial area, then state that upfront.

No change - policies proivde a balance and mix of opportunities


1040 to 1048 Talbot Mixed-Use Area - Over the years, the City has allowed the original historical city to deteriorate by chipping away at its historical housing stock and failing to ensure mixed demographic housing stock. Green amenities have paved for parking, stripping it of all elements that soften an area making it more attractive by a larger demographic.

No change- general commentary


1040 to 1048 Talbot Mixed-Use Area - The neighbourhood is changing by it remains primarily a collection of student ‘rooming houses’ dominated by investment property companies uncommitted to the long-term health of the neighbourhood.

No change- general commentary


1055 The title 180 Anne St. references Mill st. in the text? Modified - revised to address comment


1060 Is this separate from 1059? Modified - policy deleted

Urban London Place Types - Institutional

1076 Whole Chapter There is no definition of an institutional use. It is unclear whether a government office or police administration/operations uses would be considered "institutional". A definition should be provided that is broad enough to include various puiblic uses including hospitals, polic stations, government offices, etc.

No change - refer to institutional place type chapter


1076 whole chapter ADD a complete section on Non- Medical/ Post-Secondary Institutions, such as Places of Worship as these are often not Neighbourhood oriented. Change wording ‘churches’ to ‘places of worship’. Consider also adding ‘Not For Profit Sector’.

Modified - wording changed to places of worship, not for profit sector not added as listed uses are examples only


1079 Add Fanshawe College to Policy #1079 as part of the Rapid Transit Corridor. Map 1 City Structure Composite could realign the easterly terminus of the Rapid Transit Boulevard through the former London Mental Health Lands ending near the main entrance of Fanshawe College. The policies propose integration with the surrounding community. While a sound idea, the institutions themselves, hospitals, universities and colleges being “private” entities, resist the integration intended in the policies. Gridiron streets and connections into the neighbourhood run contrary to the Near Campus Neighbourhood thesis to direct students to large scale dormitory communities instead of integration.

No change - list is not intended to be comprehensive


1082 _6 What does this Policy mean? For e.g., Brescia is not integrated from an Urban Design perspective. What would have been different if its recent application was done under the new Plan - anything?



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types - Institutional

1082 The principles for realizing the vision for the Institutional Place Type (1082) has been and will continue to be important, including in particular: allowing for change and evolution of institutional lands over time; providing civic infrastructure that facilitates and accommodates institutional growth and development; creating strong pedestrian, bicycle and transit connections to/from institutional places; protecting instituional lands for future growth and expansion; and creating amenities nearby to make institutions desirable places to learn, work, live and play.



1082 The principles for realizing the vision for the Institutional Place Type are well founded, including protecting institutional lands for future growth and expansion and allowing for change and evolution over time that are in the best interest of the City and Western.



1083 to 1085 A complete and thorough understanding of the full extend of Policy for permitted uses (1083), intensity(1084) and form(1085) for institutions will be important for longer-term campus master planning purposes. Policy statements in sections 1083 to 1085 relating to the application of permitted use, intensity and form appear to be either too vague, too restrictive or generally inappropriate for consideration with current applications on existing campuses.


City Building Policies - Institutional

1083 Since churches are not all doing the same thing, I hope there can be some flexibility within the London Plan to clearly allow for this range of facility need. I have spoken a little on this within the LSA comments, especially on Institutional Placemaking where a clearer approach or discussion is needed for smaller to mid-sized institutional, religious and not for profit users and how they fit into neighbourhoods. Also, since we are trying to be inclusive of all, “Cultural” is not the proper umbrella to contain religious uses.

No change - places of worship permitted in Neighbourhoods and other Place Type

City Building Policies - Institutional

1083 On a broad note concerning worship facilities, the day of the small neighbourhood parish church is long gone (no parking!) and many are being sold and repurposed or demolished. One model replacing this has been the larger “big box” facility at the periphery of the city or even in the industrial lands (needing up to 8 acres.) Since affordability is a problem and large blocks of land are hard to find, this model is becoming harder to sustain. I see, at least partially within the Evangelical sector a return to creative multi use facilities that re-engage at the level of neighbourhood in new ways.

No change - trend in places of worship development noted for information


1083 The above-ground parking structure permitted in clause six is potentially too restrictive in the University context in that many of our roads, including those internal to the campus, could be considered a “Main Street”. Also, as worded, the requirement for screening with architectural elements is too open to interpretation.

No change - policy is consistent with vision of plan


1084 _3 Again using Brescia example, what would the height transition compatible with surrounding neighbourhood and existing development look like for a newly designated Institutional area?

No change - compatibility determined based on context


1084 Understanding the full extent of intensity on all University property is important for long range campus planning. We find clause two on permitted height and intensity to be too broad, while clause three is too prescriptive to be applicable to a university. We suggest these two clauses be removed and the City reverts to current city zoning regulations.

No change - policies are consistent with the vision of the plan


1085 _1 This Policy refers to UDPRP reviewing applications visible from public streets. "Public Street" is not defined and term is not used in the Plan. Reference to neighbourhood streets, Connectors, etc. but not "public streets". Is this same as "outside campus"?

No change - term is part of plain language approach. Intent is that only development visible from a public street require UDPRP input


1085 _1 The word "all" is a strong word - there will likely be an exception. Modified - revised to allow flexibility


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types - Institutional

1085 _8 States that “Heritage buildings will be preserved”. Does not adequately define what constitutes a “heritage building”. Suggests revising wording to state “Designated heritage buildings will be preserved.”



1085 The suggestion in clause four that the tallest buildings should be concentrated around the core of the district is not in keeping with the way in which buildings are laid out on campus. Also, the topography of campus lands, including the river, makes it impractical to have a grid system within the University campus. A grid-based internal road network wouLd also not be workable for all the University land holdings identified, including the Advanced Manufacturing Park.

Modified - policy 1085_4 deleted


1085 Policy 1085: New subsections suggested: 1. "Natural Heritage will be preserved." ; 2. "Food forests and other food production will be encouraged"; and 3. "Other ecosystem services will be enhanced through flood mitigation, biodiversity gardens and pollinator gardens, etc"

Modified - policy added regarding a high standard of tree planting


1093 This Policy imposes a minimum distance separation distance on methadone clinics and other particular land uses. Could the City please provide some land use planning rationale for imposing this condition?In the absence of land use planning justification, this would appear to be in conflict with the Human Rights Code.

No change - policy based on detailed planning study and comprehensive public consultation, and subsequent OMB hearing. Information provided to Province.


1096 Why is the Western Fair Association exempt from policies about building form, and policies applying to development applications?

No change - Western Fair district is not exempt from City Design policies. This section proivdes additional policies to augment City Design section


1096 Policy 1096: Asks why is Western Fair Association exempt from policies about building form and policies applying to development applications.

No change - Western Fair district is not exempt from City Design policies. This section proivdes additional policies to augment City Design section


1097 Concept understood but how would it function when the Fair is on? What would be the Fairs position on this?

No change - building orientation does not interfere with fair operations


1098 Policy 1098: Asks why building form policies and policies for development applications do not apply to Correctional and Supervised Residences.

No change - policies do apply


1099 The zoning by-law will impose minimum separation distances between these types of facilities. Could the City please provide some land use planning rationale for imposing this condition?In the absence of land use planning justification, this would appear to be in conflict with the Human Rights Code.

No change - policies result of OMB hearing, carried over from current plan

Urban London Place Types - Industrial

1100 Whole Chapter Industrial Place Type: suggests not separating "Eco-Industrial" development and "Industrial" development, suggests all should be ecological development.

No change - not consistent with chapter


1100 Whole Chapter does the term ancillary and accessory mean the same thing? - add to Glossary to differentiate. Modified - revised to address comment


1100 Whole Chapter would hope most of the lands identified are pre-zoned to allow the industrial uses. May have some exceptions for Commercial Industrial Place Type.

No change - place types consistent with industrial lands development strategy


1100 Whole Chapter 1523 Bradley Ave - As outlined in a previous submission (June 9, 2014) on the proposed OPA to expand the Urban Growth Boundary expansion for further industrial uses development (File No. O-8014), the owners of 1523 Bradley would like some assurance that the properties along Bradley that area already within the Urban Growth Boundary will be provided, within a reasonable time period, with full municipal services (expecially sanitary sewers) that will be needed to develop the area in accordance with the proposed Light Industrial Designation"

No change - Urban Growth Boundary consistent with recent studies


1100 Whole Chapter Light Industrial - Should have common references on each map - clear to orient people. Modified - maps revised to improve clarity


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types - Industrial

1100 Whole Chapter Other successful cities mix hwy retail surrounded by hwy industrial @ Hwy 401 interchanges. Why isn't this Place Type configuration in The London Plan?

No change - place types consistent with industrial lands development strategy


1100 Whole Chapter Industrial Development example: "Ancillary" term should not be taken out of context - should allow for headquarter office. Transit should also be tied into Policy.

Modified - revised to clarify ancillary. Transit -supportive is addressed under the form policies for all industrial Place Types


1103 Policy 1103: Suggests that Light and Commercial Industrial be integrated with shopping, institutional and residential. Believes it's only way to become a car-free city by 2035.

No change - comment is not consistent with intent of policy


1106 Policy 1106 states that it is appropriate to separate light industrial uses from heavy industrial uses but not with other uses, unlike Policy 1105. MOECC does not understand why 1106 only speaks to potential incompatibility with heavy industrial uses and Bullet 1 of Policy 1110 only to light industrial uses. MOECC does appreciate that Policy 1109 and 1110 reference the Ministry's D series guidelines however the earlier clauses set the stage.

No change - addressed elsewhere in the Plan


1107 How will these lands be accounted for? Will they be a part of the industrial or commercial land supply? If the use is not commercial, is it industrial and vise-versa? RECOMMENDATION: There are questions regarding the intent of this Policy as it would appear that these uses should either be considered “commercial” or “industrial”.

No change -


1108 _11 Does north-south connection to east/west extremities of city mean a ring road? Or road connections? There is almost no industrial on west side, so what is the purpose? The kind of industrial in Hyde Park (Policy 1142) is not truck time sensitive (office-related light industrial).

No change - intent is to support flow along east-west connections


1108 _15 How will these lands be accounted for? Will they be a part of the industrial or commercial land supply? If the use is not commercial, is it industrial and vise-versa? RECOMMENDATION: There are questions regarding the intent of this Policy as it would appear that these uses should either be considered “commercial” or “industrial”

No change - commercial industrial lands are a hybrid commercial/light industrial place type. They will not be considered employment lands per the PPS.


1108 _16 The City has now prepared an Industrial Land Community Improvement Plan. This Policy should reflect that the CIP can only be used for the provisions outlined in the Planning Act and cannot be used for greenfield development. RECOMMENDATION: Policy needs to reflect that financial incentives cannot be used for greenfield development.

No change - policies are general in nature


1108 _9 MTO may be unable to support any plans for theming segments of the Highway 401 and 402 corridors, including the establishing of public monuments and public realm enhancements. Any such aesthetic improvements will require the approval of the Ministry of Transportation in accordance with their policies.

Modified - revised to include "in accordance with MTO regulations and guidelines"


1108 Policy 1108: Suggests a new subsection mentioning protection of existing railway corridors for strategic transportation role to support industrial activities and that City recognizes future need for new spur lines connecting to existing trunk railroads



1109 Industrial uses from incompatible uses. MOECC staff fully supports this objective. It is recommended that Bullet 8 of this clause recognize that the D series methodology can also be used to locate new incompatible uses away from permitted heavy industrial uses.



1109 Policy 1109: Railways as permitted and essential uses within Heavy Industrial Place Type should be noted, notwithstanding they are mentioned in Policy 1313 (uses permitted in all Place Types).

No change - railways permitted in all parts of City


1109 “ancillary” (office) versus “accessory” (retail) … what is the difference between ancillary and accessory?



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1109 Does not mention outdoor storage – probably should Modified - revised to address comment


1109 1. Speaks to uses that have impact such as noise, odour etc. whereas 2. Says permitted if they have a low level -- they conflict

No change - policy 2 applies where there is low sensitivity


1110 _3 Self-storage was just removed from industrial areas? Is this a case by case by request? Modified - removed from light industrial place type


1110 1523 Bradley Ave - Significant Light Industrial areas in southeast London are located adjacent to designated Freeways (Highway 401) and Expressways (Highbury Ave, Veterans Memorial Parkway), as indicated on proposed OP Map 5. Figure 2, which is an excerpt from Map 5, shows the close proximity of the 1523 Bradley property to Highbury Avenue and Highway 401. Properties with good highway visibility in strategic locations on entry roads into London could be considered as potential "gateway" development properties for London. It is suggested that there should be some additional flexibility in the LIight Industrial designation to permit a wider range of uses for "gateway" sites. The following Policy is proposed as an addition to 1110 - Permitted Uses in LIght Industrial Place Types. "Properties within the LIght Industrial designation that are in strategic locations on entry roads into London and have good highway visibility may be developed with a wider range of commercial and institutional uses than would otherwise be permitted ina LIght Industrial area. The range of permitted uses and scale of development will be determined on a site-specific basis, and is intended primarily for uses with a significant regional presence that would benefit from a gateway location. The Light Industrial policies for Innovation Parks in 1111_ will also apply to gateway areas.

No change - Light Industrial approrpaite for the site.


1111 _5 Mini-storage should not be permitted in Innovation parks – warehousing/logistic should be considered

Modified - removed from light industrial place type


1112 There are questions about how these lands will be accounted for? Will they be a part of the industrial or commercial land supply? If the use is not commercial, is it industrial and vise-versa? RECOMMENDATION: There are questions regarding the intent of this Policy as it would appear that these uses should either be considered “commercial” or “industrial”.

No change - commercial industrial lands are a hybrid commercial/light industrial place type. They will not be considered employment lands per the PPS.


1113 _5 Policy 1113.5: asks why residential is not permitted in the Commercial Industrial Place Type. No change - creates land use conflicts per the PPS and D-series guidelines


1113 A number of the commercial industrial uses permitted have as much potential impact upon nearby sensitive (incompatible) land uses as light industrial uses and yet there is no recognition of the possibility of adverse impacts and no corresponding requirement for separation or mitigation measures which would flow from use of the MOECC's D Series Guidelines. MOECC questions, would a scrap metal operation be considered a Commercial Industrial use? It is noted that places of worship may be located within this place type (Policy 1112). Places of worship would be considered to be sensitive uses.



1115 _2 Policy starts with "It is an important goal of this Plan": Asks whether this is a more important goal that other goals of the Plan? Asks how tree planting presents a positive image when people are driving (notes PenEquity will take down existing woodland that will take 20 years to regrow through plantings). Suggests deleting first sentence and just start Policy with "Development adjacent to these corridors..."

No change - intention to present a positive image is important


1116 Policy 1116: suggests new bullet stating "Placing industries so that waste heat of bigger companies can be used to heat other buildings."



1116 Policy 1116: suggests that in first sentence after "development of new industrial parks" the following is added "and the renovation of old industrial parks."



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1116 Nice Policy but there is no mention of incentives or requirements. As such, asks if this is just a "will be considered" type of Policy?

No change - use of "will" indicates a requirement.


1118 How are these lands accounted for in the City’s land supply? The PPS only permits a 20-year land supply of designated uses. RECOMMENDATION: How are these lands accounted for in the City’s land supply? The PPS only permits a 20-year land supply of designated uses.

Modified - revised to clarify that removal of industrial lands would be as per the PPS


1118 Wow, brownfield sites are out and greenfield sites are in for industrial uses. No change - intent is to allow for transition where appropriate


1118 Suggest you add “...redevelop for non-industrial and/or Less intense Light/Innovative industrial Modified - revised to address comment


1120 This clause appears to require application of MOECC's D Series Guidelines for Industrial Uses to consideration of new industrial uses establishing within transitional industrial areas. MOECC presume this requirement is founded on the belief that at some point in time all existing industrial uses/properties will be converted to other (sensitive uses); otherwise why would one apply the guidelines which were developed by the ministry to address potential adverse impacts between sensitive and industrial uses.

No change - D-series guidelines to allow for transition over time


1121 & 1122 Why not include protecting NH features and functions, including woodlands, unless the intent is to have them in public ownership? There is nothing in the Plan regarding coexistence and protecting and conserving them as Policy of the City. Should try to avoid situations like Centennial Windows, Great Lakes Copper and General Dynamics.

No change - Natural heritage policies address natural heritage features


1121 This Policy needs to reflect Policy 1.1.3.8 of the PPS in that the expansion of the Urban Growth Boundary can only occur through the demonstration of need through a comprehensive review and other criteria.



1121 Similar to the comment above pertaining to the Shopping Area Place Type, the justification requirements outlined in Section 2.3.6.1 (b) of the PPS (2014) are not reflected in the list of criteria for evaluating expansions of the Industrial Place Type. RECOMMENDATION: OMAFRA recommends that a 5th bullet be added to this section which states that: where the expansion is proposed in the Farmland Place Type, it shall only be permit where all of the following are demonstrated:1. the land does not comprise a specialty crop area;2. the proposed use complies with the minimum distance separation formulae;3. there is an identified need for additional farmland to be designated to accommodate the proposed use; and4. alternative locations which avoid the Farmland Place Type have been evaluated, and where no reasonable alternative locations exist, a location in the Farmland Place Type with lower priority agricultural lands was selected.


Urban London Place Types - Open Space

1143 (New 701)

Whole Chapter LP should include a natural heritage place type, it should not be included in Open Space. Modified - revised to improve clarity. The Green Space Place Type encompasses many areas that make up our Natural Heritage system . While they share the same Place Type on Map 1, the features are individually identified on Map 4 and there are specific policies governing these individual natural heritage features in the Natural Heritage Chapter.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types - Open Space

1143 (New 701)

Whole Chapter Protection of natural heritage should be the first Policy/priority in the proposed natural heritage place type . Restrict use of natural areas to passive recreation only. If the additional place type is not wanted add the Policy to the natural heritage section of City Building Policies

No change - The Green Space Place Type encompasses many areas that make up our Natural Heritage system. While they share the same Place Type on Map 1, the features are individually identified on Map 4 and there are specific policies governing these individual natural heritage features in the Natural Heritage Chapter.


1143 I(Now 701)

Whole Chapter Weakness - no map for designated ESA. No change - Green Space Place type includes all ESAs within the City of London. ESAs are shown on Map 4..


1143 (Now 701)

Whole Chapter No Adelaide Street through ESA, so rename Adelaide Street South to confirm no connection. No change - Adleaide Street does not extend through ESA.


1143 (Now 701)

Whole Chapter Food Vendors along Thames Valley Parkway. No change. - Policy 706 identifies permitted uses.


1146 (Now 704

Policy 1146: Suggests that "Natural Heritage Land" and "Natural Hazard Land" be put into a separate Place Type called "Natural Heritage Place Type"

No change - The Open Space Place Type encompasses many areas that make up our Natural Heritage system. While they share the same Place Type on Map 1, the features are individually identified on Map 4 and there are specific policies governing these individual natural heritage features in the Natural Heritage Chapter.


1147 (Now 705)

_3 Consider providing flexibility to accommodate linkages “where appropriate.” Consider revising this Policy to read as, “Provide for linkages among open space areas throughout the City, where appropriate.”

No change - In an increasingly fragmented urban London landscape the City's vison is to increase linkages/connectivity. Language is consistent with natural heritage and parks and open space policies.


1147 (Now 705)

_5 Policy 1147, 5: The emphasis in this Policy should be on protection of significant natural features and ecological functions. Therefore, the wording should be changed to read as two sentences to make this clear - “Enhance the accessibility of publicly-owned open space areas, where there is no danger to public safety. Restrict accessibility where significant natural feats and ecological functions need to be protected.”

No change - appropriate access and use of natural areas addressed in natural heritage policies.


1147 (Now 705)

_7 It should be noted that for some natural heritage features and areas, it is the responsibility of the Ministry of Natural Resources and Forestry to confirm the boundaries and evaluations, including wetlands, habitat for endangered species and threatened species, and ANSIs. Therefore, City council would not be responsible for recognizing these provincially significant natural features. RECOMMENDATION: MNRF suggests the following revisedd statement:Provide for the protection of natural heritage features and areas, which have been identified, studied and recognized by Council as being of city-wide or regional significance, and/or by the Ministry of Natural Resources and Forestry as provincially significant.



1148 (Now 706)

_1 & 484 Not supportive with the inclusion of Environmentally Significant Areas (ESAs) in the “Open Space Parks” place type. This is inappropriate as ESAs are not parks, and need very different planning and protection than parks. Please create a separate place type for ESAs to give them the recognition and protection they need.

No change - The Green Space Place Type encompasses many areas that make up our Natural Heritage system . While they share the same Place Type on Map 1, the features are individually identified on Map 4 and there are specific policies governing these individual natural heritage features in the Natural Heritage Chapter.


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1148 (Now 706)

_1 & 484 On the whole, I am pleased with The London Plan and its “green” goals. However, I am not happy with the inclusion of Environmentally Significant Areas (ESAs) in the “Open Space Parks” place type. This is inappropriate as ESAs are not parks, and need very different planning and protection than parks. Please create a separate place type for ESAs to give them the recognition and protection they need.



1148 (Now 706)




1148 (Now 706)




1148 (Now 706)




1148 (Now 706)




1148 (Now 706)




1148 (Now 706)




1148 (Now 706)

_1, 1153, & 217 Need to ensure consistence with the term "will". Do pathway connections or natural resources/heritage have primacy? See sections 1148_1, 1153, as compared to Policy 217 (Active Transportation)

No change - policy 1153 speaks to linkages as part of open space system. 217 addresses linkages with mobility. No primacy required


1148 (Now 706)

_2 What “corridors” is this Policy referring to? Modified - reference to corridor removed.


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1148 (Now 706)

_5 Policy 1148.5: suggests adding the following use to list of permitted uses: "urban gardening"; and after "municipal services" add "including stormwater management, …"



1153 (Now 711)

& 1154 & 1160 Policies 1153, 1154 and 1160 are especially commendable. No change - indicates support for the Plan.


1153 (Now 711)

As mentioned within MNRF comments regarding the PPS requirement to identify a natural heritage system and including linkages/corridors. RECOMMENDATION: The MNRF recommends that the City consider identifying the potential linkages listed within this Policy on a map. This would help with identifying a natural heritage system, including corridors and linkages as per PPS Policy 2.1.3.

Modified - revised to incorporate text in Policy that points to Natural Heritage map, which shows "Potential Naturalization Areas".


1153 (Now 711)

Policy 1153: Suggests new final sentence related to the suggested new section on "Ecological City": "It may also occur through such initiatives as backyard and boulevard naturalization"

No change - That is dealing with private property where control is limited. This would be more appropriate under Stewardship in the Natural Heritage Section of the London Plan.


1153 (Now 711)

This Policy should be revised to be more flexible. Consider revising this Policy to read as, “Linkages will be provided between open space areas, where possible and appropriate,(…)”

No change - policy includes "where possible" for flexibility


1160 (Now 718)

Policy #1160 should read: ….and any anthropogenic disturbance of soil, destruction, removal or injuring of trees


Urban London Place Types - Environmental Review

1162 (Now 722)

Need to compare the proposed Map 4 to the existing Schedule B-1. Current LP schedules are not of a quality sufficient for detailed review and analysis.

No change - electronic version of the maps are now able to be scaled, and hard copies are available for review and analysis through Planning Services.

Urban London Place Types - Environmental Review

1163 (Now 723)

The policies in the Environmental Review section look good. (Note: some spacing between words needs amending. e.g. in Policy 1163.)


Urban London Place Types - Future Growth

1171 (Now 1080)

Whole Chapter This place type should be located outside the urban boudary instead of 'agriculture'. Agricultural development adjacent to the boundary should be carefully considered and policies should be implemented to ensure this review is completed.

No change - Future Growth Place Type is for lands within the urban growth boundary. City must also ensure the longterm preservationof agricultural lands, in accordance with provincial policy.

Urban London Place Types - Future Industrial Growth

1171 (Now 1080)

Whole Chapter While Peel’s approach to protect employment through SISA is different from that of Halton, the intent and the attempt to protect is consistent with Halton’s proposed approach. Where it differs is the way the areas are represented on a map (Peel’s SISA is represented as a conceptual corridor whereas Halton’s strategic employment areas are depicted as an overlay on a map). The conceptual nature of Peel’s SISA policies is consistent with PPS2014 policies 1.1.2 and 1.3.2.4 .

No change - commentary on other municipal approaches


1171 (Now 1080)

There are questions regarding the planning merits of such a place type, especially when dealing with settlement boundary expansions. If the lands have been justified, some level of understanding of where the locations of these types of uses should be known.

No change - this Place Type is similar to the intent of the Urban Reserve designation of the current Official Plan. It is intended to ensure properly and orderly development through a comprehensive review. A secondary plan will determine the appropriate Place Type uses.

Urban London Place Types -Future Growth

1180 (Now 1089)

If the lands have been justified through a comprehensive review, some level of understanding of where the locations of these types of uses should be known.

No change - while the lands have been identified for Future Growth, the specific Place Types will be determined as part of a comprhensive planning exercise such as a Secondary Plan.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types - Future Growth

1182 (Now 1091)

For the purposes of reviewing future planning applications, new Future Growth Place Types will be treated as an urban land designation and where these designations are proposed in the agricultural area the proposal will be subject to Policy 1.1.3.8 of the PPS (2014). As currently drafted, the Plan does not indicate that these criteria will need to be met for new Future Growth Place Types. RECOMMENDATION: OMAFRA recommends that the City either cross-reference the requirements found in Policy 114, Pg. 49 with respect to UGB expansions, or alternatively, include those same Policy requirements here in order to apply them to new Future Growth Place Types.

No change-Future Growth is an Urban Place Type, and does not apply to Rural London or to the Farmland Place Type.


1186 (Policy deleted)

Map 4 It does not appear that the Jackson District is shown on Map 4 as a Future Growth Place Type.Conversely River Bend South is shown on Map 4 but there is no accompanying text

Policy deleted-Jackson North lands designated Neighbourhood Place Type



Jackson District North - Clarify/establish priorities for policies in the Plan - eg. Infrastructure over other policies.




High density development will impact the environmental area by Meadowlily Woods and diminish experience of people who enjoy it. Designations do not meet setbacks/buffers in policies 337-340. Lands south and east of this area are more appropriate for high density.




Reminder that desgination of Meadowlily as a Cultural heritage landscape was approved in principle by Council on January 28 2014. This and the associated studies should be completed prior to desgination of the area.




Woodlands, environmentally significant areas, and cultural heritage resources all support the view that development is unwarranted and unwanted in meadowlily.


Rural London Place Types 1189 (Now 1097)

Whole Part PLC is very surprised and disappointed that a comprehensive study (2004-2009) will be modified significantly - size of area increased substantially. No opportunity for public consultation, land set aside has had no additional users locate there that were not known and planned for in 2009, PLC not aware of any known demand for future use of the current zoned area. REQUEST to put this area into a separate category when a process occurs that is examining the need for significant change.

Modified - area revised to include only city-owned lands


Whole Part Opportunity to balance/ transition Ag lands to industrial in future. Need to balance the protection of Ag lands as interim use, but also allow for development as Industrial as a future use. (e.g. east side of City)

No change - Agricultural lands not a transitional use. Farmland areas outside the UGB intended to support longterm agriculural uses.


Whole Part Identify the differences from the existing OP policies to the new Plan. Of note would be the updating of the OMAFRA MDS guidelines update.?

Modified - policies modified as required to be consistent with the Provincial Policy Statement.


Whole Part The Rural London - Individual Private Servicing Policy should be incorporated into the London Plan

Modified - revised Civic Infrastructure polices to incorporate private individual servicing policies for Rural London Place Type.


Whole Part Why are the lands on 2135 Highbury received a special private servicing Policy of its own? No change - Specific policy for 2135 Highbury Avenue has been carried over from the current Official Plan.


Minor grammatical changes proposed. RECOMMENDATION: OMAFRA recommends that Policy 1189 be modified to state:“Over 40% of the City of London is comprised of rural comprising lands located outside of the Urban Growth Boundary where farmland and farm-related activities are intended to be the predominant uses. Rural London has its own unique function and distinct identity, defined by both its integral connections to, and its interface with the urban portions of the City and London’s neighbours in the region.”



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanRural London Place Types 1191 (Now

1100)Minor grammatical changes proposed. RECOMMENDATION: “Similar to the approach taken for the Urban London Place Types, the Policy for each place type begins with a vision, and then explains the guiding principles for how we will realize this vision. Each Place Type chapter then establishes the range of permitted uses, allowed intensity of development, and the envisioned built form within that given place type. This connects with many of this Plan’s priorities, to protect the agricultural land resource and maintain the viability of farming, and recognize the need for a long- term commitment to sustain farmland within these areas so that farmland it may continues to make a significant contribution to London’s economy. The policies in this section of The London Plan also recognize the rRural nNeighbourhood areas which historically developed as farm service centres and which currently exist as small residential communities with a mix of small-scale commercial uses. The rRural Nneighbourhoods are not regarded as centres for growth, and therefore, development within these areas will be limited to uses that can be accommodated on an infill basis.”

Modified -incorporate revised wording as recommended.

Rural London Place Types - Farmland

1195 (Now 1103)

Whole Chapter Suggest new Policy under "Public Realm": Bicycle lanes should be added for Regional Connectors.

No change - City Structure Plan includes future path connections.


1195 (Now 1103)

Whole Chapter Concern over increased traffic conflicting with rural farm equipment. No change - Policy 1150 address role of Rural Thoroughfares and Rural Connectors.


1195 (Now 1103)

Whole Chapter Londoners have a responsibility to preserve as much Class 1 agricultural land as possible and also improve the natural characteristics of lands converted to urban over the last 200 years.



1195 (Now 1103)

The London Plan does not use the PPS term ‘on-farm diversified use’ under the permitted uses section, but instead uses the term ‘Secondary Farm Occupation’. In order to be consistent, this terminology should be reflected in this vision section. The proposed recommendation relates mostly to consistency of language. In addition, there is a minor grammatical change proposed. RECOMMENDATION: The last three sentences of section 1195 should be modified to state:“Farmers and the farming community, the long-term protection of agricultural land, a healthy and vibrant rural economy, and rural quality of life will all be protected for the long-term. Agricultural uses, agricultureal-related commercial and industrial uses and on-farm diversified uses secondary farm occupations will be permitted. Farms will be permitted to sell local produce and house full-time farm labour additional family and workers on-site to maintain the farm’s vitality.”

Modified - revised to address comment. No change to on-farm diversified uses.


1196 (Now 1104)

Lands outside of classes 1, 2, and 3 are still protected as its part of a prime agricultural area. The Policy should reflect this as the lands outside of the Urban Growth Boundary are considered to be part of a prime agricultural area.

Modified - revised to incorporate recommended wording


1196 (Now 1104)

This Policy seems to confuse prime agricultural area, and prime agricultural land. Ministry staff suggest a minor rewording to clarify this important distinction. RECOMMENDATION: OMAFRA recommends that Policy 1196 be modified to state:“The Farmland Place Type is the prime agricultural area of London land which consists of prime agricultural land (Canada Land Inventory Classes 1, 2, and 3 soils) and associated Classes 4 through 7 soils that will be protected and maintained as the farmland land base for London. It to supports a healthy, productive, and innovative agricultural industry as a key component of the City’s economy economic base and heritage.”



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanRural London Place Types - Farmland

1197 (Now 1105)

, 1201 & 1219 Policies 1197, 1201 and 1219 are especially commendable. Preservation of hedgerows and woodlands promotes biodiversity, much of which has been lost in SW Ontario. These hedgerows and woodlands are also important in helping to preserve London’s Class 1 Agricultural land and its soil.



1197 (Now 1105)

The last sentence of Section 1197 is not consistent with Policy 2.3.6.2 of the PPS (2014) RECOMMENDATION: OMAFRA recommends that the last sentence of section 1197 be modified to state:“This place type will also discourage the creation of non-farm residential lots in the agricultural area. , where necessary mitigate Moreover, impacts from any new or expanding non-agricultural uses on surrounding agricultural operations and lands are to be mitigated to the extent feasible , where possible.”



1198 (Now 1106)

_10 Ministry staff simply suggest that the word ‘farmland’ be replaced with ‘agricultural’. RECOMMENDATION: OMAFRA recommends that the tenth bullet of section 1198 be modified to state:“Discourage uses which are not supportive of farmland agriculture from locating in the Farmland Place Type.”



1198 (Now 1106)

_11 Ministry staff suggest that the use referenced in bullet 11 is incorrect.se three bullets have some overlap and redundancy, and therefore some rewording would be beneficial. RECOMMENDATION: OMAFRA recommends that the eleventh bullet of section 1198 be modified to state:11. “Direct new non-agricultural permitted agriculturally-related development in the Farmland Place Type agricultural areas to lands that have a marginal or lesser lower capability Canada Land Inventory soils for farmland, and to areas where the potential for conflict between agricultural and the proposed non-agricultural uses will be minimized.”



1198 (Now 1106)

_12 Ministry staff respectfully suggest that the scope of bullet 12 be expanded. RECOMMENDATION: OMAFRA recommends that the twelfth bullet of section 1198 be modified to state:12. “Minimize the potential for land use conflicts between residential uses in the settlement area and livestock farm operations.”



1198 (Now 1106)

_13 Section 2.3.6.2 of the PPS (2014) includes both new and expanding non-agricultural uses. RECOMMENDATION: modified to state:13. “Mitigate impacts from any new or expanding non-agricultural uses on surrounding agricultural operations and lands.”



1198 (Now 1106)

_4 Ministry staff simply suggest that the word ‘farmland’ be replaced with ‘agricultural’. RECOMMENDATION: OMAFRA recommends that the fourth bullet of section 1198 be modified to state:“Foster an farmland agricultural sector that is diverse, profitable, and able to adapt.”



1198 (Now 1106)

_6 Under the PPS (2014), tourism, recreation, and education uses are not permitted in a prime agricultural area without adequate justification for limited non-residential uses. RECOMMENDATION: OMAFRA recommends that the sixth bullet of section 1198 be modified to either state that these uses are only permitted in accordance with the justification provisions located in Policy 2.3.6.1 (b) of the PPS, or that these uses are only permitted in a the Farmland Place Type if they are part of an agricultural operation. In other words, if they are on-farm diversified uses (e.g. agri-tourism, agri-tainment, agri-education).



1198 (Now 1106)

Policy 1198: Suggests new subsection stating "encourage organic and ecological ways of farming including no till, mixed crops and agroforestry"

No change - Policy 1106_3 and 1106_7 supports innovative practices that are sustainable, and support green technology and farm management techniques as they evolve.


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1198 (Now 1106)

Policy 1198: City should buy agricultural land and lease it to young people who don't have money to buy large farms. Allows for small plot cultivation.

No change - The chapter on Food System provides the necessary policy framework to support City investment in encouraging production and processing of food, as provided for by the Farmland Place Type policies.


1199 (Now 1107)

_ Farm Unit The policies for the Farm Unit are critical to proper implementation of the PPS agricultural policies, and as such, some modifications to ensure consistency with the PPS and rectify some grammatical issues are recommended. RECOMMENDATION: OMAFRA recommends that the Farm Unit section be amended as follows:“1. The predominant type of development permitted in the Farmland Place Type will take place within be the farm unit.2. The farm unit consists of the land base, the principal farm residence dwelling, supplementary , any secondary farm residence dwellings unit that are may be required for the farm operation, and associated on-farm buildings and structures, including, but not limited to barns, silos, drive sheds, manure storage facilities and other farm buildings/ structures that support the farm operation cultivation of land for the growing of crops such as nursery, cash crops, biomass, and horticultural crops; the raising of livestock and other animals for food, fur or fibre, including poultry and fish; aquaculture; apiaries; agro-forestry and maple syrup production.3. For the purposes of this Plan, only individual farm properties will be considered as farm units. Wherea farmer owns two or more farm properties and where those farm properties are separate lots for Planning Act purposes, each of the farm properties will be considered as a separate farm unit.4. 3. The farm unit also may include any Ssecondary farm occupation uses, home occupation uses, and bed and breakfast/farm vacation uses, as well as any where they exist, are considered as part of the farm unit.5. Wwoodlands which are located on farm properties will be considered as part of the farm unit, unless otherwise delineated on Map 6 – Natural Heritage Features.”

Modified - revised to incorporate recommended wording to be consistent with PPS


1199 (Now 1107)

_1 Ministry staff suggest that the descriptor part of the bullet be moved to the section on Farm Units later in the Plan and that a cross-reference to this section be added here. In general, this format of cross-referencing the relevant detailed Policy sections for each of the permitted uses listed in Policy 1199 should be adopted for clarity to the reader. RECOMMENDATION: 1. “Farm units, in accordance with Section ____ of this Plan. for the cultivation of land and the raising of livestock, which may include, but not be limited to, general farming, livestock farming, cash crop farming, market gardening, specialty crops, nurseries, forestry, aquaculture and agricultural research.”

Modified - revised to incorporate recommended wording to be consistent with PPS


1199 (Now 1107)

_10 The PPS does not permit institutional and recreational uses in a prime agricultural area without adequate justification as outlined in section 2.3.6.1 (b). RECOMMENDATION: OMAFRA recommends that the tenth bullet of section 1199 be modified to state:10. “Limited Iinstitutional and recreational uses where they support the agricultural community and do not impair normal farm practices and where there is an identified need in the next 20 years for additional agricultural land to be redesignated to accommodate the proposed use, and only where alternative locations have been evaluated and it was determined that there are no reasonable alternative locations within the City’s Urban Growth Boundary or Rural Neighbourhood Place Types, or on lower priority (Class 2-7) soils. Further, the proposed location must not comprise a specialty crop area and must comply with the required MDS I setback(s).”



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1199 (Now 1107)

_11 The PPS does not permit municipal infrastructure to be located in a prime agricultural area without adequate justification as outlined in section 2.3.6.1 (b). RECOMMENDATION: OMAFRA recommends that the eleventh bullet in section 1199 be deleted in its entirety, and the remaining subsections renumbered accordingly.11. Public utilities and stormwater management facilities.

Modified - reference deleted from list of permitted uses


1199 (Now 1107)

_13 Policy 1199.13: asks why only one wind turbine will be permitted? And it if one per farm? No change - this policy has been carried over from the current Official Plan. Yes, only one wind turbine with blade and supporting tower per farm is permitted.


1199 (Now 1107)

_2 & 3 The second half of bullet two is redundant with bullet three. In addition, the terminology used in section 1200 should be consistent with the terminology used in the third bullet.Moreover, the above comment related to cross-referencing should also be implemented. RECOMMENDATION: OMAFRA recommends the following modifications:2. “Residential use solely on existing lots of record, in accordance with Section ____ of this Plan and a secondary dwelling unit.”3. “Secondary farm dwelling units, in accordance with Section ____ of this Plan.”

Modified - revised _2 and deleted _3 from list of permitted uses


1199 (Now 1107)

_6 Section 2.3.3.1 of the PPS (2014) permits agriculture-related uses, but not industrial or commercial uses in a prime agricultural area. RECOMMENDATION: Therefore, OMAFRA recommends the following modifications:6. “Agricultural-related Industrial commercial and commercial industrial uses where they are necessary and directly related to an agricultural use farm operations in the region and provide direct products and/or services to farm operations as a primary activity.”

Modified - incorporate recommended wording from Province to be consistent with PPS.


1199 (Now 1107)

_6 & 1199_7 Policy 1199.6 and Policy 1199.7: Suggest considering PPS 2014 terminology as follows: Policy 1199.6: Agriculture-related Uses that will include related industrial and commercial uses where they…" and for Policy 1199.7 "On-farm diversified uses which may include retail sale of on-farm ....."



1199 (Now 1107)

_8 The PPS does not permit cemeteries in a prime agricultural area, and the London Plan already has a section which permits all existing uses (bullet 15.) therefore, bullet 8. should be deleted in its entirety, and the remaining subsections renumbered accordingly. RECOMMENDATION: 8. Cemeteries, as existing.

Modified - revise to delete use from list of permitted uses


1199 (Now 1107)

_Residential Uses on Existing Lots

Some modifications to the Residential Uses on Existing Lots of Record policies are recommended to ensure consistency with the PPS, other sections of the Plan and the MDS Guidelines. RECOMMENDATION: OMAFRA recommends that the Residential Uses on Existing Lots of Record section be amended as follows:“1. Residential dwellings will may be permitted subject to a zoning by-law amendment on existing lots of record provided it does not create conflicts with farming operations and subject to an environmental impact study if adjacent to any natural heritage feature.2. The MDS I Minimum Distance Separation setback regulations in the Our Tools part of this Plan will be applied at the time of the zoning by-law amendment and prior to the issuance of the building permit.3. New residential units may only be permitted where an adequate supply of potable water is available or can be made available, and where thelot size and soil types are suitable to support an individual on-site waste disposal system.4. A severance to create a new residential lot outside the Urban Growth Boundary in the Farmland Place Type will not be permitted, except for surplus farm dwellings in accordance with paragraph 1230 of this Plan.”

Modified - revised Policy to be consistent with PPS.


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1199 (Now 1107)

Policy 1199: suggests that "ecovillages should be allowed to organize" as a permitted use in the Farmland Place Type.

No change - the Provincial Policy Statement does not support uses which are not supportive of agriculture. The Rural Neighbourhood Place Type provides opportunity for limited non-agricultural activity.


1200 (Now 1119)

_1 PPS definition identifies agricultural related commercial and industrial uses as, “farm-related commercial and farm related industrial uses that are directly related to farm operations in the area (…)”While the LP definition refers to a singular “farm operation”, the PPS definition permits these uses seems to provide a broader definition that allows for these uses to not be associated with a specific operation, but are supportive of area farms. Consider revising this Policy so that it is consistent with the PPS definition of “Agriculture-related uses”, to read as: “Small-scale agriculturally-related commercial and industrial uses that are supportive of the farm operations in the area (…)”

Modified - incorporate recommended wording from Province to be consistent with PPS


1200 (Now 1119)

_Agricultural-Related Commercial and Industrial Uses

Ministry concerns around consistency with the definition and policies for agriculture-related uses in the PPS (2014) prompt suggested wording changes. Subsections (g) and (h) have simply been moved from sections 1210 & 1211 of the Plan to this location as they are related. RECOMMENDATION: OMAFRA recommends that the Agricultural-Related Commercial and Industrial Uses section of the Plan be amended as follows:“1. Small-scale agriculturally-related commercial and industrial uses that are directly related to farm operations in the region and provide direct products and/or services to farm operations as a primary activity supportive of the farm operation and that require a location in close proximity to a farm operation by adding value to, or retaining the value of, an agricultural commodity produced by that operation are deemed to be farmland-related uses. Such uses may include grain drying, handling and storage facilities, and farm market uses.2. Legally existing agriculturally-related commercial and industrial uses will be recognized in the Zoning By-law.3. Impacts from any new or expanding non-agricultural uses on surrounding agricultural operations and lands are to be mitigated to the extent possible.4. 3. New agriculturally-related commercial and industrial uses may be permitted by an amendment to the Zoning By-law to apply the appropriate agricultural commercial or agricultural industrial zone, subject to the following policies:a. The amount of land devoted to the activity includes only the minimum necessary to support the activity and its servicing requirements.b. It can be demonstrated that the use is supportive of the farm operations in the area and requires a location in close proximity to these farm operations to function successfully. It shall also be demonstrated that the use provides direct products and/or services to farm operations in the region as a primary activity.c. The location of the facility should not impose any operating constraints or result in a reduction of the efficiency of existing farms in the vicinity. Agriculturally-related commercial and industrial uses should be directed to sites having soil capability, drainage, topographic, site size or configuration limitations for agriculture. In other words, Tthese uses should be directed to the poorest soil quality available.



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1200 (Now 1120)

_Home Occupation.1

Clarity need to ensure that these uses are permitted in the Farmland Place Type. RECOMMENDATION: OMAFRA recommends that the first bullet of the Home Occupation section be amended as follows:“1. Home occupations not directly related to, but supportive of the primary farm operation may be permitted in the Farmland place type, provided they are accessory to the primary use of the property, operated only by those residing on the property on which the home occupation is located, and conducted entirely within the dwelling.”.



1200 (Now 1132)

_New Institutional and Recreational Uses

New or expanding institutional and recreational uses are not permitted in a Prime Agricultural Area under Section 2.3.3 of the PPS (2014). Accordingly, this section of the Plan needs to be amended to reflect the justification requirements outlined in Section 2.3.6.1 (b) of the PPS. RECOMMENDATION: OMAFRA recommends that the New Institutional and RecreationalUses section of the Plan be amended as follows:“1. New institutional and recreational uses are encouraged to locate within the Urban Growth Boundary of the city City.2. New or expanding institutional and recreational uses will only be permitted in the Farmland Place Type only where it has been demonstrated that:a. the location does not comprise a specialty crop area;b. the proposed use complies with the MDS I setback(s);c. there is an identified need within the planning horizon for additional agricultural land to be designated to accommodate the proposed use; andd. the ability of the adjacent farmland area to function is maintained by retaining the soil viability, and open space character.e. alternative locations have been evaluated, and it was determined that there are no reasonable alternative locations within the City’s Urban Growth Boundary or Rural Neighbourhood Place Types, or on lower priority (Class 2-7) soils.f. Sensitive uses which would preclude future livestock operations in the area will not be permitted.”

Modified. Also addressed in 1107_8 to refer to Provincial Policy Statement.


1200 (Now 1124)

_Secondary Farm Occupation.3

Additional wording to distinguish between home occupations and secondary farm occupations is suggested for clarity sake. RECOMMENDATION: OMAFRA recommends that the third bullet of the Secondary Farm Occupation section be amended as follows:“3. Secondary farm occupations are differentiated from “home occupations” by the larger size and scale of the activity, and they fact that they can be conducted outside of the dwelling.”



1200 (Now 1127)

_Secondary Farm Occupation.6.a

Minor change to state such uses should be directly related to agriculture, not farmland. RECOMMENDATION: OMAFRA recommends that the sixth bullet, subsection a. of the Secondary Farm Occupation section be amended as follows:“a. A secondary farm occupation may include the processing or retailing of goods produced on the farm, a welding or fabricating shop, a vehicle repair establishment, a contractor or trade shop, a personal service establishment, a craftsperson’s shop, a day care facility, a bed and breakfast or farm vacation establishment, a small business office, or any other occupation which is directly related to agriculture farmland.”

Modified - incorporate recommended wording from Province.


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1200 (Now 1119)

Some modifications to the Secondary Farm Dwelling Unit policies are recommended to ensure consistency with the PPS, other sections of the Plan and the MDS Guidelines. RECOMMENDATION: OMAFRA recommends that the Secondary Farm Dwelling Unit section be amended as follows:“The establishment of one additional (two dwellings in total, including the principal farm residence) single detached dwelling on the farm unit for the farm owner, an immediate family member engaged in full-time employment on the farm or a full-time farm employee, or living quarters for seasonal farm help, may be permitted by an amendment to the Zoning By-law subject to the following criteria:1. The size of farm parcel and type of farm operation warrants an additional dwelling unit to provide for the close proximity of farm personnel employees to the farm operations.2. A factory-built or manufactured home may be permitted as an additional dwelling unit provided the home is placed on a permanent foundation and meets all requirements of the Zoning By-law and Building Code.3. The secondary farm dwelling unit or living quarters for seasonal farm help will be clustered with the existing single detached dwelling principal farm residence and farm-related buildings and structures. Access to the secondary farm dwelling unit or living quarters for seasonal farm help will be restricted to an existing driveway and no new driveway will be permitted.4. A secondary farm dwelling shall not be severed from the farm unit.5. Temporary living quarters for seasonal farm help may only be permitted through a temporary Zoning By-law amendment.6. Secondary farm dwelling units shall meet the required MDS I setback(s) at the time of the Zoning By-law amendment and prior to the issuance of the building permit.”

Modified - incorporate recommended wording from Province.


1201 (Now 1132)

_2 Recreational and institutional uses are not agricultural uses and would constitute the removal of prime agricultural land. This would not be consistent with the PPS.

No change - addressed in 1107_8.


1205 (Now 1136)

Policy 1205: Green energy projects should be integrated into the city grid, in case the national grid goes down, regional would still run.

No change - beyond the scope of Official Plan policy


1207 (Now 1139)

_4 Recreational and institutional uses are not agricultural uses and would constitute the removal of prime agricultural land. This would not be consistent with the PPS.



1207 (Now 1139)

_5 Policy 1207.5: asks why limit retail function to "temporary in nature" when limitation about "sale of on-site produce" is the greater influence upon the duration of retail sales.



1208 (Now 1141)

_2 Policy 1208.2: Suggests smaller than 40ha farm size so that millennials without enough capital can do small plot farming

No change - The chapter on Food System provides the necessary policy framework to support alternative ways for Londoners to grow and sell food within the city.


1208 (Now 1141)

_3 It is not the MDS requirements that are important here. It is the MDS setback. Hence, the suggested minor wording changes to reflect this point. RECOMMENDATION: OMAFRA recommends that the third bullet, of the Existing Farmland Lots section be amended as follows:“3. Recognize existing land holdingsin the Farmland Place Type that do not meet the minimum 40 hectares farm parcel size and that are under separate ownership from abutting parcels of land at the date of adoption of this Plan, may be used for agricultural purposes, including one single detached dwelling, subject to an Minimum Distance Separation (MDS I) requirements setback(s).”



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Given the existence of the provincial Nutrient Management Act, there is no longer a need for municipal policies to be incorporated into local planning documents. Consequently, to avoid redundancy, Ministry staff recommend that this section of the Plan be deleted in its entirety. RECOMMENDATION: “Nutrient Management1209 The City supports the use of Nutrient Management techniques in accordance with provincial Policy and legislation to mitigate negative impacts on natural features and functions and to maintain the long-term viability of agricultural operations.”

Modified - removed Policy



Policy 1209: Suggests encouraging more ecological ways of managing nutrients. Modified - removed Policy



Policy 1209: Nowhere does London Plan address tile drainage effluents. Suggest that as subsection to 1209, or elsewhere, a Policy should note "tile drainage systems shall not outlet directly into receiving water courses. The City will work with farming community to require settling ponds between tile drainage outlets and receiving water courses and water bodies." (relates to Provincial Drainage Act).



1210 (Now 1144)

and 1211 As mentioned above, in an attempt to improve implementation, these two sections have been moved to the agricultural-related uses section of the Plan to ensure all related planning criteria are located in one place. Consequently, they can be deleted here. RECOMMENDATION: “Agriculturally-Related Commercial and Industrial Uses1210Industrial and commercial uses may be permitted in accordance with relevant provincial guidelines.1211Industrial and commercial uses will comply with provincial environmental approvals and regulations respecting the release of pollutants into the air, onto land, or into water, or for the storage, transportation or disposal of waste that is produced by the operation of the industrial and/or commercial use.”

Modified - polcy addresses site plan matters only


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1212 (Now 1142)

, 1213, and 1214 Many of the criteria listed in these three sections are repeated and equally should apply to all development in the Farmland Place Type. Consequently, the Ministry suggests that the criteria listed in Policy 1213 & 1214 be combined with the others listed in 1212. This change along with some minor wording modifications form the basis for the following expanded section 1212 regarding Form in the Farmland Place Type. RECOMMENDATION: OMAFRA recommends that Policy 1213 & 1214 be deleted, and merged into Policy 1212, such that 1212 would read as follows:“All development taking place within the on Farmland Place Type parcelswill should be efficient and where possible directed so as to:• Minimize noxious impacts on residential buildings neighbouring uses.• Locate development toward the street frontage to minimize the impact on the amount of agriculturally viable land removed from for production.• Be grouped or clustered to minimize points of access to the street which would may create transportation conflicts.• Locate buildings and structures on the least valuable soil within the farm unit parcel.• Be oriented to maximize the use of solar energy, and designed to recycle water.• Be designed such that their demolition would not preclude a return to field-based agricultural production.• Ensure the minimal amount of parking for ancillary retail and secondary occupations is required.• In all instances maximize the quality and amount of possible land area for agricultural production.”Farm Unit Buildings1213_The buildings which define a farm unit should appear as an efficiently designed collection of buildings. They will be located such that:1. They are on the least valuable soil within the farm parcel.2. Only a single access point from the street is necessary.3. Only the minimal amount of parking for ancillary retail and secondary occupations is required.4. Non-livestock farm buildings are grouped.5. Any residential buildings and structures are grouped.



1214 (now 1143)

MOECC staff supports the idea of recycling process water in greenhouse operations. Their experience with greenhouse operations is that water supply - quantity and quality - and the treatment of process wastewater, stormwater and domestic sewage are significant issues which ought to be considered through the site approval process.

No change - policies 1564 to 1571 specify matters to be considered through site plan approval process


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Ministry staff request that Policy 1215 be deleted in its entirety for the following reasons:1. The MDS requirements outlined in the Our Tools section already requires the application of MDS II for livestock operations. Listing it here again is redundant.2. The above modification for 1212 would cover all development, including livestock operations in the Farmland Place Type, and it already includes criteria 1, 2 and 3 proposed here.3. Regulating development based on prevailing winds is unnecessarily onerous for the farm community and enforcement would be difficult. RECOMMENDATION: “Livestock Operations1215_ Livestock operations are to be considered in conformity with the Minimum Distance Separation policies of the Our Tools part of this Plan. The building portion of the operations will be located such that:1. They are on the least valuable soil within the farm parcel.2. They are designed to recycle water.3. They are designed such that their demolition would not preclude a return to field-based agricultural production.4. Prevailing wind patterns directs their odour away from the residential portion of the farm unit and, where possible, adjacent farm units.”




Policy 1215: Suggest permitting "rotating livestock operations". Provides link to YouTube video on the subject.



1216 (Policy deleted/ 1217 now 1144)

For the same reasons listed above Policy 1216 of the Plan should be deleted in its entirety. Moreover, the title for this section should reflect the terminology used throughout the Plan as Agricultural-Related Commercial and Industrial Uses, not Agriculturally-Related. RECOMMENDATION: “Agriculturally-Related Commercial and Industrial Uses1216_ Agriculturally-related commercial and industrial development in the Farmland Place Type will be located such that:1. They are on the least valuable soil within the farm unit parcel.2. They are designed to recycle water and are not utilizing or expecting municipal servicing.3. They are designed such that their demolition would not preclude a return to field-based agricultural production.4. Prevailing wind patterns directs their odour away from the residential portion of the farm unit and where possible adjacent farm units.”

Modified - Policy to relabeled as "Agricultural-Related" - Policy 1216 deleted, but kept/rewrote 1217 (now 1144)under the heading


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1217 (Now 1144)

First, Ministry staff note that this section of the Plan will be renumbered to 1216 to reflect the above changes.Next, Ministry staff are simply seeking clarification as to how bullet #6 will be implemented. To elaborate, there are countless variations as to how MDS could be applied to agricultural-related commercial and industrial uses.Is it the City’s intention to require an MDS I setback for ALL agriculture-related uses at the time of the Zoning By-law amendment?Some of these uses are often compatible with, and complement agricultural uses. Consequently, planning applications to permit these uses will generally not need to meet MDS I setbacks from existing livestock facilities. However, some proposed agriculture-related uses may exhibit characteristics that could lead to potential conflicts with neighbouring livestock facilities and consequently, it may be appropriate to require an MDS I setback to permit these types of uses. Typically these uses may be characterized by a higher density of human occupancy or activity, or will be uses that may generate significant visitation by the broader public to an agricultural area. Examples of these uses include, but are not limited to: food service, accommodation, agri-tourism uses and retail operations. For these reasons, municipalities may choose to require an MDS I setback for proposals, including lot creation, to permit certain types of agriculture-related uses, rather than all agriculture-related uses. RECOMMENDATION: The City is strongly encouraged to develop policies to provide consistent direction on this issue, as the current policies are too general to allow for consistent implementation.

Modified - reference to MDS removed from policy


1218 (Now 1145)

Policy 1218: similar to comments about Policy 812, establish a trust fund for wind turbines to pay for eventual dismantling and site rehabilitation costs. Trust fund similar to the model the province runs for aggregate operations' rehabilitation.

No change - trust fund not appropriate for Official plan policies


1219 (Now 1146)

_2 Does maintained = retained? Wording should be "shall" or "will", not "are to be" No change - policies provide clear direction


1219 (Now 1146)

OMAFRA is recommending that the two bullets listed under this section be amended slightly to capitalize the word City and to add the word ‘the’ to address a minor grammatical issue. RECOMMENDATION: It is recommended that the following amendments be made:“1. Development within a farm parcel should in all instances not damage the functional viability of woodlands either on the parcel or neighbouring parcels so as to respect their value as a part of the rural landscape and the Ccity’s natural heritage system.2. Hedgerows and woodlands are to be maintained and, where possible, enhanced to bolster the image of the Forest City, enhance their environmental features and functions, and connect to the Ccity’s natural heritage system.”

Modified-modified to reflect comments


1219 (Now 1147)

Policy 1219: allow woodlots for coppicing operations for biofuel prod'n. Article from resilience.org added for reference.

Modified - added policy oregarding other incentives for woodland retention.


1219 (Now 1147)

Policy refers to "woodlands …are to be harvested…". This makes it sound like they will be cut down. Suggest rewording to "…if harvested, are to be in accordance…"

No change


1219 (Now 1147)

What about woodlands that are designated OS (part of the NHS)? Are they treated the same ("harvested") or is this just for ER lands?

No change - policies already included for protection of woodlands, refer to natural resources and heritage chapters



Recreational and institutional uses are not agricultural uses and would constitute the removal of prime agricultural land. This would not be consistent with the PPS.



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OMAFRA notes that the proposed revisions to section 1212 detailed above would cover all development in the Farmland Place Type, including institutions and facilities. Therefore, section 1220 is no longer required as it is redundant and should be deleted in its entirety. RECOMMENDATION: “Institutions and Facilities1220_ Institutional and public facility uses will develop in an efficient manner which minimizes the quality and amount of agricultural land taken up by:• Locating close to the street.• Utilizing the minimum required parking.• Locating on the least valuable soil within the farm parcel.• Being designed to recycle water.• Being designed such that their demolition would not preclude a return to field-based agricultural production.”



1221 (Now 1148)

Policy 1221: Public realm needs 30 metre buffers along all watercourses in agricultural land to protect from sediment and nutrient transfer.

No change - policy not intended to set measurement


1223 (Now 1150)

The agricultural community has identified the use of local roads by farm operators with large, and often, slow moving farm vehicles/machinery as a road safety hazard and as a potential impediment to productive and efficient farm operations. Therefore, it is recommended that a few additional items be included in this section to address this concern. RECOMMENDATION: OMAFRA recommends that Section 1223 be amended, such that it states:“Rural Thoroughfares should be clear to provide efficient movement for safe passing and allow for the movement of agricultural vehicles and agricultural products. Where there is a foreseeable conflict, agricultural vehicles will take precedence. Rural Thoroughfares will remain clear through measures including:1. Proper drainage design.2. Limiting farm units to a single access point with the exception of livestock operations and field accesses.3. Providing off-street parking for non-agricultural uses.4. Limiting the use of hard curbs and adopting wider shoulder to accommodate large farm machinery with wide turning radiuses.5. Utilizing slow moving vehicle signage on roadways which are frequently travelled by the farming community.”

Modified - revised to incorporate recommended wording from Province


1224 (Now 1151)

or 1225 (Now 1152)

Policy 1224 or Policy 1225: Policy about prohibiting creation of lots for non-farm rural residences should be restated in either of these policies. This is key PPS agriculture Policy aimed at limiting conflict.

No change - Policy 1107 lists the permitted uses for the Farmland Place Type and Policy 1153 further refines the circumstances that lot creation can occur in the Farmland Place Type.


1226 (Now 1153)

A minor editorial change is proposed to ensure consistent terminology used throughout the Plan. OMAFRA recommends that the ‘ly’ be removed from ‘agriculturally’ to use consistent terminology throughout the Plan. This comment applies in multiple places throughout the Plan and a search and replace function would be helpful in ensuring consistent terminology is used elsewhere. RECOMMENDATION: “Agriculturally-related commercial and industrial uses.”



1227 (now 1154)

This Policy would permit farm parcels that are smaller than 40 ha. This is something that OMAFRA has not been supportive of in the past.

No change - this Policy establishes 40 ha as the minimum farm parcel size.


Page 188


1227 (now 1154)

Ministry staff recommend that the title of this section be changed to be consistent with the first bullet listed in section 1226 of the Plan. Moreover, there are Policy requirements found in section 2.3.4.1 (a) of the PPS (2014) which are not reflected here. RECOMMENDATION: In order to be consistent with the PPS (2014), OMAFRA recommends that the following modifications be made to this section:“Farm Consents for Farming Operations Parcel Size1227_ It is the Policy of this Plan to discourage the severing of smaller parcels from larger land holdings. In this regard, 40 hectares (100 acres) will be regarded as the minimum size for a basic farm parcel. Council will discourage the severing of farm parcels which exceed 40 hectares in size; however, an application to sever may be permitted if the land is to be used for agricultural purposes and provided that the following criteria are met:1. Both the severed and retained parcels are of sufficient size for the predominate type of agricultural use common in the area and are sufficiently large to maintain flexibility for future changes in the type or size of agricultural operations intended agricultural use including consideration of the methods of proper manure storage and disposal if there is a livestock operation existing or proposed for either of the severed or retained parcels. 2. Both the severed and retained parcels are of a nature and size, and have soil and drainage characteristics that are suitable to support an efficient farm unit, including full-time farm employment on each parcel.3. 2. The size of both the severed and retained parcels conforms to the provisions of the Zoning By-law. Should the severed or retained parcel not conform to the minimum lot area requirements of the Zoning By-law, an amendment to the By-law will be required.”



1230 (Now 1157)

Ministry staff are seeking clarification as to how the City intends to consistently determine whether a dwelling is part of a farm cluster or not, given the absence of a definition of this term. RECOMMENDATION: It is recommended that the City incorporate a definition of ‘farm cluster’ in this bullet by expanding on the phrase, or the City should provide clarity regarding the methodology or Policy test required to demonstrate that a dwelling is part of a farm cluster.

Modified - incorporate a definition of "farm cluster"


1231 (Now 1158)

Severances for recreational and tourism uses are not permitted in the prime agricultural area, as outlined in the PPS (2014).In addition, a minor editorial change is also proposed to ensure consistent terminology used throughout the Plan. OMAFRA recommends that the ‘ly’ be removed from ‘agriculturally’ to use consistent terminology throughout the Plan. This comment applies in multiple places throughout the Plan and a search and replace functionwould be helpful in ensuring consistent terminology is used elsewhere. RECOMMENDATION: “Lot Creation for Agriculturally-Related Uses1231_ A consent to sever agricultural land to create a lot for an agriculturally-related commercial use, including recreational and tourism uses, or industrial use may be permitted provided the lot is kept to the minimum required to support the use, and to accommodate individual on-site wastewater treatment and water supply.”

Modified - revised to change reference from "Agriculturally" to "Agricultural"


1235 (Now 1163)

Permits industrial uses along the Colonel Talbot corridor to the 401 in an agricultural designation. There already exists zoning that would permit “dry” industrial uses on these agriculturally designated lands. How are these lands included in the City’s industrial land supply?

Modified - revised to permit limited range per 2.3.6.1 (b) in the PPS


Page 189


1235 (Now 1163)

While there are some existing non-agricultural uses that could be recognized as such through SPA’s in the Plan, OMAFRA has not received any justification for the addition of the large amount of land being designated for non-agricultural uses in the Tempo SPA. RECOMMENDATION: The City needs to reduce the size of the SPA to recognize the multiple existing non-agricultural uses only, or provide adequate justification for the additional land as per Policy 2.3.6.1 (b) in the PPS (2014).

Modified - revised to permit limited range per 2.3.6.1 (b) in the PPS

Rural London Place Types - Rural Neighbourhoods

1237 (Now 1166)

Policy 1237: Vision for Rural Neighbourhoods should be that these communities are allowed to turn into "ecovillages" if they wish.

No change - Policy 1168 permits a range of uses that may support an ecovillage, subject to the intensity and form policies of the Rural Neighbourhood Place Type.

Rural London Place Types - Rural Neighbourhood

1238 (Now 1167)

_4 There is an opportunity to avoid redundancy, where the term ‘livestock facility’ includes both those barns with livestock currently being housed, and those which are empty but have the potential to house livestock. Moreover, the goal should be to minimize conflicts between residential uses and all agricultural uses, not just those agricultural uses with livestock (or the potential for livestock). RECOMMENDATION: OMAFRA suggests modifying this subsection to state:“Minimize the potential for land use conflicts between residential uses of the settlement area and all adjacent agricultural uses, including, but not limited to livestock facilities. operations, or buildings that may have the potential to house livestock.”



1239 (Now 1168)

& 1244 (Now 1173)

Ministry staff note that the concept of being ‘related to the agricultural community’ established in Policy 1239, bullet 7 is not reiterated in either the title or policies pertaining to section 1244 of the Plan. RECOMMENDATION: OMAFRA recommend that the title of section 1244 be amended to state:“Commercial and Industrial Uses Related to the Agricultural Community”And that an additional criteria be added to the list in 1244 to state:“8. The use is related to the surrounding agricultural community in that it provides products and/or services to farm operations.”

No change - modifications not necessary as these policies are for Rural Neighbourhood, not Farmland


1241 (Now 1170)

Ministry staff note that this section is listed under the Residential Use heading, which is perhaps a mistake given all the uses described within this section are not residential. RECOMMENDATION: The City may wish to add an additional separate heading for this section of the Plan to indicate the content of the policies proposed.

Modified - revised to add another heading "Other Uses"


1248 (Now 1177)

_6 OMAFRA recommends that this section be modified to reflect the language of the latest MDS Guidelines and the intent of the PPS, Policy 2.3.3.3. RECOMMENDATION: “Any proposed planning and development application within a Rural Neighbourhood Place Type shall meet the required MDS I setbacks as set out that would reduce the distance between the built-up area and an existing livestock operation will be reviewed for its effects on the livestock operation in conformity with the Minimum Distance Separation policies in the Our Tools part of this Plan. In other words, If if the application will result in a development that imposes operating constraints on the a neighbouring livestock facility operation, the application will be refused.”



Page 190

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanRural London Place Types - Waste Management Resource Recovery Area

1250 (Now 1180)

Whole Chapter Map 4 identifies lands along the west side of White Oaks which were apparently not included in Official Plan Amendment 462. What is the basis for including these lands and where can that be found in a public document?MOECC presume that Official Plan Amendment 462 is the basis for Eco-industrial Parks.Caution should be exercised in preparing guidelines under Policy 1258 such that the result may be to cause approved landfills to fall out of compliance with their provincial approval/s. It should be recognized in Policy 1266 that changes to the boundaries of W12A may require an amendment to its ministry approval and that approval may not be forthcoming until obligations under the Environmental Assessment Act have been met. MOECC note that the lands west of White Oaks fall within this description in Policy 1266 and MOECC are not aware that the W12A boundaries have been changed accordingly.MOECC are not aware that the W12A Landfill Area Study is available to the public or agencies and have been unable to obtain confirmation from the waste management section at the city that this study is the same study as was completed for OPA 462.The matters covered by Policies 1268 to 1273 are subject to the Environmental Protection Act (Certificate of Approval/Environmental Compliance Approval) as well as the Environmental AssessmentAct. Approval under the EPA in effect implements the EA much like a zoning by-law implements the official plan.The process set out in Policy 1276 must be clearly understood to be the process the city will follow in reviewing applications submitted to it to add or expand existing waste management and resource recovery areas recognizing that in most cases provincial approval is required. The idea of coordinating municipal review with provincial approvals is helpful and supportable by the ministry

Modified-area of Waste Management Resource Recovery Area now the same as stated in the current Official Plan, and includes, city-owned lands only. The boundary of the W12A landfill operation is unchanged through these policies.

Rural London Place Types - Waste Management Resource Recovery Area

1250 (Now 1180)

Policy 1250: Vision for Waste Management Resource Recovery Area: this section should be linked to policies about generation of waste and that landfills should be "sunset industries", shut down as cites become sustainable ecosystems recycling and reusing waste.

No change - landfill closure procedures not part of the Official Plan.


1250 (Now 1180)

Add new Policy under "Our Vision for Waste Management Resource Recovery Area Modified - revised to clarify vision


1250 (Now 1180)

Change current Policy 1250 to Policy 1253, under the subtitle "Role of Landfills" combine Policy with current Policy 1251

Modified - revised policies 1180 and 1182 to address comment


1250 (Now 1180)

1250_ the purpose of the Waste Management Resource Recovery Area is to plan for the continued evolution of the W12A Landfill and area as an integrated waste management centre that uses environmentally responsible and sustainable operations and practices to transfer waste to resource materials while maintaining a high standard of compatibility and minimal impacts with its environment and neighbours.



1252 (Now 1182)

Change subtitle from "how will we realize our vision?" to "landfill policies" No change-consistent with the format of the Plan, and sub-heading addresses concern.


Page 191


1253 (Now 1183)

and 1259 OMAFRA are concerned that new industrial parks are permitted in an existing special Policy area that did not permit this land use previously. The Ministry understands that the original justification for these specific lands was for a landfill, consequently, any change in land use such as an industrial park, which is not a permitted use in a prime agricultural area, will necessitate additional justification through Policy 2.3.6.1 (b) of the PPS (2014). Simply concluding that because a landfill was permitted under a former Policy regime does not warrant the development of an industrial park on the same lands under the current land use planning Policy regime. Furthermore, it is understood that the W12A Landfill Area Study selected Option 3 (develop an integrated resource recovery centre) and did not selection Option 4 (develop an eco-industrial park). RECOMMENDATION: The Ministry recommends that this section of the official plan be removed in its entirety until such time as adequate justification is provided for an industrial park in the prime agricultural area.

No change - Place Type boundary reduced to be same as existing, no new land uses permitted


1253 (Now 1183)

Policy 1253: Suggest including "wind farms and solar farms" as permitted uses under Policy 1253.

No change - primary uses associated with waste management functions


1253 (Now 1183)

Move to section 1251 No change-consistent with the format of the Plan.


1254 (Now 1184)

_2 Intent of Policy is unclear Modified - policy deleted


1255 (Now 1185)

_4 What is meant by the public realm? No change-consistent with the language of the Plan.


1255 (Now 1185)

Change wording to "the following policies apply to landfills in the …" No change-the policies apply to the Place Type, not a use permitted in the Place Type


Page 192

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanRural London Place Types - Rural Neighbourhood

1256 (Now 1186)

OMAFRA notes that applications to expand or add new landfills will also need to meet all applicable PPS policies, including the justification and alternative site analysis required by Policy 2.3.6.1 (b) of the PPS (2014). RECOMMENDATION: OMAFRA request the following modifications to this section:““Applications to expand or add new landfills will need to meet all applicable provincial legislation and regulations, including but not limited to the Environmental Protection Act, the Environmental Assessment Act and the Ontario Water Resources Act. In addition, applications to expand or add new landfills in Rural London shall only be permitted where it is demonstrated that:1. The land does not comprise a specialty crop area;2. There is an identified need within the planning horizon for additional land to be designated to accommodate the proposed landfill;3. Alternative locations have been evaluated, and upon this evaluation it is determined that there are no reasonable alternative locations which avoid the Farmland Place Type; and there are no reasonable alternative locations in the Farmland Place Type with lower priority agricultural lands; and,4. Impacts from any new or expanding landfills on surrounding agricultural operations and lands shall be mitigated to the extent feasible.”



1256 (Now 1186)

Change subtitle to "applications to add or expand landfills" Modified - revised to address comment


1257 (Now 1188)

Change subtitle to "landfill planning and development applications" No change-consistent with the format of the Plan.


1257 (Now 1188)

Update points 3-5 to state" 3. Proximity to existing or future development, 4. Mitigation measures including measures to mitigate noise, dust, litter, odour, and visual impacts, 5. (delete)



1258 (Now1189)

_5 Change to "Guidelines for monitoring and/or remediating groundwater, surface water, and air quality on an ongoing basis"



1258 (Now1189)

Add litter and visual to the list of imacts in opening paragraph Modified - revised to address comment


Page 193


1260 (Now 1190)

Need a new section under City Building Policies. Need to compare our city to an organism, a tree. Organism is part of an ecosystem. Need a section that spells out how even highly modified human systems such as cities are like ecosystems; they have a metabolism by taking resources and energy in and spewing waste out, and also functions and services occur not just in Natural Heritage System but everywhere with permeable surfaces. Need planning to be imbued with science of ecology. Don't need separate eco and non-eco development, need only ecological development. Some policies speak to this, but should be under one banner "The Ecological City". Add this type of language to Policy 1260 as well (eco-park to use ecological design, follow principles of natural system through cycling of resources and optimizing energy use within the constraints of local and global ecosystems).

No change - not consistent with intent of policy


1264 (Now 1196)

Policy 1264: Suggests in this Policy that there should be a target of 100% diversion by 2035, requiring no new landfill or extension of existing one.

No change - targets not included in policy


1266 (Now 1198)

and map 4 It was indicated by the City that additional lands were added to this designation in the new Official Plan. MMAH will need to see the justification for the removal of these lands for the W12A Landfill.

Modified - revisions to map and text to show reduced area and add new policy reference to PPS for the redesignation of Agricultural land


1266 (Now 1198)

and map 4 The area described in this section and shown on Map 4 as Resource Recovery Area is much larger than the former City of London Official Plan. Therefore, justification would be required under Section 2.3.6.1 (b) of the PPS (2014) to allow for these additional lands to be added to this area. Moreover, this redesignation shall also require an official plan amendment in accordance with the City’s former OP Policy 9.2.15.1 which states:“The lands affected by this Policy, include the lands identified as Waste Management and Resource Recovery Area in the W12A Landfill Area Plan, and are generally located within the block bounded by Wellington Road South, Manning Drive, White Oak Road and Scotland Drive. Properties known municipally as 3137 and 3405 Scotland Drive and 5529, 5595, 5615, 5751 and 5879 Wellington Road South, which are located within this City block, do not form part of this specific Policy area and are excluded. Any future changes to this defined boundary shall require an Official Plan Amendment.” RECOMMENDATION: The lands shown as Resource Recovery Area on Map 4 should be reduced to reflect the area shown on Map 8, Item 24.In addition, the policies which speak to this boundary in the Plan shall also be modified to state that any changes to this boundary shall require an official plan amendment which meets all of the Policy tests established in section 2.3.6.1 (b) of the PPS (2014).



1266 (Now 1198)

Add after description of W12A site "plus properties abutting the west side of Scotland Drive. Properties known as 5595, 5615, 5751, and 5879 Wellington Road South, which are located within this City block do not form part of this specific Policy area and are excluded."



Page 194


1267 (Now 1199)

_uses permitted by site-speciific zoning.4

Similar to the Ministry’s concerns around industrial parks, permitting recreational uses within or adjacent to the landfill special Policy area would require additional planning justification under the PPS (2014). To elaborate, the Ministry understands that the original justification for these specific lands was for a landfill, consequently, any change in land use such as a recreational use, which is not a permitted use in a prime agricultural area, will necessitate additional justification through Policy 2.3.6.1 (b) of the PPS (2014). Simply concluding that because a landfill was permitted under a former Policy regime does not warrant the development of recreational uses on or adjacent to the same lands under the current land use planning Policy regime.Moreover, permitting recreational uses within the buffer area around W12A seems to directly conflict with section 1281, bullet #2 of the Plan regarding the prohibition of sensitive land uses, which states:“Within the Farmland Place Type, the City will discourage new Official Plan and/or zoning by-law amendments to allow the development of new residential uses or other sensitive land uses within a 1,500 metres radius of the Waste Management Resource Recovery Area Place Type to provide appropriate separation distance to mitigate impacts.” RECOMMENDATION: The Ministry requests that bullet #4 be removed from this section in its entirety.



1269 (Now 1200)

It is understood that the area shown on Map 8, Item 24 as Resource Recovery Area includes both the ‘fill area’ and the ‘peripheral area’ as described herein; however, it would be helpful to provide a map showing the limits of each of these areas as part of this Plan. RECOMMENDATION: The Ministry recommends that the Plan include a visual graphic or map indicating the physical extent of both the ‘fill area’ and ‘peripheral area’ of the landfill as described in section 1269.

Modified - revised text to address comment, no map change


1274 (Now 1211)

_3 Policy 1274.3: Suggests windmills and solar generation should also be permitted. No change - not consistent with intent of policy


1276 (Now1213)

_3 Add groundwater and surface water to impact assessments Modified - revised to address comment


1277 (Now 1214)

Policy 1277: Policy should include monitoring of leachate and publishing data on a "Smart City" website (for the Smart City section of London Plan).

No change - specific programs not listed in this section


1281 (Now1218)

_2 Impact on industrial land west of 401 Modified - revised to address comment - lands removed

Rural London Place Types - Open Space

1283 Policy deleted)

Whole Chapter The policies for rural open space look good. It is vital that the natural features and natural heritage system in rural London be protected and enhanced.

This section of the Plan has been deleted. The Green Space Place Type applies to both Urban and Rural London.


Page 195

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanRural London Place Types - Open Space


As currently drafted, this section appears to permit golf courses, recreational activities and other ancillary facilities in the agricultural area without the justification required by Policy 2.3.6.1 (b) of the PPS (2014). RECOMMENDATION: OMAFRA requests that the additional justification policies of the PPS be inserted in this section of the Plan, or alternatively, an appropriate cross-reference to the policies found in the Farmland Place type be inserted, such that it states:“Open space and conservation uses will be permitted within Rural London, in conformity with the Urban London Open Space Place Type and Farmland Place Type policies of this Plan. Open space uses may include outdoor recreational activities, golf courses and conservation areas, as well as any ancillary facilities that are associated with these uses. Open space lands may be publicly or privately-owned.”




_1 MOECC staff does not understand why potential impacts of open space and conservation uses are limited to soil and topography. Hydrological impacts are also important.




The rationale for not allowing any adverse impacts upon agricultural land drainage systems with regard to the purposes for Open Space and Conservation uses should be explained. The Policy recognizes the presence and benefits of environmental features and the natural heritage system. MOECC do not believe that the prohibition provided by this Policy strikes a balance between these two uses of limited water resources within the rural places in the city.




Policy 1285: Suggest deleting the end of this Policy, starting from "without creating constraints for agricultural land management and farming operations. No project or works will be….."




The rural component is well covered for land use planning but does not seem to encompass operational sustainability matters. Items like design standards and asset management are not specified. It would be a good thing to consider separate rural/urban sections in Chapter 4 for a future rendition of the plan.


Secondary Plans 1289 Whole Part SWAP (SE corner of Fanshawe Park Rd W and Hyde Park Rd) - please keep them informed of status of any amendments to SWAP that will facilitate transition to the LP

No change - all who submitted comments will be circulated

Secondary Plans 1289 Whole Part Seeking confirmation that the Southwest Area Plan will remain fully in effect. No change - SWAP will remain in effectSecondary Plans 1290 This Policy means that HCD Plans are, in effect, Secondary Plans. Policy 1291 states that

secondary plans shall prevail (in accord with Section 41.2(2)), but HCD Plans are not really Secondary Plans…

Modified - HCD removed from list

Secondary Plans 1292 _8 States that the financial analysis must provide a clear understanding of “ongoing costs and revenues that will be generated”. What does this mean? It could refer to many things such as operational costs of infrastructure or community facilities, property tax revenue, building permits, admission fee revenue to recreational facilities, etc., many of which are difficult to predict and entirely out of the applicant’s ability to control or predict. How long is “ongoing”? Suggests providing additional clarification of intent or remove requirement for “ongoing” costs and revenues.

Modified - revised to explain relationship to asset management best practices. The model exists to evaluate whole life cycle costs, and policy revised to clarify that it is a forecast.

Secondary Plans 1292 _8 Change this to a financial analysis that conforms to asset management best practices including whole life cycle costs, level of service considerations, risk management and revenues.



Page 196

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanSecondary Plans 1292 This Policy states that background studies will be prepared for large secondary plans. What is

the definition of “large”? MOECC staff believes that all secondary plans must be supported by sufficient information and analysis to enable decision makers and the public to form opinions as to their appropriateness with regard to community vision/goals/objectives as set out in the Plan as described for example by Policy 1324 (pg 362), Policy 1339 (pg 364) and Policy 149 (pg 365) et al.Bullet 1.b appears to conclude that only best management practices need to be considered to provide necessary management/treatment of stormwater at the tributary scale. MOECC would be interested to understand the basis for this conclusion. MOECC’s expectation is that the stormwater management component of a secondary plan consider all reasonable management approaches in deciding upon what is “best” in the circumstances, from the perspectives of environmental impact, financial implications, operations, community values etc. To this end the ministry’s Stormwater Management Planning and Design Manual and Stormwater Pollution Prevention Handbook were developed as guidance material.It is understood that secondary plans are adopted by Council as guidance documents (and not as official plan amendments per se). Therefore should they not be listed or discussed in Policy 1432 et al on pages 384/385?

Modified - revised to address comment. Secondary Plans are not guideline documents

Secondary Plans 1292 Revised to:“A cash flow analysis, providing a clear understanding of the one-time and ongoing costs and revenues that will be generated by the development of the subject lands.”

Modified - revised to address comment regarding timing of costs and revenues

Secondary Plans 1293 _ 10 States that 60% of new housing units “will be” in forms other than single detached dwellings. This is too prescriptive and does not reflect the housing mix forecast by Altus. Suggests removing or revising.

Modified - revised to address comment, points to Homelessness prevention and Housing policies

Secondary Plans 1293 _10 The language of this Policy needs to be softened, otherwise development will be driven out to satellite communities.

What analysis was undertaken to support this?How was this percentage calculated? What market analysis was used?

This is higher than the Altus projection of 53% single-detached dwellings.


Secondary Plans 1293 _10 See previous comments for City Building Policies – Homelessness Prevention and Housing, para 622. A requirement of 60% MDR units for new growth areas is significant, and appears to be well beyond what present projected demand would indicate a need for. To achieve this split, major changes to preferred housing forms would have to occur. It is unclear from the Plan how this shift will occur and what will encourage increased market demand for greenfield medium density housing opportunities. SUGGESTION: No revisions to the Policy are suggested, but it is unclear/unknown if the 60% non-LDR requirement can be achieved.


Secondary Plans 1293 _8 Insert a new 9. “A development staging plan, identifying the build-out timing of developable lands based on projected city-wide residential and non-residential construction.”


Secondary Plans 1293 _8 and conforms to asset management best practices. Modified - revised to address comment


Page 197

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanSecondary Plans 1293 Would the secondary plans dictate a better target than 60% (how was this target determined)?

Has there been given thought to minimums / maximums. When new zoning is developed we need to consider an all imposing zone to ensure a mix of housing types. Is it best to identify that in the secondary plans vs. the OP. It seems very prescriptive to identify the rate – how does this effect subdivisions? Secondary plans – Are secondary plans not considered a tool? Is the intention for these to stand alone - is that why they have their own chapter.

Modified - revised to allow flexibility, points to Homelessness prevention and Housing policies

Secondary Plans 1295 City staff has clarified that the intent of Policy 1295 is to “capture the integrated Planning Act and Environmental Assessment Act process for secondary plans and infrastructure planning within a secondary plan area”. MOECC staff is supportive of the intent of this Policy; however, the wording in the clause is not correct.Under the MEA Municipal Class EA, an integrated approach is available under two conditions:1. There is a Planning Act instrument (e.g. an official plan amendment, plan of subdivision application)2. The requirements of Section A.2.9 of the MEA Municipal Class EA have been fulfilled.It is suggested that Policy 1295 be amended along the following line below in order to accurately describe when an integrated planning approach may be implemented.A project contemplated and studied as part of a secondary planning process fulfills the requirements of the Environmental Assessment Act if all the requirements of the Municipal Class Environmental Assessment Integrated Approach are completed within an official plan amendment or other Planning Act instrument process which implements a secondary plan.


Secondary Plans 1295 This Policy doesn't make sense. Is it referring to Municipal Class EAs ? Schedule A of Munic. Class EAs describes them differently than this Policy. Is this Policy trying to say that an EA for SWM will be considered "minor"? That would not be appropriate. Asks for clarification as to what Policy is trying to say.

Modified - policy revised to include wording from provincial policies related to integrated secondary plan and environmental assessment processes

Secondary Plans 1296 The Special Policy Areas are listed on Map 8, SWAP and other secondary plans (London Psychiatric Hospital; Old Victoria Hospital Lands) are not shown. revised Map to illustrate the approved secondary plans.

Modified - maps revised to show secondary plan areas

Secondary Plans 1298 Policy #1298, Old Victoria Hospital Lands Secondary Plan should be added. Modified - revised to address comment


Page 198

Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools 1299 Whole Chapter Add new section “Growth Monitoring” and the following policies:

“Annually, monitoring will be conducted regarding the previous year’s growth and development. The monitoring program will consist of the following elements:1. The number of new housing units by type constructed and the departure, if any, from anticipated residential development identified in the City’s growth projections.2. The amount of new and added industrial, commercial and institutional floor space constructed and the departure, if any, from anticipated non-residential development identified in the City’s growth projections.3. The geographic location of constructed residential and non-residential units/space.4. The number of new housing units occurring within the Built Area Boundary.5. The cumulative surplus or deficit, of new housing units occurring within the Built Area Boundary in relation to the intensification targets. Should there be any significant deficits identified, an evaluation will occur of the performance and success of the Plan’s intensification measures and policies. Additionally, recommendations of short-term action items will be prepared that can be implemented immediately to more effectively accommodate intensification opportunities and/or provide for greater levels of intensification.6. Other items identified in the City’s growth plan, as applicable.

No change - addressed under GMIS policies in the Our Tools part of the Plan

Our Tools 1299 Whole Chapter Add new Policy 1320: “Future development will be monitored to ensure that a balance is maintained between demands for servicing and the overall fiscal capacity of the City to extend services or provide new capacity.”

No change - addressed under GMIS policies in the Our Tools part of the Plan

Our Tools 1299 Whole Part New Policy - "secondary uses, such as active and passive recreation, agriculture, community gardens, other utilities and uses such as parking lots and outdoor storage that are accessory to adjacent land uses, are encouraged on utility corridor lands, where compatible with surrdounding land uses. However, a proponent should be aware f the primacy of the electricity transmission and distribution facilities and that secondary uses require technical approval from Hydro One Networks Inc."

No change - landowner to approve uses

Our Tools 1299 Whole Part How do the Our Tools apply? The language in Our Tools doesn't match the rest of the policies (eg. Pre-consultation is a hot button issue)

No change - Our Tools is a technical portion of the plan and cannot be presented in plain language

Our Tools 1299 Whole Part Prescriptive wording will result in leveraging during the approval process. Modified - language reviewed throughout plan, more flexibility allowed in some sections

Our Tools 1299 Whole Part add policies to highlight expectations of proposals so that applications can be fairly analyzed and reviewed

No change - complete application requirements are provided

Our Tools 1299 Whole Part Our Tools needs a section on "Targets". Indicators and metrics to monitor and use adaptive management

Modified - revised to include monitoring program policies in Our Strategy

Our Tools 1299 Whole Part Targets should be important tools under Our Tools section. All targets throughout Plan should be listed here. Suggested targets: 1. London will be energy self-sufficient at the bioregional level, heating most of our buildings with geothermal and solar systems, generating our electricity using solar, wind, biogas and hydroelectric sources. 2. Ldn will have cut its CO2 emissions by 80% over 1990 levels. 3. Ldn will divert 100% of solid waste by focusing on reduction, reuse and recycling. 4. Ldn will grow 50-70% of its own vegetable and fruit by 2035, and be 90% self-sufficient at bioregional level. 5. All our watersheds will be on an improved trajectory of ecosystem health, encompassing aquatic and terrestrial components (water quality, woodland cover in upland and riparian forests, etc.). 6. 90% of all trips will be made on foot, bicycling and public transport.



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools 1299 Whole Part Targets

I have already mentioned the need for targets, which is a key tool that needs to be prominent in the Tools section with a list of all of the major targets set at 5, 10, 25 year planning horizons. Here is one more concrete target which I think the city needs put on that list, especially given the provinces high priority of improving pollinator health: o meadow (or short and tall grass prairie) coverage (providing pollinator habitat) will be 2% of London


Our Tools 1299 Whole Part Communicating progressTransparency, data collection and dissemination should also be listed under tools. Without these the city will lose the recently renewed interest by the public regarding civic matters. We need to see how the city is doing in key areas. What are the targets, how are we doing in reaching those targets? This should be readily available and not hidden under multiple layers of website space. And they should be kept up-to-date on an annual basis.

Modified - monitoring program policies added to in Our Strategy

Our Tools 1299 Whole Part Pattern language for sustainable developmentThis idea of pattern language, which I recommended in my earlier submission, also needs to go into the Tools section. City planners, along with all Londoners really, should be building a database of best examples of building and neighbourhood types and details: a pattern language of the city we want to see. The London Plan should not contain all these example, but should provide an explanation of what and why a pattern language is needed.

No change - addressed in City Design chapter and in urban design guidelines

Our Tools 1299 Whole Part Stewardship There should be a separate section on stewardship under Tools to describe how it can and will be fostered. One way is by the City running programs that educate the public, for example, through courses offered in the Spectrum magazine. Another way is through educational brochures handed out to all citizens or just groups of citizens that face a certain problem.

I think another important way will be through a Community-based School (and eventually schools) of Sustainability. This could be a joint effort by the City of London, Western, Fanshawe, TVDSB and local environmental organizations to offer various educational programs for the public (kindergarten to adults, average citizen to developer). How will we convince the staunch supporters of the grow-forever crowd if not through education?

No change - operation concern, not to be addressed in Official Plan policies

Our Tools 1299 Whole Part Financial toolsCurrently under tools, bonusing is really only offered to developers by allowing them to build taller structures if they offer development that is perfectly aligned with Policy goals. But what about bonuses to individual property owners who go above and beyond what the targets of London Plan call for? These incentives could be offered through super cheap financing of green infrastructure (1% loan for solar panels), through tax rebates, or actual cheques in the mail. I am sure there are many other ways the carrot can be offered to citizens to help London reach its goals.Similarly, development which the city doesn’t want to see (because it is too far from the core) but can’t really stop through zoning, could have all city financing cut off. If developers want to build greenfield subdivisions at the margin of the city, they can, but they have to build all of the servicing, including roads, etc. themselves.

No change - plan supports bonusing as per Planning Act. Community Improvement Plans also supported by plan


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools 1299 Whole Part example like Transit stations - zoning that doesn't "down zone" or pre-zone for uses than

presently exist or is not contemplated in Place Type so the applicant will have to go through bonusing to get back the height and density originally approved for under the current OP.

No change - issue addressed by legal non-conforming policies

Our Tools 1299 Whole Part Evaluation Criteria - suggest prepare infill guideline document to give guidance to the implementation process.

No change - infill addressed in various other guideline documents

Our Tools 1299 Whole Part Need to develop guidelines for an application versus the big picture and more granular. No change - guidelines are prepared for a variety of applications

Our Tools/City Design 1299 Whole Part Need more discussion about base/middle/top - concerns that it is a requirement even if it is a 2-storey building or a 40 -storey building.


Our Tools? 1299 Whole Part Re: Local Improvement Projects, the ACE sub-committee did work on Property Assessed Clean Energy (PACE) style program for London. ACE has recommended adoption of PACE for the city.

No change - specific programs not included in Official Plan policy

Our Tools? 1299 Whole Part Consider the inclusion of policies to promote sustainability and sustainability programs. Now change - included in green city chapterOur Tools 1300 P357, Policy 1300 states that Official Plan policies are designed to protect public health and

safety. Safe cycling though is referenced minimally in this document. Observed examples include p24, Direction 7_6 safe cycling infrastructure, p41, Policy 91 safe on-street cycling routes, p57, Policy 144 traffic calming, p70, Policy 192 grade separations safe for cycling and pedestrian movement, p147, Policy 521 public facility design layout for pedestrian and cycling safety, p231 Policy 898_6 wide sidewalks for safer access through parking lots, p239 Policy 917 site layout, building location, and design reinforcing comfort and safety. There should be more reference to safe pedestrian and bicycle oriented streetscapes visible in The London Plan, particularly on cycling.

No change - statement of authority for producing the Plan.

Our Tools 1301 MTO would request that “The Public Transportation and Highway Improvement Act” be added to the list of Provincial legislation that The London Plan will have regard to.

Modified - revised to add Public Transportation and Highway Improvement Act

Our Tools 1301 Policy 1301: Add the Provincial Parks and Conservation Reserves Act to list of relevant legislation, because Komoka Provincial Park is partly in City, so city may defer to Province on its operation and Province must consult City on management planning for the park.

No change - intent is not to list all legislation

Our Tools 1304 New bullet - Management of corporate assets. No change - not necessary in this policyOur Tools 1305 How are the vision, goals and objectives to be considered Policy? No change - Intent is to create an understandable plan. Vision and

goals provide clarity of direction through policy. The set important directions that are followed up in more specific policies. The Planning Act incldues that Official Plans should include goals, objectives, and policies

Our Tools 1305 States that all the text is considered as Policy. As noted previously, there are many statements in the London Plan that are more suited to a preamble section or the City’s strategic plan as they are broad statements that are not capable of being implemented. Suggests revising wording and document format to recognize that not everything can or should be considered Policy.

No change - such policies are important to the direction of the plan. It is consistent with the Planning Act descriptions of items to include in a plan.

Our Tools 1307 While MMAH understands that to fully understand that relationship between policies, etc. that the document should be read in its entirety, however, the nature of the document and the length makes this very difficult. More direction may be required by the City for individuals to understand which policies apply to a given property. RECOMMENDATION: Please see comments/concerns. Some additional direction is being sought by the Provincial Policy Branch of MMAH.

Modified - expanded "how to use this plan"


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools 1309 OMAFRA staff are concerned that the flexibility granted in this Policy section may unintentionally

lead to decisions being made which are not consistent with the PPS (2014). RECOMMENDATION: It is recommended that the City make the following modifications:“The boundaries between place types as shown on Map 4 of this Plan, are not intended to be rigid, except where they coincide with physical features (such as streets, road allowances, railways, rivers or streams) or lot lines. The exact determination of boundaries that do not coincide with physical features will be interpreted by Council. Council may permit minor departures from such boundaries if it is of the opinion that the intent of the Plan is maintained, that the departure is consistent with the PPS, and that the departure is advisable and reasonable. Where boundaries between place types do coincide with physical features or lot lines, any departure from the boundary will require an amendment to the Plan.”

No change - as discussed with province, policy is appropriate

Our Tools 1309 The London Plan notes that “The boundaries between place types as shown on Map 4 of this Plan, are not intended to be rigid except where they coincide with physical features (such as street, railways, rivers or streams). “ As many major street types use building height to frame or enclose the public right-of-way and Place Types depend on the street network to convey various mobility options, suggest that streets be deleted as a physical feature, thus avoiding an amendment to the Plan for minor departures.

No change - defining the street as a boundary can include properties fronting on both sides of the street.

Our Tools 1309 Given that boundaries are not intended to be rigid, the mapping on schedules should not be so precise to better reflect this Policy. Suggests revising mapping so that it does not precisely follow property lines for the proposed place types.

No change - base mapping is at property level, to be interpreted at 1:30,000 scale

Our Tools 1313 _2 remove wording "which are intended to serve the surrounding area only". No change - language is consistent with existing policy, per OPA 88 (OMB Decision)

Our Tools 1313 _4 remove wording "serving the immediate surrounding area" No change - language is consistent with existing policyOur Tools 1313 - provide definition for "Transmission lines". Is it the same as hydro transmission lines" Modified - transmission lines added to 1313_2Our Tools 1313 1313 - revised the wording to clarify that despite the Policy of this section, "Hydro-electric power

facilities which are intended to serve the surrounding area only" and "telecommunications works and transmission lines serving the immediate surrounding area" will be permitted in all areas of the city, including the flood plain or environmentally significant areas where it has been demostrated through an EA that is is the preferred location for the infrastructure

No change - addressed by other policies of the plan

Our Tools 1313 Many, if not all, of the uses listed in section 1313 are not permitted without justification in a prime agricultural area. To elaborate, the only permitted uses in a prime agricultural area are agriculture, agriculture-related and on-farm diversified uses. While these other uses may be permitted in the Rural Place Type in the City, they may only do so when their location is justified through an official plan amendment that demonstrates consistency with the policies of 2.3.6.1 (b) and 2.3.6.2 in the PPS (2014). Moreover, these uses shall be subject to the MDS Guidelines and setbacks as established in Policy 2.3.3.3 in the PPS (2014). RECOMMENDATION: Ministry staff require that an OPA be required for these uses in the agricultural area of the City and that all of the appropriate agricultural policies in section 2.3 of the PPS be reflected in this section of the Plan as required by the Planning Act.

Modified - revised to clarify that uses listed in 7-9 not permitted in farmland place type

Our Tools 1313 Policy 1313: Add new subsection noting that Telecommunications facilities are approved pursuant to municipal input to and approved by Gov't of Canada under the federal Radiocommunications Act. Suggests this is different than subsection 4 because they have different planning requirements from transmission lines.

No change - policy does not apply to other approvals required, permitted uses only


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools 1314 MOECC staff believe it would be beneficial for land owners and the public to know that a

number of the projects which may be contained in a Growth Management Implementation Strategy require completion of an environmental assessment process under the Environmental Assessment Act. They further believe there are temporal, financial, public information benefits and duplication of effort savings in combining a GMIS with a master planning approach under the MEA Municipal Class EA.

Modified - added wording "within the context of the City's servicing master plan"

Our Tools 1314 The notion that the GMIS will “ensure” orderly progression of growth is an overstatement. For example, the orderly progression of growth also depends on what types of actions Council takes that may be contrary to the recommendations in the GMIS. SUGGESTION: Remove:“GMIS will ensure the orderly progression of development “Insert :“GMIS will encourage the orderly progression of development “

Modified - revised to include the term "plan for"

Our Tools 1315 According to this Policy, financial sustainability is dependent on the adequacy of DC rates to finance required growth infrastructure and the impact of development projects on taxes and user rates. We ask that the financial health of DC reserve funds also be specifically mentioned. Further, we suggest some revised wording associated with tax/user rates. SUGGESTION: revised to: “Financial sustainability (as it relates to financing growth) depends in large measure on:1. The adequacy of Development Charge rates to finance infrastructure required by growth.2. The financial health of the applicable Development Charge reserve fund to support future infrastructure investments.3. The effects of development proposals on tax and user rates. Impacted by the non-growth share of infrastructure projects.”


Our Tools 1317 _10 Although it is the intent of this Policy to provide the City with protection against significant future cost obligations associated with infrastructure renewal, the Policy is a bit nebulous. Technically, all growth and development is expensive and financially disadvantageous over time, no matter what growth pattern emerges. It is suggested that the Policy be revisedd. SUGGESTION: Perhaps revised the Policy to be more specific than present.


Our Tools 1317 _7 This Policy requires that services are in place to supply an “adequate” amount of developable land. We request that a specific amount be identified, rather than leaving the definition of “adequate” open to interpretation. It is suggested that the Policy speak to a maximum of 5 years. A maximum would permit the City to defer infrastructure projects in order to avoid pre-mature investments not required due to a large supply of vacant and available lands. SUGGESTION: revised to: “Ensure that services are in place or planned to provide a maximum supply of 5 years of serviced lands in registered and draft approved plans to support the city’s physical growth and the city’s housing mix and affordability objectives. Should a development proponent wish to develop lands beyond the 5 year inventoried supply due to perceived economic benefits for the developer, services may be extended by the City with the cost solely borne by the proponent developer (i.e., no future reimbursement by the City).”



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools 1317 A new Policy is suggested that discourages private construction of DC-eligible infrastructure in

advance of GMIS/capital budget timelines without an MSFA. SUGGESTION: Add new Policy 1319: “The private provision of infrastructure in advance of the timing indicated in the GMIS and capital budget is discouraged. Unless a development proponent and the City have entered into a Municipal Service and Financing Agreement, the City will not provide compensation for DC-eligible infrastructure constructed in advance of GMIS/capital budget timelines.”


Our Tools 1319 _1 So far these estimates are not done on whole life cycle costing but this will be coming into effect in the future and will need to be considered in the process.


Our Tools 1319 _3 This review needs to be consistent with the best practices of asset management and include whole life cycle costing, level of service considerations and risk management.


Our Tools 1319 _5 The wording of this Policy is carried over from the present Official Plan. The wording is slightly inaccurate, given that servicing arrangements do not pay development charges. It is suggested that the wording of this Policy be revisedd. SUGGESTION: revised to: “All servicing arrangements must be consistent with long-term planning, servicing and financing strategies and policies. Development benefitting from temporary servicing arrangements must contribute to the cost of providing long-term servicing through the payment of development charges, as outlined in the Development Charges By-law.”


Our Tools 1319 _5 Add corporate asset mangement planning. Modified - revised to address commentOur Tools 1319 _6 Add - and asset management... Modified - revised to address commentOur Tools 1319 Growth Financing, starting at s. 1319: Does this consider maintenance and later retrofit costs?

Especially for greenfield development areas outside PTA?Modified - revised to include corporate asset management

Our Tools 1320 Minor wording additions are suggested to include reference to the Development Charges Background Study, given that the present MSFA Policy is not attached as a schedule to the DC By-law. SUGGESTION: revised to: “Consistent with the provisions of the Development Charges Act, the City may provide for Municipal Service and Financing Agreements (MSFA) to permit a development applicant(s) to accelerate works outside of the timing established in the capital budget. MSFA principles, parameters, policies and criteria will be set out in the City’s Development Charges By-law and/or Background Study.”


Our Tools 1321 Add and Corporate Asset Management Policy. No change -Our Tools 1322 Doesn’t have part lot control listed – perhaps it should? Same considerations as consent Is step

back part of the podium for building design? Is this defined?Modified - revised to include Part Lot Control Exemption

Our Tools 1324 _4 Should cultural heritage resources impacts be identified or “the above list is not exhaustive” sufficient?


Our Tools 1324 _4.k Policy #1134 Subsection 4k should read “Loss of trees and tree canopy cover” Modified - revised to address commentOur Tools 1324 _5 "Level of certainty" is mentioned in Policy 924.13, but where is the certainty in Policy 1324.5?

What is meant by "sensitive to its context"? What is meant by a "planning perspective" (is this the City Planner's perspective)? What is meant by "surrounding area" (how big?)? Can you show an example from another City of an "analysis of fit, based on type of application and its context" (No idea what this looks like, or how large a geographic area will be drawn to define a relevant neighbourhood/Planning District/or "surrounding area")? Why is the "analysis of fit" only a "may" direction rather than a "shall/will" direction? The list of things that "may" be included in analysis of fit are mostly built form, and there's nothing to evaluate "neighbourhood character" or "sensitivity to context" which may be easiest to dismiss (e.g. Rexall at "gateway" to Bishop Hellmuth HCD).

Modified - City Design policies revised to provide more direction for measuring fit. Level of detail in comment is to high for Official Plan policy. Deleted "from a planning perspective"


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools 1324 _5 Terms should be defined, ie - does it mean existing or future context? Does it refer to form?

Density? Use? Should allow certainty without removing flexibility.Modified - revised to include "density"

Our Tools 1324 _5 Urban London Place Types - Rapid Transit Urban Corridors: "fit" criteria for new development may not allow for significant intensification near neighbourhood areas.

No change - fit allows for substantial intensification in appropriate locations

Our Tools 1324 Sentence 5. speaks to the degree to which the proposal fits within its context. Bullet k. should reference not only the relationship of the proposal to adjacent heritage properties but in addition the relationship of the proposal to heritage structures extant on the site.


Our Tools 1324 page 362 – clause 1324 – the words “the above list is not exhaustive” should be qualified by stating that every effort will be made to provide a complete list of studies. This would add “certainty”.


Our Tools 1324 In clause 2, add ‘and guidelines’ after ‘policies’. No change - London Plan include policies, not guidelinesOur Tools 1326 Create a separate Section with Policies for Pre-application which includes an initial review of

the proposal with the proponents, followed by a process for obtaining Conditional Approval prior to it being necessary to submit a Complete Application. PRIOR to any design being undertaken, a “PRE”- Pre Consultation Meeting should be considered. As this clearly is the PRE- consultation the current Pre-consultation step should be relabeled.

No change - it is not appropriate in the context of planning applications to provide "conditional approval"

Our Tools 1331 Asks if there will be new Guidelines created for an application in order to prove "fit"? If so, when? And will there be consultation with neighbourhood (community assoc'n) leaders to discuss the meaning of "Neighbourhood Character"?

No change - City Design policies indicate intensification guidelines may be created. An application process would engage the public regarding impact and fit

Our Tools 1335 & 1336 The first part of 1336 is quite repetitive of 1335. Suggests removing the beginning of Policy 1336 up to “The required report/study...how the proposed development and/or change in land use will be serviced by transit....”


Our Tools 1336 Recommendation: Transportation Studies must also include evaluation of pedestrian and cycling mobility in their analysis.


Our Tools 1336 What does this analysis entail, and who does it? No change - analysis to be included as part of a complete application

Our Tools 1342 To assist development proponents preparing reports/studies regarding financial matters and to clarify the intent of financial impact assessments, several new policies are proposed. SUGGESTION: Add new policies:1343_ The terms of reference for fiscal impact studies will be jointly determined by the City and the owner/applicant at the time of the request. The study will be prepared and may be peer reviewed at the owner/applicant’s expense. Development applications or proposals that otherwise comply with the relevant policies of this Plan may be refused or deferred on the basis of financial impact and burden on the City, if suitable mitigation measures are not available.1344_ The Growth Management and Growth Financing policies contained in the Our Tools chapter of this Plan provides more guidance.


Our Tools 1342 Add, identify on whole life cycle costs, level of service and risk for any City of London infrastructure impacted or required by the development,


Our Tools 1343 1345 & 1437 Policy 1343-1345, and 1437 - LACH recommends that more direction be given to the requirements of a Heritage Impact Study. This could be done by expanding on the policies of 1343-1345, and/or by developing or adopting a detailed Guideline Document to be included under the Cultural Heritage section of Policy 1437.



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools 1353 The requirements of the Reports/Studies to Address Agricultural Matters are vague and require

additional detail specify what the City expects to be documented when it comes to agricultural features. RECOMMENDATION: The Ministry recommends that this section be expanded to include additional details around agricultural impact assessment reports. An example document has been provided to generate some ideas and discussion around what might work for the City locally. The additional details can be set out in this section of Plan, or contained in a separate standalone guidance document listed in section 1437 on page 385. OMAFRA supports whichever approach is more suitable locally, provided that the result improves the product that is being submitted and ensures consistency with policies 2.3.3.2 and 2.3.6.2 of the PPS (2014).


Our Tools 1353 It is possible that not all proposed developments will require a buffer to agricultural features. Suggests rewording section of Policy as follows: “...identify the areas that are to be employed as a buffer, if necessary, between the proposed development and/or change in land use....”

Modified - revised for consistency with the PPS.

Our Tools 1360 to 1364 Public Participation" provisions remain over-passive and may leave the public feeling threatened by "inward and upward" and higher potential density of land use. A public that is that absent full end-user knowledge may also become a public that kicks back at the The London Plan when it goes into action. A public that knows its own options and its power to make planning events work as a win-win all around will in contrast support The London Plan in action. There seems to be no knowledge-driven improvement to the Public Participation process that would leverage citizen efficiency to the advantage of the City's often repetitive "back-to-planning" meetings process.

No change - engagement project is underway, outcome may result in changes to public engagment policies

Our Tools 1362 _2 Suggest you remove ‘hosted by City staff” – best to leave generic Modified - revised to address commentOur Tools 1362 Recommendation: Specifically identify the Cycling Advisor Committee and all Council

Committees as a source of input to the approval process and a requirement for the City of London to seek their input.

Modified - added policy regarding important role of advisory committees

Our Tools 1362 Comment related to Policy 159: Notes that in Policy 1362 the engagement techniques are ones the Municipality "may" utilize, and list includes "direct consultation with various groups/individuals. Asks why there are not specifics about proponents meetings with neighbourhood and why this is a "may" instead of "shall" since all other techniques are fairly standard approaches.

No change - flexibility is appropriate to allow for consideration of best practices. Acknowledges that different applications require varying engagement approaches

Our Tools 1364 _4.b The "Public Participation" notice process states at one point that meeting notice is sent to " Every owner of land within 120 metres of the area to which the proposal applies, as shown on the last revisedd assessment roll." It would be fair to notify all residents including TENANTS in apartment buildings within the distance limits. Reasonably speaking you cannot expect citizens to routinely check the newspaper or a City website for abstruse notices on properties and notice critical applications. No average citizen has the time for that in daily life; but a key planning decision on a property near them on which no notice ever arrives at their apartment can alter their local landscape forever. Case in point, I live on Elmwood Avenue and only my Landlord received notices on two nearby applications that I would have preferred to have had input on.

No change - issue is being addressed through the planning process engagement project. Direct notification is included as a possible improvement.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools 1364 If the goal is as stated to make "wise planning decisions" then it would be fair to notify all

residents including TENANTS in apartment buildings within the distance limits. Reasonably speaking you cannot expect citizens to check the newspaper of a City website for abstrusely worded planning notices on all city properties with such frequency that they notice critical applications. Development applications are inherently often obscure in import and their impact not obvious unless directly delivered. Case in point, I live in South London and only my Landlord received notices on two nearby applications that I would have preferred to have had some input on.

No change - issue is being addressed through the planning process engagement project. Direct notification is included as a possible improvement.

Our Tools 1365 As noted previously, MOECC staff believe this statement of “consultation” with First Nations is likely inadequate. This Policy should be strengthened with regard to First Nations Consultation.


Our Tools 1371 to 1379 Why two types of bonusing and not just one with the combined set of objective criteria for it. Some members state that the Policies for two tiers of bonusing create a system of planning by negotiation. This approach to planning creates uncertainty and is discretionary based on the interpretation of staff and the decisions of Council. What is an acceptable bonus by one staff may not be acceptable to another. What is acceptable to one Council may not be acceptable to a subsequent Council. The success of bonusing relies on the ability, resources, to sell a project to the community. Developers who are well funded and promise great amenities will gain approval, while small scale projects that cannot offer the “bonus” features will not be approved. The demand for these projects will be lost to the larger projects. There may be other preferred approaches to incentives for redevelopment.


Our Tools 1371 to 1379 Could road widening dedications be a criteria for bonusing? No change - road widening is a requirement, not to be confused with bonusing.

Our Tools 1371 to 1379 Missing from bonusing list: 1) retention of heritage buildings, 2) addition of public realm elements, 3) LEED Certification


Our Tools - Bonus Zones 1371 to 1379 As-of-right residential bonusing should be included to offer certainty to a developer No change - can be inclduded in Zoning By-law

Our Tools 1371 Policy 1371: can the bonus be something other than height? Doesn't support tall buildings, so asks if bonus could be lower development fees.

No change - not permitted in legislation

Our Tools 1371 Should “permitted” be revisedd to “prohibited”? Modified - revised to improve clarityOur Tools - Bonus Zoning 1372 to 1379 Can bonusing provisions be applied to required increased buffers to natural areas? Is it

permitted by the Planning Act? If so add "elements of the natural heritage system" to list of community benefits.


Our Tools 1372 Conservation of cultural heritage resources is not identified; should it be? (Cultural Heritage Policy 658)


Our Tools 1373 States that “Type 1 Bonus Zoning allows for a height or density that is at, or below, the standard height or density limit allowed...” How is it a bonus if a proposal is at or below the allowable height / density? Wording is also inconsistent with Policy 1375 which refers to additional height or density beyond what would otherwise be supported. Policy refers to Table 11, which would require someone to search the plan for the applicable table. Suggests providing clarification / consistency between policies 1373 and 1375. Also provide the page number for Table 11 in paragraphs 1373 and 1377 to assist users of the Plan.

Modified - revised to improve clarity, Bonusing is related to zoning, not the standard height in the London Plan place type

Our Tools 1378 Bonus policies - 1378 (1375) should include "such as" or something to the effect that this list is not exhaustive.


Our Tools 1378 “…or matters “ such as : Modified - revised to address comment


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools - Bonus Zones 1378 some Type 2 bonusing requirements are unreasonable and should be provided by public

initiativesNo change - bonusing is optional for applications

Our Tools - Bonus Zoning 1378 some Type 2 bonusing requirements are unreasonable. These include transit infrastructure and public facilities, which should be provided by the City. A more reasonable list of type 2 bonusing requirements should be establsihed.

No change - bonusing is optional for applications

Our Tools - Bonus Zones 1379 Clarify what is of 'public value' and how this is quanitified/calculated. No change - as in all Ontario municipalities, this is not a mathematical equation. It is an evaluation of public benefit that will be made by Council.

Our Tools 1387 Sentence 5 of the Criteria for Reviewing Applications appears to run contrary to the controls established by The London Plan for amendment to the Place Types.

No change - place types and zoning is distinct

Our Tools 1388 The conditions which the Committee of Adjustment may deem appropriate to attach to the approval of an application for minor variance should not negate the application of the urban design guidelines associated with the applicable Place Type.

No change - comment is consistent with intent of plan

Our Tools 1397 OMAFRA recommends that this section be expanded to also prohibit severances of temporary uses. RECOMMENDATION: The following are the requested revisions:“It is not intended that temporary uses will be permitted on a long-term basis. Permanent structures for temporary uses will not be permitted, nor will the severance of such uses.”

Modified - revised to to prohibit severances of temporary uses.

Our Tools 1398 The Plan should include language addressing the importance of differentiating between complex or significant projects, which require more thorough review, versus projects for which the review should be ‘streamlined’, especially when they are consistent with the applicable zoning parameters, design guidelines and other priorities identified in the Plan.


Our Tools 1398 extend site plan control to residential developments, and establishing urban design guidelines that include a list of materials

No change - issue addressed through City Design policies

Our Tools 1401 _2 Add site servicing to list. Modified - revised to include suggestion in 1401_1 for clarityOur Tools 1403 _1 & 1403_11 Policy 1403_1, indicates that site plan control is to provide for development which “implements

all the City Building and Place Type policies of this Plan” and Policy 1403_11 “implements the City Design policies of this Plan”. This suggests that any development subject to Site Plan Control is required to be in conformity with the new Official Plan. In instances where a small building pad or addition is proposed on one of our Clients’ sites, this could potentially necessitate either a complete redesign of the Site, or an amendment to the London Plan.

No change - Site Plan applications intended to comply with the London Plan

Our Tools 1403 _11 Policy 1403.11: suggests new ending to this subsection stating "…including a strong focus on environmental sustainability"

No change - additional wording is not necessary

Our Tools 1404 _11 ADD water and water servicing. No change -Our Tools 1406 Where required Modified - revised to address comment, removed "always"Our Tools 1407 Policy 1407: Great section and should be expanded since new place-type approach appears

better suited to the Development Permit System than zoning by-law system. Perhaps policies detaining types of conditions and criteria for DPS?

No change - if a DPS is implemented, amendments would be required to the plan.

Our Tools 1410 Add - Corporate Asset Management Plan Modified - revised to address commentOur Tools 1419 _4 States that any lot created must “conform” to adjacent development. Does this mean it needs to

be the same as adjacent development? Wording is too restrictive. Suggests considering revising Policy as follows: “That the size and shape of any lot(s) to be created is compatible with adjacent development and conforms to any registered development agreements....”


Our Tools 1419 _9 Are there areas where private services are permitted? No change - addressed in Civic Infrastructure chapter.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools 1429 _3 The vacant land condominium policies were changed through an OPA earlier this year.

Suggests revising Policy to reflect approved OPA.Modified - amended to be consistent with OPA 582

Our Tools 1429 _3 Changed as to recent re-zoning (needs to be changed to reflect this) Modified - amended to be consistent with OPA 582Our Tools 1429 _3 & 1419_4 The London Plan policies for VLCs retained sub-sections (iii) and (vi), but left out subsections

(iv) and (v) to the current OP policies (adopted through OPA No. 582). As incorporated into Section 19.15.4 of the current OP, revised these policies so that they are consistent with OPA 582.

Modified - amended to be consistent with OPA 582

Our Tools 1429 _4 States that the minimum number of units in a condominium will be “more than adequate” to allow for operation of the condo corporation. How many more units would be considered as ‘more than adequate’? Number of units should simply be “adequate” to allow for operation. revised wording to state: “....The minimum number of units to be included in each condominium corporation will be adequate to allow for the reasonable, independent operation of the condominium corporation.”


Our Tools 1431 Under Civil infrastructure guidelines: Need to add Corporate Asset Management Plan. Modified - added as a guideline document under Civic Infrastructure Guidelines

Our Tools 1432 Policy 1432: Further reiteration of concern about guideline documents being outside of Planning Act processes. How would conflicts be addressed? Inappropriate because a denial of natural justice to have policies linked to guidelines outside Planning Act. Consider using Province's "Manuals" instead, which are not Policy. Suggest Policy wording change so that "Manuals may contain suggested approaches, standards...."

Modified - revised to remove word "policy"

Our Tools 1432 page 384 – clause 1432 - There remains a concern about the relationship of Policy and Guideline documents. LAPC feels that the City prepares Guidelines but administers them as Policy. That creates inflexibility. LAPC recommends a definition (Glossary) of GUIDELINE and how it is to be applied. Guidelines and policies should be distinguished and different. Guidelines should be flexible and “objective based” such that proponents can offer alternative solutions as long as the objective is met. (Ian Seddon has submitted comments that elaborate on this more).

Modified - revised to remove word "policy"

Our Tools 1436 Policy 1436: Suggest changing "guideline document" to "Manual" No change - intended to include guideline documentOur Tools 1436 Heritage Conservation District Plans have been identified as Guideline Documents, which

contradicts their status in OHA 41.2(2)Modified - removed HCDs from list


1437 _e "creeks" should be singular. No change - reference is to multiple creeks, therefore is plural

Our Tools 1437 _h. - Natural Heritage Guidelines

h. : Please note that the spelling of “Kilally” should be “Killaly” in a future conservation master plan for Killaly Meadows ESA. It was named after Hamilton Hartley Killaly, a former Londoner and MPP.

No change - usage consistent with other City documents

Our Tools 1437 Natural Heritage Guidelines

The Sifton Bog ESA Conservation Master Plan 2009 –2019 should be added to the list of guidelines.


Our Tools 1437 Recommendation: Add reference to the Complete Streets Manual that is in progress. No change - will add by OPA when completed and adoptedOur Tools 1437 Will any of the Natural Heritage Guidelines listed within Policy 1437 be updated as part of this

Official Plan review?No change - list includes most up-to-date guidelines

Our Tools 1437 There is no reference to secondary plans in this section of the plan, however there is a listing of area plans in Policy 1439 (pg. 386). Also, MOECC find it curious that the Civic Infrastructure guidelines do not include water, sanitary or stormwater management plans or guidelines.

No change - there are long-term plans for stormwater, sanitary services and water service. Secondary Plans are not guidelines, refer to Secondary Plan Part of the Plan.

Our Tools 1437 Policy 1437: guidelines to manuals. No change - listed documents are guidelines


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools 1437 There is a very extensive list of guideline documents. Are all of these still relevant and

applicable? Consideration should be given to amalgamating some guideline documents to reduce their numbers and/or reviewing and confirming that all the documents are still relevant and applicable given that some of them are nearing 20 years old.

No change - guidelines documents will be reviewed in separate process in the future. Amendments will be required to add to plan.

Our Tools 1437 Include the Heritage Community Improvement Plan, Is there a difference between j (Heritage Places – A Description of Potential Heritage Conservation Districts) and m (Potential Heritage Conservation Districts)? DM doesn’t recall so. Develop Guideline Documents for the identification and evaluation of CHL, HCD, and individual cultural heritage resources? HIA Terms of Reference? Include LACH Terms of Reference as a Guideline Document

Modified - updated list, items must be adopted for inclusion in list

Our Tools 1437 Several additional guideline documents are suggested for inclusion in the various lists. SUGGESTION: Add under Parks and Recreation:- “Parks and Recreation Master Plan”;under Civic Infrastructure Guidelines:- “Growth Management Implementation Strategy”;- “Water Servicing Development Charge Background Study”;-“Stormwater and Drainage Development Charges Update Study”;- “Wastewater Servicing Master Plan Update and- Development Charge Background Study”;- “Transportation Development Charge Background Study.”


Our Tools 1437 Policy #1437 should include the following under the Natural Heritage Guidelines: Emerald Ash Borer Strategy 2011, Urban Forest Strategy 2014, Urban Forest Strategy Implementation Plan 2014, and Tree Protection Guidelines


Our Tools 1439 Policy 1439: Why has Byron Southeast Area Study (circa 1982) been omitted from list of area plans? There was an OMB case on it, too. This study contained policies about the future land uses of Byron Pits after rehabilitation and surrender of aggregate licenses.


Our Tools 1444 The policies of this section need to ensure that they reflect that community improvement plans cannot be applied to greenfields.

No change - policies reflect Planning Act language

Our Tools 1445 Introductory paragraph is somewhat repetitive and awkward. Consider rewording as follows: The City may pass by-laws under the authority of the Planning Act or Municipal Act or other Provincial legislation which will apply to designated areas of the city to assist in, or facilitate, the implementation of the vision, key directions and policies of The London Plan, for matters such as, but not limited to:....”


Our Tools 1445 In section 1445 there is a list of municpal by-laws. Some of the most common by-laws we enforce which directly impact community livability are not listed yet others which are very minor in terms of our workload are nted. Would you like a list of by-laws with brief descriptions in place of the proposed list? I note that some need to be listed in the OP such as Property standards due to provincial legislation.


Our Tools 1448 to 1458 especially 1457

City should work on getting upland "connectors" that are marked on natural heritage maps. Is Natural Heritage System dedication in addition to parkland dedication?

No change - there is no legislative requirement or authority for natural heritage dedication. 1458 modified to allow for natural heritage linkages

Our Tools 1448 Policy #1448. The City may not always acquire lands in partnership with UTRCA. There are two other CAs in London.


Our Tools 1457 Policy #1457. “ …lands containing features such as ravines, woodlots and other vegetation or variations in topography may be accepted at a rate which reflects their relative development value as per the Parkland Dedication By-law

Modified - parkland acquisition and dedication policies to recognize that by-laws may be established


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools 1458 _5 Policy #1458 (5) should read: Acquisitions which will serve to create a more continuous or

linked Natural Heritage or Park system.Modified - revised to address comment

Our Tools 1459 Additional uses besides residential may be susceptible to adverse noise, vibrational and particulate transmission effects from rail lines et al.

Modified - revised to indicate sensitive land uses

Our Tools 1461 _4 States that noise impact studies will be undertaken “based on ultimate traffic volumes as established by the Mobility policies of this Plan....” There are no traffic volumes included in the London Plan. Consider revising.


Our Tools 1463 _2 MOECC staff requires clarification as to how provincial input will be obtained in Bullet 2 in view of One Window/Municipal Plan Review.

No change

Our Tools 1464 _2, 3 & 4 As above, MOECC are unsure how circulation to the MOECC in Bullets 2, 3 and 4 will be operationalized under One Window/Municipal Plan Review.

Modified - revised to remove reference to Ministry

Our Tools 1466 OMAFRA recommends that this section be modified to reflect the language of the latest MDS Guidelines and the intent of the PPS, Policy 2.3.3.3. RECOMMENDATION: The following are the requested revisions:“Any proposed planning and development application for all place types that would reduce the distance between outside of the Built-up Aarea Boundary and an existing livestock operation will be reviewed for its effects on livestock operations shall meet the required odour setbacks in accordance with the provincial Minimum Distance Separation (MDS) Implementation Guidelines and Formulae, as amended by the province from time to time requirements.”

Modified - revised for consistency with provincial policy wording

Our Tools 1466 Does this Policy apply to land use designations within the Urban Growth Boundary?

Will the City require MDS I compliance for developments inside the Urban Growth Boundary Place Type (See Implementation Guideline 37 for Minimum Distance Separation.


Our Tools 1467 OMAFRA recommends that this section be modified to reflect the language of the MDS Guidelines and the intent of the PPS, Policy 2.3.3.3. RECOMMENDATION: The following are the requested revisions:“Prior to the issuance of any building permit for the establishment of a new livestock building or structure, or an expansion to an existing livestock building or structure any new or altered livestock facility, including manure storages and other waste handling facilities, the City will require compliance with the Minimum Distance Separation ( provincial MDS II setbacks) requirements and compliance with the provisions of the Zoning By- law.”



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools 1468 OMAFRA recommends that this section be modified to reflect the language of the latest MDS

Guidelines and the intent of the PPS, Policy 2.3.3.3. RECOMMENDATION: The following are the requested revisions:“The MDS I formula, established by the Ontario Ministry of Agriculture, Food and Rural Affairs, will apply as follows:1. The City will require compliance with the MDS I requirements setbacks for all types of development proposed by building permit on all existing lots of record.2. Livestock facilities operations that exist within the Farmland or Rural Neighbourhood Place Types will be provided protection from the encroachment of all new development including all planning and development applications through the application of MDS I setbacks requirements at the time of planning and/or development review.3. The City does not require compliance with the MDS I setbacks requirements for surplus farm dwelling severances, except where the surplus farm dwelling is located on the same lot as the subject livestock facility prior to the consent being granted in accordance with the Rural London policies of this Plan.4. The City does not require compliance with the MDS I setbacks requirements for the construction of a new dwelling that is replacing a dwelling that is destroyed in whole, or in part, by a catastrophe, provided that the new dwelling is located no closer to a livestock facility than prior to the reconstruction catastrophe.5. The City will require compliance with the MDS I setbacks requirements for any proposal to expand the Rural Neighbourhood Place Type.6. Lands within the Future Growth Place Type that cannot be developed for urban purposes due to MDS I setbacks requirements may be permitted to develop for municipal infrastructure that does not allow for passive/active recreation uses.7. Lands within the Future Growth Place Type that cannot be developed for urban uses due to MDS I setbacks requirements may be draft approved for plans of subdivision or condominium only where a holding zone or draft plan conditions requiring phasing are applied to these lands to preclude development until such time as the subject livestock facility is removed.8. The City will require treat cemeteries in compliance with the MDS I setbacks for all new or


Our Tools 1469 OMAFRA recommends that this section be modified to reflect the language of the latest MDS Guidelines and the intent of the PPS, Policy 2.3.3.3. RECOMMENDATION: The following are the requested revisions:“The MDS II formula, established by the Ontario Ministry of Agriculture, Food and Rural Affairs, will apply as follows:1. The creation, alteration or expansion of any livestock facility operation within the Farmland, Rural Neighbourhood and Future Growth Place Types shall meet the appropriate MDS II setbacks.2. The City does not require compliance with the MDS II setbacks for the reconstruction of a livestock facility, provided that it is located no closer to surrounding development after reconstruction and the livestock facility will house the same number and type of animal on the same style of manure system that existed prior to the reconstruction. The construction of a livestock facility that is replacing a livestock facility that is destroyed in whole or in part by a catastrophe.3. For the purposes of MDS II setbacks, the City will treat all inactive cemeteries as Type A land uses in accordance with the Minimum Distance Separation Implementation Guidelines. For clarity, such cemeteries shall be documented in an appendix in the Zoning By-law4. The City does not require compliance with the MDS II setbacks between new or altered livestock facilities and existing agriculture-related and on-farm diversified uses.”



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools 1470 Policy 1470: Suggests that maps be available as Shapefiles for download. Should also be a

zoomable map for all layers. "Smart City" needs smart mapping applications.No change - it is a legal requirement to provide maps hard copy of maps. Will also provide maps in new creative ways

Our Tools 1470 Plan reads that the maps are the “official copies” of the London Plan. Are we to have large scale copies available via Web? Might have difficulty arguing a position on such a small map at the OMB - Maps are shown NTS but are created to scale. Are we intentionally not displaying the plot scale of these graphics?- The maps seem disjointed as the beginning of the plan integrates map 1,2,3 directly into the document, whereas the plan later begins to reference appendixes of attached plans 4,5,6 etc. should we integrate all maps into the plan or all maps into appendixes? Perhaps both?

Modified - revised to address comments

Our Tools 1476 Need to compare the proposed Map 6 to the existing Schedule B-1. Current LP schedules are not of a quality sufficient for detailed review and analysis. Proposed schedules were recently received from the City in a format that is suitable for detailed review.


Our Tools 1478 This map does not show any of the approved Secondary Plans (e.g, SWAP, Psychiatric Hospital, Old Victoria Hospital)


Our Tools 1485 Glossary Add reference to cultural heritage in glossary Modified - revised to address commentOur Tools 1485 addition/expansion of the glossary will be assist in creating more clarity. Modified - glossary to be expanded to include additional termsOur Tools 1485 Suggest glossary needs definition for "LIC" No change - defined in policyOur Tools 1485 Suggest definition for complete streets includes "ecology" and "corridors for wildlife movement"

and "placement of geothermal".No change - not consistent with use of term in plan

Our Tools 1485 New terms should be added to glossary: "ecosystem services", "ecosystem health" and "LIC". No change - terms not used in plan

Our Tools 1485 Suggest glossary needs definition for "Ecosystem Services" and definition for "Ecosystem Health".

No change - terms not used in plan

Our Tools 1485 Suggest Plan needs definitions for "Working in Place" and "Shopping in Place" No change - terms not used in planOur Tools 1485 There are terms and words used throughout that are either colloquial, of frequent use and/or

convenient, but care should be made to avoid them or define them in the Glossary. The term “good fit” is an example. “LOS” is another ( level of service) example.

Modified - revised to add "level of service" to glossary, "good fit" is subjective and open to interpretation.

Our Tools 1485 Why was January 2011 selected as the date? No change - date the built area boundary was establishedOur Tools 1485 It is pointed out that the ministry’s D series guidelines relate to more subjects than land use

compatibility. The City needs to include a definition for “low and moderate income households”, consistent with the PPS, 2014, in this section of the OP.

Modified - incorporated Policy to be consistent with the PPS

Our Tools 1485 - a variety of terms for hydro corridors, including "utility", "utility corridor", "hydro corridors" and "rights of way". It is unclear whether these terms have different meanings. Define "utility" and "utilities" to include in glossary "electricity generation facilities and transmission and districbution systems."

No change - too detailed and operational for official plan

Our Tools 1485 Update cultural heritage landscape to incldue: "means a defined geographical area that may have been modified by human activity and is identified as having cultural heritage value or interest by a community, including an Aboriginal Community. The area may involve features such as structures, spaces, archaeological sites, or natural elements that are valued together for their interrelationship, meaning or association. Such a cultural heritage landscape is valued by Londoners and is of significance to an understanding of the histories or a people or place."



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools 1485 Glossary - Adjacent: In terms of assessing potential impact of proposed development or site

alteration on the heritage attributes of a cultural heritage resource, adjacent can include real properties or sites that are contiguous; real properties or sites that are directly opposite a cultural heritage resource separated by a laneway, easement, right-of-way, or a roadway; and/or real properties or sites upon which a proposed development or site alteration has the potential to impact identified visual character, streetscapes, or views as defined within a statement explaining the cultural heritage value or interest of a cultural heritage resource (including Statement of Cultural Heritage Value or Interest, heritage designation by-law, heritage character statement, Heritage Conservation District Plan, and/or reasons for designation).

Cultural Heritage Resource: means a human work or a place that gives evidence of human activity or has spiritual or cultural meaning or value, and which has been determined to have historic value. Cultural heritage resources include both physical and intangible resources, properties protected under the Ontario Heritage Act, built heritage resources, cultural heritage landscapes, archaeological resources, paleontological resources, and both documentary and material heritage.

Conservation: All actions or processes that are aimed at safeguarding the heritage attributes of a cultural heritage resource so that it retains its cultural heritage value or interest and extends its physical life. This may involve preservation, rehabilitation, restoration, or a combination of these actions or processes.


Our Tools 1485 The definition of “Infrastructure” matches that used by the Provincial Policy Statement; however, this definition only speaks to “hard services” being considered infrastructure. Perhaps we could expand on this definition to include “community infrastructure” such as libraries, police and fire facilities, etc., supportive of infrastructure recovery through development charges. SUGGESTION: revised to: “Infrastructure means physical structures, facilities and corridors that form the foundation for development. Infrastructure includes sewage and water systems, septagetreatment systems, stormwater management systems, waste management systems, electricity generation facilities, electricity transmission and distribution systems, communications/telecommunications, transit and transportation corridors and facilities, oil and gas pipelines and associated facilities. Infrastructure also includes community infrastructure, such as parks, libraries, community centres, police and fire facilities.”


Our Tools 1485 Both the Development Charges By-law and the Development Charges Background Study are italicized in the Plan, indicating that they are defined in the glossary; however, no definitions exist in the Plan for these terms. SUGGESTION: Add:“Development Charges Background Study means the City’s study of projected growth, capital infrastructure projects and costs, all used in calculations to determine the amount of net recoverable funding required to be generated by development charge rates to pay for future growth-related infrastructure projects. The Background Study will be consistent with the provisions of the Development Charges Act.”“Development Charges By-law means the City approved by-law for requiring fees to be paid by applicable development for the recovery of growth-related capital infrastructure costs. The Development Charges By-law will be supported by the Development Charges Background Study and will be consistent with the provisions of the Development Charges Act.”

Modified - revised to address comment, DC by-law added


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanOur Tools 1485 Add - Corporate Asset Management Plan- documents the plan for the City to manage its

infrastructure under its direct ownership and control, satisfying provincial needs while optimizing and standardizing asset management practises in London.



Table 1 to Table 5 Presumably these figures are based on the Altus projections which were completed as part of the background studies for the London Plan. However, there is not a table illustrating the forecasted housing mix projections which is essential to understanding future demand. Suggests a table should be included to show the Altus projections with respect to type/mix of housing units projected.

No change - intent is to focus on higher level figures


Table 6 Questions arise to vehicle zones and which areas are defined where (Engineering issue). Engineering needs to understand how the current street hierarchy relates to the new zone designations Ma ins tre e t ha s s ide wa lks

- Transportation master plan cross-reference- Need to update design manual - All the major streets speak to a high standard of urban design, but what does that mean? Is that just the chart? Do we really need the highest standard on every single major street? Perhaps a more strategic approach is warranted to focus on significant areas.

Modified - table revised to improve clarity.


Figure 1 P72 figure 1 street design zones – add bike lanes to the graphic to align with p71 Policy 200, that references pedestrians, cyclist and transit in figure 1.



Figure 1 Shift the Property Line left to the edge of the Development Zone allowing the pedestrian zone to extend over the Property Line into the Development Zone but not vice versa.

No change - property lines are consistent with policies

Maps Map 1 , 2 & 3 Maps 1, 2, 3 are not included in the Maps section. Even if included elsewhere within the Plan, they should also be included in the Maps section to assist users in finding relevant information.

Modified - all maps included in maps section

City Structure Plan Map 1 Scale of maps is difficult to read/interpret. Consider clarifying maps to improve understanding As part of implementation large scale maps will be printed, similar to the approach taken with the current Official Plan. Modified - to organize maps in body of text and at end of document.

City Structure Plan Map 1 Map 1 - City Structure Composite: "thick buffers" around river system should be kept that way. No change - natural heritage and parks kept on map

City Structure Plan Map 1 orange downtown boundary not on legend Modified - revised to address commentCity Structure Plan Map 1 missing servicing layer No change - Map not intended to show servicingCity Structure Plan Map 1 Consider expanding the urban boundary to include lands adjacent to Highways 401/402 in SW

London.No change - urban boundary consistent with 2006 study

City Structure Plan Map 1 Main street in Byron is shown in the wrong location (shown adjacent to the gravel pit) should be commissioners

Modified - revised maps, main street location corrected

Maps Map 1 The Built-area Boundary is not shown on Map 1 of the Plan. Moreover, all instances of the term ‘Built-area Boundary’ throughout the Plan should be consistently hyphenated and capitalized as per the definition section. RECOMMENDATION: Because of the importance placed on the Urban Growth Boundary for land use planning in the City, it would be helpful to have a map which shows the UGB, Built-area Boundary and the Agricultural Area together. If this is not possible or desired, at the very least, the Built-area Boundary should be shown on Map 1 (page 33) and the UGB should be shown on Map 4 (page 405).

Modified - revised Map 1 to clearly show the lands comprising the Rural London area.

Maps Map 1 discrepancies between map legend and policies - eg primary industrial district or employment areas

Modified - changed to Employment Lands

Maps Map 1 Reference that the composite doesn’t include some overlays Modified - revised to address comment


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanMaps Map 1 “Future Path Connection” label to be consistent with Map graphic so that it is not confused with

the Rapid Transit Corridor. Modified - revised to address comment

City Structure Plan Map 1 Show future Rapid Transit corridor to Hyde Park / Riverbend, add more transit villages, include missing Main Streets and show HCD’s

No change - 4 transit villages is sufficient for life of plan, other items included on other maps

Maps Map 1 and Map 4

Victoria park included in Downtown? Look at adding boundary map of downtown in Plan like in the current OP.



Map 2 Map 2 Mobility Network - this map should be copied and moved forward as a component of the City Structure Plan, Active Transportation Layer, to consistently reinforce the transportation shift to walking, cycling and transit. The Map appears to be incomplete and needs to be sourced. Is it the exisitng cycling master plan or the Transportation Master Plan?

Modified - map revised to improve clarity, not included in city structure


Map 2 Map 2 Mobility Network is a critical reference to existing and future infrastructure. Recommendation: This Map should be copied and moved forward as a Component of the City Structure Plan, Active Transportation layer, to consistently reinforce the transportation shift to walking, cycling and transit. The Map appears to be incomplete and needs to be sourced. Is it the existing cycling master plan or the Transportation Master Plan? There are no future on-street bike routes shown and should be added.

Modified - map revised to improve clarity, not included in city structure


Map 2 Mobility Network – make the map a full page for readability. Add the Mobility Network map to Policy 60 - reinforce the importance of cycling as a viable mode of transportation.

Modified - map revised to improve clarity, revised title to "Active Mobility Network"


Map 2 In the Mobility section on page 81 there is a map entitled “Map 2 – Mobility Network”. It is called a Mobility Map but only shows walking and cycling routes. Perhaps a better term is Active Transportation Map.

Modified - revised title to "Active Mobility Network"

Maps Map 2 As part of providing a vision for the future, the Mobility Netwotk presented as Map 2 should include Future Multiuse pathways. While this would be confirmed as part of an update of the Bicycle Master Plan it is suggested that this should include extensions of the Thames Valley Parkway along the area’s original transportation corridor, the Thames River.


Maps Map 2 “Future On-Street Bike Routes” noted in Legend but not shown on map. Modified - revised to address commentCity Building Policies - Mobility

Map 2 Does not show bike paths nor future bike paths or future on-street bike routes. Correct mapping by including bike paths and future bike routes & paths. Map should also be included at end of the OP in Maps section so that it is easily found.

Modified - map revised to improve clarity

Maps Map 2 - Mobility Network

" The Thames Valley Trail (hiking) is 110km in length. It links the Elgin Trail (Middlesex County line in the south) to the Avon Trail (St. Mary's). Londoner can access the trail at Komoka Provincial Park, follow westward to Kains Woods and Warbler Woods. Continue through Springbank Park, Terry Fox Parkway, Forks of the Thames, Harris Park, Gibbons Park, UWO grounds, Kilally Meadows and finally Fanshawe Conservation Area. The trail needs to be protected for hiking use only. A Guide to Hiking the Thames Valley can be obtained on loan from the public library or from Tourism London. It would be appreciated if the ReThink

Modified - reference to hiking trail added to map


Map 3 Need to integrate mobility/cycling links better on the Maps in the Plan (eg. Better integrate Map 3 and Street Classification Map)

No change - maps each include specific information

City Structure Plan Map 3 Add 100 metre buffer to Map 3 as a component of the City Structure Plan. No change - not applicable to remnant high denisty residential overlay

Maps Map 3 map does not show entire EIS No change - EIS shown on Map 6


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanMaps Map 3 HDR Remnant of 1989 Plan - I believe Central Avenue, north side, between Adelaide Street

and Maitland is on such remnant. I feel this should be changed back to Low Density Residential because the existing buildings are all that use. Also, the south side of Central Ave is part of E. Woodfield HCD and that will help keep the context of the HCD in place.


Maps Map 3 Remnant High Density Residential Areas are not identified in the table of contents nor is the map included at the back. Therefore it is difficult to find (or know about) the appropriate section if necessary. Include map at back with all other Schedules and include in Table of Contents.



Map 3 Does not include high density designation currently in existence in Andover Trials, south of Bradley Ave and abutting Pincombe Drain. Suggests adding to map.


Maps Map 3 NE corner of Bradley and Highbury - Designation conflicts with a wetland area that is an extension of the Westminster Ponds.

No change - property is in the approrpaite place type

Maps Map 3 - Remnant High Density

"In review of the London Plan, there is property that we own where the mapping of Remnant High Density Parcels is missing. It's difficult to be sure, but on the mapping it seems like the 4 current single family homes were missed".

Modified - map updated to recognize parcels

Maps Map 4 Map 4 identifies three Industrial Place Types: Heavy Industrial, Light Industrial and Future Industrial Growth. It appears that only one relatively small area south of Dingman along Wellington is identified as Future Industrial Growth. Presumably this means that a future amendment to the London Plan will be forthcoming if additional lands are considered for inclusion in this Place Type and that opportunity will be available for full public and agency review and comment. It is understood from Policy 1174 that further planning study will be completed before development of these lands proceeds.

No change - There are two small areas designated Future Industrial Growth Place Type - south of Dingman Drive, east of Wellington Road; and north of Dingman Drive, west of White Oak Road. Policy 1174 does require further comprehensive study to establish the appropriate Industrial Place Type.

Maps Map 4 The Urban Growth Boundary is not included on Map 4 of the Plan. RECOMMENDATION: Because of the importance placed on the Urban Growth Boundary for land use planning in the City, it would be helpful to have a map which shows the UGB, Built-area Boundary and the Agricultural Area together. If this is not possible or desired, at the very least, the Built-area Boundary should be shown on Map 1 (page 33) and the UGB should be shown on Map 4 (page 405).

Modified - revised Map 4 to show the Urban Growth Boundary.

Maps Map 4 It is suggested that the City of London review the proposed Place Types, identified in Map 4, and consider expanding the limits of the lands designated as Rapid Transit Corridor adjacent to planned rapid transit stations noting that the proposed Mobility Policies (page 68) identify the City of London will:• Link our land use plans and our transportation infrastructure plans so they are mutually supportive, and• Utilize rapid transit services to strategically promote and catalyze infill andintensification.

No change - not consistent with intent of the plan

Maps Map 4 The greatest potential for intensification should be recognized to exist in the areas immediately adjacent to rapid transit stations. Consistent with those policies, an expansion of the lands designated as Rapid Transit Corridor adjacent to transit stations should help increase the potential return of an investment in rapid transit while still limiting the impacts on the local neiglibourhoods.

No change - Rapid Transit corridor and Transit Village place types encourage intensificaiton near transit

Maps Map 4 Missing neighbourhood designation No change - property location not provided in commentMaps Map 4 Revised to remove farmland adjacent to urban boundary. An intervening place type is required,

agriculture uses need to be reviewed to avoid future conflictsNo change - farmland located outside Urban Growth Boundary

Maps Map 4 Some lands are within the Urban Boundary but included in the Agricultural place type. These lands should be designated for future development

No change - farmland located outside Urban Growth Boundary


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanMaps Map 4 Our lands (frontage along Wonderland, from Sunningdale to municipal boundary) located

northeast of the intersection of Wonderland Road North and Sunningdale Road West are proposed to be designated as an “Open Space” place type on Map 4 of the proposed London Plan (see excerpt below). Presently, these same lands are designated as “Multi-Family, Medium Density Residential” on Schedule ‘A’ of the existing City of London Official Plan (see excerpt below). Accordingly, we would respectfully request that these lands continue to be designated as an “Multi Family, Medium Density Residential” place type on Map 4 of the proposed London Plan.


Maps Map 4 Our lands located immediately north of Sunningdale Road West (between Richmond and Wonderland) and immediately east of the Medway Valley are proposed to be designated as an “Open Space” place type on Map 4 of the proposed London Plan (see excerpt below). “Presently, these same lands are designated as “Multi-Family, Medium Density Residential” on Schedule ‘A’ of the existing City of London Official Plan (see excerpt below). Accordingly, we would respectfully request that these lands continue to be designated as an “MultiFamily, Medium Density Residential” place type on Map 4 of the proposed London Plan.


Maps Map 4 Our lands located northwest of the intersection of Wonderland Road North and Sunningdale Road West have a vegetation patch that is proposed to be designated as an “Open Space” place type on Map 4 of the proposed London Plan (see excerpt below). Presently, this same vegetation patch is designated as “Environmental Review” on Schedule ‘A’ of the existing City of London Official Plan (see excerpt below). We are not aware of an environmental analysis that has been completed to determine the significance of this vegetation patch.Accordingly, we would respectfully request that this vegetation patch should continue to be designated as an “Environmental Review” place type on Map 4 of the proposed London Plan.

No change - lands in appropriate place types

Maps Map 4 Request a transit village for Argyle No change - current number of transit village sufficient for life of plan

Maps Map 4 I am writing on behalf of my grandparents who own 6499 Pack Rd in London, Ontario. As per the London Zoning By-Law their property is current zoned as UR4. According to the new ReThink London plan this has been proposed as Open Space and Environmental Review with a proposed park area to the South. The current retention pond that the South edge of their property was dug by my grandfather many years ago in order to improve on the swampy ground that existed when they first brought the property, and many of the trees there were planted at the same time as the property was simply barren farmland with some character. Given that there is no inlet, outlet or connection to other waterbodies, we ask that you rethink the proposed Open Space designation. Our family is active in real estate development and architecture and would prefer to see improvement to the property in the future. The existing retention pond would serve well as a storm water management pond for future residential developments in the surrounding properties. As for the higher ground, we would like to see a mixed-use project that incorporates senior living and/or retirement lifestyle buildings with some retail component. Given the character features of the property it would serve as an ideal Neighbourhood Central Activity Node as opposed to the fabricated commercial nodes that are commonplace today. At this time should we be doing anything further to expresss our intent for the future of the property?

No change - property included in Open Space Place TypeMaps Map 4 1597 Sunningdale Road - Has not had a chance to discuss prior to August deadline, intends to

submit comments at a later dateNo change - lands include a Provincially Significant Wetland


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanMaps Map 4 Need to compare the proposed Map 4 to the existing Schedule A. Current LP schedules are not

of a quality sufficient for detailed review and analysis. Modified - large scale maps to be adopted as part of plan, small scale maps will be provided for reference only

Maps Map 4 Need to include street names. Modified - revised to address commentMaps Map 4 Road System on Map 4 needs to be consistent with Map 5. Modified - revised to address commentMaps Map 4 Environmental Review designation needs to be consistent with Schedule B-1 of the current

Official Plan, unless detailed studies have recommended the change in designation. No change - environmental review consistent with 2006 study.

Maps Map 4 I would say that for continuity with the existing OP all HD lands should be shown on the new land use plan. It recognizes that the lands did have a HD designation so that if someone wants to develop in the future it is an indication within the plan of the previous designation. This may help with NIMBY issues going forward and helps to preserve property values

No change - not consistent with direction of plan

Maps Map 4 The boundaries of the place types are generally based on street boundaries. Consider mid-block boundaries between Place Types where appropriate.

No change - current boundaries consistent with plan objectives

Maps Map 4 695 Proudfoot Lane - We support the proposed Transit Village designation for the lands at 695 Proudfoot Lane as this Place Type will allow for the full utilization of this transit oriented property including a wide range of housing types and complimentary uses.


Maps Map 4 Map 4 shows this important future employment area as Farmland versus a place type like Future Employment Area. At a minimum those areas could be designated a place type of Future Employment Area and subject to an E.A. be added to the Urban Growth Boundary or until such time as a City-initiated secondary plan is prepared.

Modified - revised to reflect the recommendation of the Industrial Land Demand Study

Maps Map 4 Having green for farmland, Open Space and ER is confusing and hard to read. Modified - revised to address commentMaps Map 4 Place types should not precisely follow property boundaries, as they are difficult to see and of

insufficient depth in many cases to fulfill The London Plan place type policies.No change - boundaries consistent with intent of plan

Maps Map 4 Given the Main Street and Preservation Policies on pages 222-223, what is the point of showing the majority of Richmond Street and a section of Wellington Street on the plan, as the infill / intensification policies would be difficult to achieve? Consider removing these sections from the map or revised the policies.

No change - Rapid Transit corridor policies and segment policies apply

Maps Map 4 Review Open Space Place Type Boundaries - Downtown / Harris Park and Victoria Park Modified - revised to include in downtown boundary

Maps Map 4 No urban growth boundary is delineated Modified - revised to address commentMaps Map 4 Map # 4 (page 404) needs to be larger than rest so you can read it. The Legend can be smaller

so it will fit. The same comment could apply to all maps.Modified - revised to address comment

Maps Map 4 We would really prefer not having commercial in this established upscale neighbourhood.No change - not consistent with vision of plan


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Map 4 The central theme of the resulting discussion at this meeting was the proposed "Need" to expand the area zoned as a "waste management resource recovery area" to the west of White Oak Road. It seems the sole reason for this proposal is some vision creating convenience for currently non existent potential users intending to set up a business in the newly zoned area. The convenience woul be an ability to use the new WOnderland Road and 401 interchange to access to area. This would not only be counter to the currently designated route (established as a result of extended hearings when W12A was established) but would allow access by a route which not only was not designed for this traffic, but for which there is no plan to upgrade the infrastructure. It was alos pointed out that the plan was lacking the details that would proivde the necessary oversight to protect the community from the likely adverse impacts of the plan. We were assured by the City staff on the W12A PLC as well as Planning that our comments at the December 4 meeting would be brought forward as the London Plan proceeds. There is no need for these changes and is no plan to accomodate the changes.

Modified - area of Waste Management Resource Recovery Area revised


Map 4 Wonderland Road and 401/402 - With respect to the Highway 401 and 402 corridors, the Plan acknowledges there is opportunity to capitalize on the City’s proximity to these corridors by providing opportunities for Industrial development with highway frontage and through sites that are highly accessible to these highways. However, the Plan does not provide any provision for development along the 402/401 corridors other than on the City owned Industrial land centred around the Veterans Memorial Parkway and Highway 401 interchange.

No change - property is outside the Urban Growth Boundary

Urban London Place Types - Transit Village/Rapid Transit and Urban Corridors

Map 4 Wider "banding" is reqiured to allow development that at high density that does not conflict with neighbourhoods

No change - Place Types consistent with intent of plan


Map 4 & 265 Notwithstanding the discussion in text which seems to imply that HVAs and SGRAs have been included in Open Space, these areas do not appear to be included within Open Space shown on Map 4 as suggested in Paragraph 265.


Maps Map 4 & Map 5 Environmentally sensitive features at NW corner of Commissioners Road E and Meadowlily Road S have not been recognized.

No change - map 6 includes current environmental data

Maps Map 4 Adelaide and Sunningdale intersection - Given that these are two major arterials, high density uses would be suitable and should be permitted in the plan


Maps Map 4 Sunningdale and Blackwater intersection - permit a commercial area of approx. 10,000 sq. m. to provide local shopping amenities


Maps Map 4 952 Southdale Road West - Disagree with designation of "Future Community Growth" and "Open Space". Current designation is Multi-Family, Medium Density Residenital. Requested Place Type is "Shopping Area"


Maps Map 4 952 Southdale Road West - Property designated "future community growth", should be "shopping area" possible map error

Modified - property in Neighbourhoods Place Type

Urban London Place Types - Rapid Transit Corridor

Map 4 listed rapid transit corridor widths may not accommodate tall buildings, and there are strict requirements for sensitivity to existing neighbourhoods. Additional lands should be included in the corridor areas to allow greater setbacks from mid and highrise buildings to neighbourhoods and support intensification along the transit corridors.


Urban London Place Types - Rapid Transit Urban Corridors

Map 4 Corridor widths not adequate to accommodate high rise forms. Uncertainty with conflicting policies for lot assembly (861-862) and protection of neighbourhoods.



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanMaps Map 5 MTO would request that Highway 4, Highway 401 and Highway 402 be identified as “Provincial

Highways” rather than FreewaysModified - revised to address comment

Maps Map 5 The planned extension of Veterans Memorial Parkway as an Expressway to Wilton Grove Road was omitted from Map 5 — Street Classifications

Modified - revised to address comment, rural thoroughfare segment added

Maps Map 5 Rapid Transit Boulevard page 405 “TBD” – clarify/define on legend Modified - information provided on map regarding future Rapid Transit Boulevard locations

Maps Map 5 Rapid Transit Corridor and Civic Boulevard are indistinguishable Modified - revised to address commentMaps Map 5 Map 5 shows Wonderland Rd. between the 401 and 402 as “Rural Thoroughfare” along with the

easterly portion of Wilton Grove Rd. No proposed extension of Veteran Memorial Parkway to Wilton Grove Rd. is shown. At a minimum those areas could be designated a place type of Future Employment Area and subject to an E.A. be added to the Urban Growth Boundary or until such time as a City-initiated secondary plan is prepared.

No change - classification consistent with intent of plan

Maps Map 5 Colours are difficult to distinguish. Main Street classifications are so small that they are almost invisible. With no street names shown anywhere on the map, it will be very difficult for users to identify the classification of a given street unless they are very familiar with the City. Modified - revised to address comment

Maps Map 5 Request to change Lawson Road from a Neighbourhood Connector to a Neighbourhood Street. No change - classification consistent with intent of plan

Maps Map 5 Street designation appears to be key. How do you change designations or evaluate criteria if there is a change in the street classification?

No change - refer to implementation and interpretation sections in Our Tools

Maps Map 5 How is Oxford Street a "rural thoroughfare" at its west end? This classification has no development status or reference. Also suggest better colour differentiation

No change - classification consistent with intent of plan

Maps Map 5 Wychwood Park should be a neighbourhood street north of Lawson Road Modified - revised to address commentMaps Map 5 1959 and 1997 Oxford St. West. And the parcel in between 1997 and 2085 Oxford Street West -

Map 5 should have the updated alignment of Kains Road as per the recently finalized Tributary ‘C’ EA. All other maps will have to be updated accordingly.

No change - to be updated when mapping available

Maps Map 5 Re-evaluate number of Units for converted dwellings in Near Campus Neighbourhoods. No change - policy consistent with intent of planCity Building Policies - Natural Resources

Map 6 Consider renaming Map 6 – Natural Heritage System for consistent approach to terms. Modified - map names and contents updated


Map 6 The Ground Water Recharge Areas that are shown on Map 6 – Natural Heritage Features Overlay are not consistent with the Significant Groundwater Recharge Areas (SGRAs) which meet the test of designated vulnerable areas under the PPS and are contained in the approved Upper Thames River Source Protection Area Assessment Report (http://www.sourcewaterprotection.on.ca/ar_UTRCA.html). SGRAs are delineated based on provincial standards set out in the Director’s Technical Rules under the Clean Water Act (CWA). While the recharge areas identified on Map 6 may have been developed based on other standards, it will be confusing for development to be faced with considering both recharge areas as the SGRAs defined in the Assessment Report are commonly accepted to be the designated vulnerable areas under the PPS and therefore require consideration as to how they are being protected.



Map 6 With all source protection mapping features included in the London Plan, it will be important that the City ensure that it is using the most current delineation at each stage in the development and consultation on the Assessment Report. It is also important that any Assessment Report (AR) or Source Protection Plan (SPP) features mapped in the Official Plan have a suitable note to direct the reader to the AR or SPP for the current authoritative mapping.



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanMaps Map 6 Significant Valleylands

Policy 294 of the London Plan states that significant Valleylands are delineated on Map 6 as Significant River, Stream and Ravine Corridors. To make this clear within Map 6, especially because Policy 300 specifically refers to the protection provided to Significant Valleylands, MNRF suggests that the Map 6 Legend provides a note about this, i.e. “(Significant Valleylands)” could be written beside Significant River, Stream and Ravine Corridors in the Legend.

Modified - legend modified to include significant and unevaluated valleylands

Maps Map 6 Natural Heritage SystemThe map is called ‘Natural Heritage Features Overlay’ and the Legend’s title is ‘Natural Heritage System’. There does not appear to be a clear and well-defined natural heritage system within the City of London which identifies ecological linkages and core natural heritage features and areas. To meet the requirements of Policy 2.1.3, the MNRF recommends that the City map a natural heritage system. This could be done by creating an additional map that illustrates a natural heritage system as a single colour with linkages (e.g., arrows on the map) and corridors connecting natural heritage features and area. Please refer to the Natural Heritage Reference Manual for guidance on natural heritage systems.

Modified - Overlay removed from map title

Maps Map 6 Provincially Significant WetlandsThe Legend in Map 6 identifies PSWs as ‘Provincially Significant Wetlands Potential ESA’s’. MNRF recommends that ‘Potential ESA’s’ are identified and represented separately from PSWs.It appears as though the woodlands in Map 6 are mapped over top of wetlands. As per comments provided below, MNRF recommends that PSWs are mapped separately from other natural heritage features, as they should be designated for protection as per PPS Policy 2.1.4. Currently, with woodlands mapped over top of wetlands in Map 6, the map resolution is too low for MNRF to accurately determine where there are gaps in information, especially with regards to unevaluated wetlands. Therefore, for unevaluated wetlands and Locally Significant Wetlands identified on Map 6, MNRF strongly recommends that they are mapped over top of significant woodlands, or alternatively provided on a separate map.MNRF provides the following comments with respect the mapping of PSWs in Map 6.• It does not appear that all areas identified as unevaluated wetland in Map 6 are identified as Environmental Review Place Type in Map 4. MNRF recommends ensuring that all areas identified in Map 6 as unevaluated wetlands are identified as Environmental Review Place Type in Map 4, including in areas where unevaluated wetland patches may overlap with Open Space.• There is inconsistency in representation in Map 6. In many cases wetland appears to be behind woodland and so it is not represented on the map. The overlays should be adjusted so that the wetland layer is displayed on top of woodland wherever it occurs, especially considering that the Policy regarding wetland protection in the PPS is such that no development is permitted in a PSW, whereas this is not the case for woodlands.• Regarding representation of the Allen White PSW complex along the south border of the city limits, south of Harry White Dr. between Wonderlands Rd. S. and Wellington Rd. In Map 6, two woodlands are mapped showing no PSW though it should be present as identified in Land Information Ontario (LIO), and adjacent to this, a woodland is mapped as PSW. Therefore, it is not clear whether the mapping is incorrect, wetlands are missing, or if it is being improperly/inconsistently represented. Also within this area, a woodland is mapped as locally significant wetland when it should contain a unit of the Allen White PSW. MNRF recommends

Modified - revised mapping for consistency


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanMaps Map 6 Areas of Natural and Scientific Interest (ANSI)

As a result of the low resolution of the mapping in Map 6, it is difficult for MNRF to confirm that all ANSIs are accurately depicted within the boundaries of Environmentally Significant Areas. As commented in the table below regarding Policy 277, MNRF recommends that ANSIs are mapped separately from Environmentally Significant Areas. When updated mapping is provided (and shapefiles), MNRF may have further comments regarding ANSIs.

Modified - revised to incorporate most up-to-date Provincial mapping. Sent Province shapefiles for Map 6 for review and confirmation of boundary mapping.

Maps Map 6 Unevaluated Vegetation PatchesGiven the pattern currently used in Map 6 for Unevaluated Vegetation, in addition to there not being a clear boundary, it is difficult to determine the locations of these patches. MNRF recommends that Map 6 is enhanced to better depict the locations of unevaluated vegetation patches.


Maps Map 6 Unevaluated Wetlands• Several woodlands in the area enclosed by Westminster Dr., Old Victoria Rd., Glanworth Dr., and Wellington Rd. S., should be considered for unevaluated wetlands or designated Environmental Review place type until an assessment is done, as wetland appears to be present.• There are several woodlands within the Wonderland, Fanshawe Park Road and Sunningdale Road area that should be considered for unevaluated wetlands or designated Environmental Review place type until an assessment is done, as wetland appears to be present.• The woodland that is north of River Road and Scalan Street appears to have unevaluated wetland within and should be designated Environmental Review place type until an assessment is done, as wetland appears to be present


Maps Map 6 concerns with the "Potential Naturalization Areas" "potential Upland Corridors" and identification of waterways where they do not exist.

No change - map titled Natural Heritage

Maps Map 6 n/w intersection of Wonderland Rd N and Sunningdale Rd W - Our lands located northwest of the intersection of Wonderland Road North and Sunningdale Road West have a vegetation patch that is proposed to be designated as an “Significant Woodlands” place type on Map 6 of the proposed London Plan (see excerpt below). Presently, this same vegetation patch is designated as “Unevaluated Vegetation Patch” on Schedule ‘B1’ of the existing City of London Official Plan (see excerpt below). We are not aware of an environmental analysis that has been completed to determine the significance of this vegetation patch. Accordingly, we would respectfully request that this vegetation patch should continue to be designated as an “Unevaluated Vegetation Patch” place type on Map 6 of the proposed London Plan.

No change - map implements recommendations of study

Maps Map 6 Map 6: what happened to "patches"? Hope the NHS is checked in detail. No change - map includes most recent environmental dataMaps Map 6 Map 6: Add Komoka Provincial Park to the Legend and highlight the area of this Park on the

map. Rationale relates back to its identification in relevant legislation and natural heritage sections.

No change - Areas of Natural and Scientific interest included

Maps Map 6 Need to compare the proposed Map 6 to the existing Schedule B-1. Current LP schedules are not of a quality sufficient for detailed review and analysis.

Modified - large scale maps to be adopted with London Plan

Maps Map 6 There is a recent gravel pit application adjacent to the Kilworth Lake Maumee Earth Science Area of Natural and Scientific Interest (ANSI). It is also adjacent to the Dingman Creek Fen PSW Complex (see UTRCA map attached to submission). The ANSI is referenced in the PEC report (M. Davis) but does not appear on Map 6.

Modified - natural features mapped based on recent data from conservation authority


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Map 7 Although Wellhead Protection Areas (WHPAs) are intended to be shown on Map 7 – Natural Resources Overlay, the proposed Source Protection Plan would require the OP to make reference to the Significant Threat Policy applicability mapping which illustrates areas where activities may be prohibited restricted or otherwise regulated through Source Water Protection Plan policies.



Map 7 The shape of the WHPA shown on Map 7 is not consistent with either the WHPA or the significant threat area within the WHPA. Again, we recommend that the City verify the accuracy and currency of all Source Water Protection mapping at each stage in the development and consultation on the Official Plan. As indicated, each feature from the AR or SPP mapped in the OP should include an appropriate reference to the source document as the official delineation and the fact that they may be updated from time to time.


Maps Map 7 Petroleum Well LocationsMNRF has noted that Map 7 of the London Plan shows the known petroleum well locations within the City. Petroleum well data can change on a daily basis as unrecorded wells are discovered and well locations are updated. Therefore, MNRF recommends including a note on Map 7 that states:“Known petroleum wells and associated works should be considered in the review of Planning Act applications. Please reference the Ontario Oil, Gas and Salt Resources Library website (www.ogsrlibrary.com) to obtain the most up-to-date information regarding known petroleum wells”.

Modified - revised text to address comment, no map change

Maps Map 7 Aggregate Resource AreasIt is not possible to distinguish Aggregate Resource Areas or Extractive Industrial Areas because boundaries are not defined. MNRF recommends enhancing the mapping by providing boundaries on these areas in Map 7. Once improvements are made to Map 7, MNRF may have additional comments.


Maps Map 7 "Steep Slope" is misrepresented on Col. Talbot property. It is also a "regulated area". No change - features based on mapping provided by UTRCAMaps Map 7 1959 and 1997 Oxford St. West. And the parcel in between 1997 and 2085 Oxford Street West -

Map 7 appears to have aggregate resource area shown (purple colour). This could be removed since this area is contained within the neighbourhood place type, and will be developed.

No Change -

Maps Map 7 Need to compare the proposed Map 7 to the existing Schedule B-2. Current LP schedules are not of a quality sufficient for detailed review and analysis.

Modified - large scale maps to be adopted as part of London Plan

Maps Map 7 The mapping (Map 7 Natural Resource and Natural Hazards) shows the Fanshawe WHPA but does not show the Hyde Park WHPA. The wells are identified and correctly labeled in the legend.

Modified - revised features based on mapping proivded by UTRCA

Maps Map 7 Highly Vulnerable Aquifers (HVA) and Significant Groundwater Resource Areas (SGRA) mapping prepared by UTRCA does not cover the entire City of London. The southern portion is within another Conservation Authority and another Source Water Protection Region (Kettle Creek CA for the Lake Erie Region). Our final map for groundwater recharge to be contained as an overlay in the London Plan will need to marry the two sections together.

Modified - revised features based on mapping proivded by UTRCA


Map 7 & add new policies

Vulnerable areas including SGRAs and HVAs have been identified and approved in the Assessment Report and apply to the City of London. These areas should be incorporated onto the maps and policies should be developed which are consistent with the PPS (PPS 2.2.1e).

Modified - new policy added to 471

Maps Map 8 Fourplexes or fourplex – not listed consistently No change - not applicable to Map 8


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanMaps Map 8 It would be helpful if the chart showed relevant page numbers for the specific policies to assist

users in finding them. Suggest adding page numbers to table.Modified - new map format to improve clarity

Maps Map 8 Byron Main Street appears to be in the wrong location on map. Modified - revised to address commentMaps Map 8 Map 8 does not include Old East, SoHo or Richmond Row. Should also be shown on map,

despite being addressed in ‘special segment policies’ or revised Plan and remove Old East, SoHo and Richmond Row from Rapid Transit Corridor place type.


Maps Map 9 It is very difficult to see the Water Bodies and Courses areas of the map as colour is very faint. Suggest revising colours.



Maps Map 2 Policy 491_7 and _9 describes the network. Specific text reference should be added to the cycling or multi-use path network Map 2 illustrating the infrastructure

No change - Map 2 addresses road classification, not other transportation infrastructure


Page 47 1. What is included in capital costs?2. Are any capital costs of the developer other than Development Charges paid to City included?3. Were the costs of maintaining current infrastructure versus new infrastructure considered?4. Were the different property tax implications for different patterns considered?5. With a compact pattern, can the City comply with the PPS?6. The commentary in this section is lacking identification of the form of growth that London is already achieving, leaving the reader to make their own assumptions onthe impact that the London Plan is trying to achieve. Why would this not be provided?

Modified - Growth scenarios on page 46 & 47 removed from the Plan


Table 1 to table 5, pg. 46 Consider moving the growth scenarios information to the Our City section of the Plan. Modified - Growth scenarios on page 46 & 47 removed from the Plan


Table 1 to table 5 Growth forcast model is confusing as it isn't reality. Should show current model as a baseline. Modified - Growth scenarios on page 46 & 47 removed from the Plan


Table 1 to table 5, pg. 46 Should add that the forecasts are based on extrapolations of current trends and acknowledge that numbers are highly uncertain given instability in global ecology/economic systems.


City Structure Plan Table 1 to Table 5 Growth Scenarios

This section of the Plan outlines three scenarios for growth but does not state which one it will utilize for future growth. RECOMMENDATION: The City needs to decide which growth scenario it will be utilizing to strengthen the growth management policies in the Plan.


Our Tools - Bonus Zones Table 11 Revise table to inlcude maximum height with type 1 and type 2 bonusing No change - maximum height and bonusing shown


Table 11 Page 197, Table 11: Consistent with comment No. 4 above, we recognize and appreciate the desire to direct the highest and most intense forms of development to the Downtown, Transit Villages, and rapid Transit Corridors. However, we believe that the maximum heights for the “Neighbourhood” place type (4 storeys, 6 storey’s with bonusing) is to limiting. A huge percentage of the land within the City will find itself in the “Neighbourhood” place type. Does it make sense to limit heights to 4 storeys (max. 6 with bonusing) in all of the “Neighbourhood” place types? We would respectfully encourage the City to allow for mote flexibility, from a maximum height perspective, at appropriate locations within the Neighbourhood Place types.

No change - mid-rise is appropriate in Neighbourhoods Place Type. Higher intensity forms of development should be directed to where they can support rapid transit.


Table 11 Supports height restrictions by storeys and not metres Modified - have proivded option for minimum height


Table 11 Maximum height of 4 storeys (or 6 storeys) with bonusing is too limiting for the Neighbourhood Place Type. It does not allow for a full range of housing, which is one of the Plan’s and PPS’s goals. Suggests allowing for greater height at nodal locations, include more Transit Villages, etc.

No change - mid-rise is appropriate in Neighbourhoods Place Type. Higher intensity forms of development should be directed to where they can support rapid transit.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanUrban London Place Types

Table 11 Maximum of 12 storeys and no opportunity for bonusing is also too limiting. There may be appropriate locations for greater height as it will provide opportunities for different building types (i.e. – point towers vs slab apartments). Provide opportunities for greater height in appropriate areas and with appropriate study (e.g. – shadow studies, Planning Impact Analyses, analysis of views and vistas, architectural design, topography, etc.).



Table 11 A standard maximum building height without bonusing should be established to create a known as-of-right height and a maximum height with bonusing. Bonusing provisions should be worded to allow for some certainty, provided listed community benefits are provided.

No change - as of right heights provided as "standard maximum height"


Table 11 The plan makes it difficult to determine ultimate devleopment potential as bonusing is to be determined through negotiation with staff. This makes an investment decision very difficult, which may discourage all but the 'major players' from developing in London.

No change - site specific considerations also determine height. Note 1 states that maximum heghts may not be permitted everywhere


Table 11 Increase building height caps in all Place Types, particularly as-of-right permissions. No change - heights are consistent with intent of Plan

Urban London Place Types - Downtown London/Transit Village

Table 11 Include building height in metres and number of storeys, to avoid situations like the "towers of spite"


Urban London Place Types - Framework

Table 11 Minimum heights of 4 storeys are a concern. What economic and market analysis has been completed to confirm that a minimum of four storeys is achievable in London?

Modified - reduced to 3 storeys

Urban London Place Types - Neighbourhood - Remnant High Density Residential

Table 11 Permit bonusing on sites in the Remnant High Density Residential Designation No change - heights are consistent with intent of Plan


Table 11 rationale for capping heights? No change - maximum heights are consistent with the design objectives of the plan

Urban London Place Types - Rapid Transit Urban Corridors

Table 11 Additional building height should be permitted as-of-right in a Transit Village and Rapid Transit Corridor

Modified - increased height to 15 storeys within 100m of station


Table 12 SE corner of Adelaide St N and Huron St - Minimum building height of 2 storeys may impact ability to add to the existing uses on the site. Consider clarifying that minimum building heights apply to major redevelopment only.

No change - listed heights are the future direction of the Place Type. Non-conforming use policies may apply


Table 12 The Table identifies that a minimum height of 4 storeys is required for “properties within 100m of rapid transit stations, or at [the] intersection of [a] Rapid Transit Corridor with a Civic Boulevard or Urban Thoroughfare.”

As an example, a minimum building height of 4 storeys would be required at the intersection of Wharncliffe Rd. and Oxford St. W. Is this appropriate? Will these help to spur development by creating value, or inhibit development because returns cannot be achieved on this type of development?

What market analysis was done to determine this is achievable in London?

No change - policies provide vision for future redevelopment


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Table 12 Identifies minimum heights of 2-4 storeys along Rapid Transit and Urban Corridors and that mid-rise communities will “border the length” of rapid transit services. Map 5 is very difficult to read (colours are too similar) however it appears that much of the Rapid Transit Corridor is along Richmond Street. Redevelopment of minimum 4 storey buildings in some areas would eliminate some of the most attractive heritage housing in the City.

Modified - maps revised to improve clarity, large scale maps to be adopted as part of London Plan


Table 12 SE corner of Dundas St and Clarke Rd - Since the London East Site is already largely developed as single storey retail uses, our Client has expressed a concern that it is not aesthetically nor economically feasible to develop future commercial pads on this Site with a minimum of two storeys in height.

No change - listed heights are the future direction of the Place Type. Non-conforming use policies may apply


Table 13 to table 15 Unsure where meadowlily Road fits on Tables 13-15 Modified - maps revised to improve clarity, large scale maps to be adopted as part of London Plan


Table 13 Likes table 13, brings land use and transportation together at neighbourhood level. No change - indicates support for the plan


Table 13 Add Laneway Housing as a permitted use. No change - second dwelling units addressed in text


Table 13 Concern is that you can have a much more intensive use at corner of Wychwood and Lowson or Corley and Windermere than you would at Brescia and Sarnia because Brescia is a Neighbourhood Street. Determining development by street classification, you get more intensive development than LDR every was meant to. Asks if a sample of Connectors was taken to see what would happen?

No change - policies are consistent with vision of plan


Table 13 Uses term Neighbourhood Corridor in first column, whereas Map 5 and remainder of table refers to Neighbourhood Connector. Use consistent/correct terminology.

Modified - revised to address comment, Nieghbourhood Connector is correct


Table 13 Cell at top right should say "Fronting Onto Neighbourhood Park". (word neighbourhood left out.) No change - may apply to other park types

Urban London Place Types - neighbourhoods

Table 13 1413 Adelaide Street North - Office/commercial uses not permitted as the site is mid-block. Request consideration for permission of these uses on the site.

No change - policy is consistent with intent of plan


Table 13 Fourplexes or fourplex – not listed consistently Modified - revised to address comment


Table 13 Typo Intersects with Civic Boulevard (sp) – 5th column of table No change - to be addressed in final version


Table 13 Reference to “Neighbourhood Corridor” should be revisedd to “Neighbourhood Connector”

The table applies on the basis of an individual “property”, but should it be extended to apply to “the subject lands”, or lands subject to an application, as development may comprise multiple properties?

A review of Table 13 indicates where “supervised residences” may be permitted, but does not identify where “correctional” residences may be permitted.



Table 14 Storeys are restricted but not height. Concerned if that is wise. For example, Towers of Spite were the right height. You could end up with the right number of storeys but with larger than reasonable height per storey. Asks where are the controls to keep this from happening?

No change - polcies achieve intent of plan


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Table 14 All categories should permit a minimum of 1 storey to allow for market demand, recognition of an aging population, etc. Rationale – much of the development occurring along ‘Civic Boulevards and Urban Thoroughfares’ is one storey condos targeted to empty nesters (Gainsborough, future Bradley Ave, Highbury/Fanshawe, Commissioners, etc. Suggests Table 14 be revisedd.

No change - not consistent with intent of plan


Table 14 Maximum height of 4 storeys at higher order intersections should be increased to 8 storeys as-of-right and 12 storeys with bonusing.

No change - tall buildings to be directed to strategic locations where they are supportive of rapid transit, rather than at all high-order intersections


Table 15 Additional analysis required to determine whether more policies are needed for non-residential uses in the neighbourhood area.

No change - policies are consistent with vision of plan


Table 15 200m2 seems to be the max of non-residential at a Connector and Connector, but that is per building not per intersection. What are you envisioning being built and where? Again, the critical aspect of how you define "neighbourhood" is important in this. It makes a huge difference if it is by Planning District or by what the community calls its neighbourhood.

Modified - clarified that totals apply to intersection


Table 15 Commercial/office caps do not provide enough flexibility. No change - policies are consistent with vision of plan


Table 15 1413 Adelaide Street North - the property is in the "neighbourhood" place type and is mid-block, therefore commercial/office development is not permitted. Disagrees and suggests a wider range of uses is appropriate.



Table 15 Increase commercial GFA caps established within the Neighbourhood Place Type No change - policies are consistent with vision of plan


Table 6 & table 7 does not like legend references yes, no, avoid, & encourage Modified - table to include encourage, permitted, conditionally permitted, and not permitted


Table 6 & table 7 Add Institutional Modified - revised to address comment


Table 6 & Table 8 The decision to provide turning lanes on major streets and rural thoroughfares should be context sensitive based on a variety of factors including traffic volumes, safety and intersection capacity and not restricted by the Official Plan as identified in Table 6 andTable 8.

No change - policy is consistent with intent of plan


Table 6 Major Streets Apparent contradictions in Table 6 as part of the Mobility Policies include 1. divided vehicle zones are not permitted on Urban Thoroughfares but planted medians are permitted. 2. Transit stop and related facilities are not permitted on rapid Transit Boulevards although the plan notes that it is implied rapid transit and non—rapid transit services will be accommodated on this street classification.

No change - the table highlights transit station facilities on Rapid Transit Blvd's, planted medians provide a break and limit access


Table 6 Major Streets Graphics are confusing. Consider simplifying using green checkmarks and red x’s. No change - does not provide flexibility to design the street in a context sensitive way


Table 6 Major Streets Development Zone: The term “Lighted, full access intersections” should be changed to “Traffic Signal full access intersections”



Table 6 Major Streets Vehicle Zone: Bicycle Facilities should be “Encourage” not “Yes” for Urban Thoroughfare and “Yes” for Main Street.



Table 6 Major Streets Vehicle Zone: Left Turn Lanes should remain as an option “Encourage” for RT Blvd and Main Street for safety & capacity requirements. (i.e., transit priority measures may include left-turn lanes/channelization for queue bypasses to accommodate rapid transit).



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Table 6 Major Streets Vehicle Zone: Planted medians should remain as an option for Civic Blvd & Main Street “Encourage” not “Avoid” (How about the recent work on Horton St east of Wellington?). Also it should remain an option for RT Blvd “Avoid” since the EA’s will determine the form and design of rapid transit corridors.



Table 6 Rapid Transit Boulevard and Main Street should be amended for Bicycle Facilities from “encourage” to “yes” symbols to indicate their importance and integration with transit.

No change - need to ensure infrastructure does not ruin character of the street


Table 6 Major Streets – Vehicle Zone: Bicycle Facilities, change that they should be encouraged to ‘Yes’ on Rapid Transit Boulevards.

No change - need to ensure infrastructure does not ruin character of the street


Table 6 Indicates ‘No’ to new driveway access points for all ‘major street’ classifications. If driveway access points are not permitted, how will vehicles access new / redeveloped sites and businesses? Need to allow for driveway access points on a number of the road classifications (urban thoroughfare, civic boulevard and main street most likely)

Modified - changed to conditionally permitted


Table 6 Why are planted medians to be avoided on Main streets? They would enhance the attractiveness and pedestrian amenity of main streets in some locations. Should be changed to ‘encourage’ for planted medians on main streets.



Table 6 Why are right turn lanes to be avoided on Urban Thoroughfares? Should be changed to ‘yes’ for right turn lanes on urban thoroughfares.



Table 6 Why are planters to be avoided on civic boulevards? Should be changed to ‘encourage’ for planters on civic boulevards

modified - revised to address comment


Table 6 Indicates that there should be no transit stops and related facilities on Rapid Transit Boulevards within the pedestrian zone. If it is a rapid transit boulevard, one would expect to have transit stops and related facilities throughout the ROW depending on the specific context. Should be changed to ‘yes’ for transit stop and related facilities in Rapid Transit Corridor within pedestrian zone.

No change - transit stops are for local service, not rapid transit. Those are transit stations


Table 7 Minor Streets Vehicle Zone: Pedestrian Cross-walks should remain as an option for Neighborhood Connector/Street. Use “Encourage”.

Modified - cross-walks removed, to be incldued in standards


Table 7 Rapid Transit Boulevard and Main Street should be amended for Bicycle Facilities from “encourage” to “yes” symbols to indicate their importance and integration with transit.

No change - conditionally permitted, must be context sensitive


Table 7 Why are pedestrian crosswalks identified as ‘No’ on neighbourhood connectors and streets? Doesn’t make sense as these would be the typical streets accessing schools, etc. Change to ‘encourage’ particularly for neighbourhood connectors.

Modified - cross-walks removed, to be incldued in standards


Table 7 Why are bicycle facilities to be avoided on Neighbourhood Streets? What do ‘bicycle facilities’ include? Provide clarification regarding what bicycle facilities mean. Include them on Neighbourhood Streets.



Table 7 Why are tree planted medians identified as ‘no’ on neighbourhood connectors and streets? They would enhance the aesthetic of streets, provide additional canopy and improve pedestrian comfort. Should be shown as ‘encourage’ or ‘avoid’, but not be prohibited.

No change - planted medians for city-wide significant streets


Table 8 Development Zone – Industrial (related to agriculture) – does this mean manufacturing associated to agriculture? Pick and pack? Canning facility?

No change - refers to all agriculturally related activities


Table 9 Table 9, fourth bullet: Should say “Environmentally”, not “Environmental” No change - to be addressed in final version


Table 9 In Table 15-1, the trigger distance for Locations of Species of Special Concern is 50 m. In Table 9, it is only 30 m for Special Concern Species. The problem here is that it both narrows from 50 m to 30 m (why?) and leaves out habitat completely. Why?

No change - 30m Is appropriate if the species is known to occur in the area. The Natural Heritage Reference Manual only identifies Endangered or Threatened Species having a trigger distance.


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Table 9 Table 9 on page 102 sets a trigger distance of 30 metres for the preparation for an EIS for a groundwater recharge area. We note that highly vulnerable aquifers have not been addressed and question whether a trigger distance is the most appropriate means for determining whether a study is required. It is important that direction on the purpose and content of an EIS be clearly documented and that these reports be appropriately peer reviewed. It should be noted that the EIS should not be focused on suggesting revisions to the delineation of the features which are mapped using provincially prescribed methodologies regional information. Nor should there be any expectation of removing the designation. They may be focused however on providing local information and appropriate protection or risk management measures for the site. We would be pleased to meet to discuss this matter further and to explore how this could be built in to the OP or supporting documents.

No change -


Table 9 Table 9 in the London Plan is missing the following wording for when an EIS is required for ER lands (it only says "as appropriate" which is too vague). "Within a distance appropriate to the specific components of the Natural Heritage System contained on the lands"

No change - This provides flexibility for different situations and should remain as such.

10 Big Moves - Building a City to Attract and Retain Talent

Need to develop a data base of students graduating from Fanshawe and Western that future employers could access.

Modified - removed big ideas - better addressed as part of monitoring.

10 Big Moves - Building one of the Greenest Cities in Canada

Why don't we have a green belt around the city, like Ottawa or Toronto. Modified - removed big ideas - addressed under City Structure and Rural London Place Types.


Concerns with too many trees being cut down prematurely. Modified - removed big ideas - addressed under Urban Forest chapter.


Keep up the good work with the reforestation and naturalization of the south branch of the Thames River - Watson Park to Meadowlily Woods.

Modified - removed big ideas - indicate support for Plan.


Also remember to include policies that preserve the habitat of the insects, birds and wildlife. Modified - removed big ideas- identified species included to be consistent with Provincial Policy Statement.

10 Big Moves - Building Strong and Healthy N'hoods

Healthy community nodes & amenities. Modified - removed big ideas - addressed in Our Strategy, City Structure Plan, City Building Policies, and Place Types Chapters of the Plan.


Healthy equity for new Londoners. Modified - removed big ideas - addressed in Our Strategy, City Structure Plan, City Building Policies, and Place Types Chapters of the Plan.


Affordable housing mix. Modified - removed big ideas - addressed under Our Strategy - Directions 1, 5 and 7, and Homelessness Prevention and Housing Chapters.

10 Big Moves - Creating a Cosmopolitan City

Build a performing arts centre. Modified - removed big ideas - captured under Culturally Rich and Diverse City Chapter.


London needs a performing arts centre for sure. Modified - removed big ideas - captured under Culturally Rich and Diverse City Chapter.


Culture immigrant heritage integrated into all parts of the city. Modified - removed big moves - captured underOur Strategy - Direction 3, and Culturally Rich and Diverse City Chapter.


Not only the big places like Museum London and Fanshawe Pioneer Village, but also small ones like The Arts Project & Studio 121.

No change - captured under Culturally Rich and Diverse City Chapter.


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London Plan10 Big Moves - Giving Real and Attractive Mobility Choices

Traffic signals on bike routes should be activated by bikes Modified - removed big moves - better addressed in technical guidelines and design standards.

10 Big Moves - Giving Real and Attractive Mobility Choices

Argyle Community Centre - Age in place options for Argyle Community Association and starting steering committee.

Modified - removed big moves - captured under Our Strategy - Direction 3, City Design, Culturally Rich and Diverse City, Public Facilities and Services Chapters, and Urban London Place Types - Neighbourhood Chapters .

10 Big Moves - Giving Real and Attractive Mobility Choices

Safe, active transportation Modified - removed big moves - captured under Our Strategy - Direction 6, and Mobility Chapters.

10 Big Moves - Regenerating our Urban Neighbourhoods & Main Streets

Heritage Facades - from Detroit/Cleveland downtowns - recognize the heritage as facades but build in behind.

Modified - removed big moves - best addressed at implementation.


Great idea, especially downtown with heritage buildings. Modified - removed big moves - indicate support for Plan.


Heritage Neighbourhood = 150 Years. Respect what we have built in our neighbourhoods. Modified - removed big moves - indicate support for Plan.


Heritage and history help create identity. Modified - removed big moves- indicate support for Plan.

10 Big Moves - Shaping the City Around Rapid Transit

Use "micro-buses" in older residential areas (eg. Dearness, White Oaks, Osgoode, etc.) Modified - removed big moves - better addressed through LTC services.


Develop a transit hub across from the London Convention Centre. Modified - removed big moves - location of transit stations will be determined through the Rapid Transit Environmental Assessment (RT-EA)review process.


Adelaide needs an overpass/grade separation in the next 20 years No change - better addressed in detail transportation design.

Booklet supplementing London Plan

Accompanying London Plan should be a booklet showing various elements - examples of good urbanism, naturalized stormwater, etc. Perhaps get Londoners to send in favourite examples? Get to be co-creators of city we want to see.

No change - does not address policy, for consideration as part of implementation & monitoring phase of The London Plan.

Maps ShapefilesMNRF also requests the shapefiles used by the City in developing the maps for the London Plan as these can be used by MNRF to ensure that the boundaries of natural heritage features identified in the London Plan are consistent with MNRF mapping.

No change - process related comment


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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanMaps Official Plan Mapping

In general, the maps provided within the London Plan are at such a low resolution and coarse scale that it is difficult for MNRF to confirm the boundaries of natural heritage features and natural resource areas. It is also thought that the symbols, patterns and colours used within Maps 6 and 7 make it difficult to determine where the areas shown in the Legends occur on the maps. For instance, ‘Potential Upland Corridors’ are shown as a green triangular symbol that cannot be distinguished from the green areas identified as ‘Significant Woodlands’.MNRF recommends putting clear boundaries on all areas shown in the mapping to make it possible to determine the location of natural heritage features and natural heritage resources and improving symbols to avoid confusion. Once improvements have been made to the London Plan mapping and if provided at a higher resolution for review, MNRF may have further comments and recommendations.

Modified - large scale maps to be adopted as part of plan, small scale maps included in Appendix for reference

Maps Refer to appendix 2 for assistance with knowing when to consider/ require a wetland evaluation. No change - information provided from the Province.

Maps The maps while graphically attractive are of little value given their scale. Planning has suggested that the maps will be embedded within the body of the document. We would encourage Planning to maintain a Maps section akin to street map books thus allowing for presentation of larger scale maps with greater detail.


Maps This section would benefit from an introduction which refers the reader to the Plan’s current up-to-date online maps and instruction as to which takes precedence

Modified - maps section changed to an appendix, interpretation information provided in text.

Maps Would love to see Hamilton Road become a 'Complete Street.' There is no reason for traffic to travel at 70km/h on a street with commercial store fronts and pedestrian traffic. It could really benefit from protected bike lanes.

No change - plan identifies Hamilton Road as a Main Street

Maps Rowntree needs a connection between our neighbourhood and the river trail that does not require cyclists to travel along Wellington/Adelaide, as is currently the case. (No way down into the park because of lack of steps north of Weston). Thanks!

No change - to be addressed by Cycling Master Plan, not Official Plan

Maps increase size and legibilty of legends on all maps Modified - large scale maps to be made availableMaps Include all maps in map chapter - duplication is okay Modified - map organization changed to imrove plan readabilityMaps build a walking/biking bridge across the river here to connect to windermere road No change - to be addressed by Cycling Master Plan, not Official

Plan Maps complete the walking/bike path under the bridge on highbury ave. No change - to be addressed byCycling Master Plan, not Official

Plan Maps walking/biking bridge across the river here No change - to be addressed by Cycling Master Plan, not Official

Plan Maps Should Byron Optimist Park be considered Open Space? Modified - revised to show as Green SpaceMaps Should this be Neighbourhood? (SE corner of Colonel Tablot and Southdale No change - Shopping Area Place Type is consistent with intent of

planMaps Parks and ESAs are the same colour. ESAs are not Parks No change - Natural heritage system is shown on a separate map

Maps This hydro corridor should be zone for Open Space. There is no spaces to build house there, and would allow a multi-use pathway.

No change -

Maps This is the prefect location for a mixed-use flat iron building. No change - permitted development listed in Place type policies. Specific building design not addressed in Official Plan policy

Maps This would be a fantastic location for an LRT or BRT maintenance facility due to its' existing industrial land use that surround it and its' close proximity to the proposed transit hub.



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Chapter Reference Policy No. Sub-Policy No. Comment Staff Action - For 2nd Draft of London PlanMaps Oxford Street west and east are separated by the Thames River. Ensure appropriate direction

indicated on all mapsModified - large scale maps to be adopted as part of London Plan

Maps There is a concrete wall behind this home at the end of our court protecting us from traffic on Richmond/ Western Rd. It would be better to show only the sidewalk area as Transit Corridor. We don't want increased zoning on part of our street.

No change - Place type boundaries to be interpreted per the interpretation policies of the Plan

Maps The sidewalks are too narrow along the West side of Richmond near Dundas Street and lead to many user conflicts. The seasonal wooden patio located on the sidewalk in this area should not be permitted to continue.

No change - addressed in text of City Design and Civic Infrastructure chapters

Maps Adelaide Street north of Dundas needs more street trees and incentives for facade improvements, along with bike racks and street furniture to make it more inviting and business friendly.

No change - addressed in text of City Design chapter

Maps We need many more street trees on Dundas Street, east of Adelaide to make the street more walkable, business friendly and inviting.

No change - addressed in text of City Design chapter

Maps A no-idling sign or educational signage about idling at the rail crossing may help improve air quality in the neighbourhood.

No change - this is an operational issue, not addressed in Official Plan

Maps I don't see why the Downtown core does not extend north to Central Ave and east completely to Colborne St. The majority of that area is already either High Density residential or Office/Business use.

No change - boundary is consistent with intent of plan

Maps Rona has left this retail area. The supporting plaza has empty retail space. Southeast London is floundering. Let's get someone into the empty Rona store asap. Walmart? Hello, Loblaws (Superstore)?!?

No change - policies support redevelopment opportunities

Maps The centre retail building in this area is vacant and an eyesore. Let's get some investment here or have the owner demolish it and put in a green space.


Maps This retail area is a complete eyesore (where the Little Caesars is). Either have the owner knock it down and create a green space, or let's get some investment in the area.


Maps A number of maps, although attractive, have similar colours for distinct characteristics / classifications (e.g. – Street Classifications Map, Place Types Map, etc.). Suggest revising some colours to improve clarity/readability.


Maps We also note that it would be helpful if the London Plan maps are provided at a larger scale, and if major streets are identified on the maps.


Maps I thought the City was proposing a Multi-use pathway along the gas pipeline at the City's northern boundary between Highbury and Hyde Park. Shouldn't this be reflected on Active Transportation Map 2?

No change - reflected on Map 6

Maps The Thames river is under utilized through the city. We have some great parks and bike paths, however what is missing are shops and restaurants. An area needs to be developed that includes a boardwalk with local restaurants and retail/crafty stores.

No change - issue addressed elsewhere in plan

Table of Contents Does not include Natural Heritage Section in Table of Contents. Modified - revised to address commentTable of Contents The Our Tools Section needs to be more detailed – 50 pages with no guidance where to find

things.Modified - greater detail added to table of contents