2009-03-09_Supplemental Agenda Packet--Dossier de l'ordre du jour supplémentairem;
City of Saint John
Common Council Meeting
Monday, March 9, 2009
Location: Common Council Chamber
Supplemental to Agenda
1. Planning Advisory Committee Chair Reply to the Report of Dr. Ircha - March 2(_)(_)9
City of Saint John
Seance du Conseil communal
Le Lundi 9 Mars, 2008
Lieu : Salle du Conseil communal
Ordre du jour supplementaire
1. La Reponse du comite consultatif d'urbanisme au raport de Dr. Ircha
March 9t', 2009
City of Saint John
Office of the Common Clerk
15 Market Square
City Hall
Saint John, NS
ATTi N: Elizabeth Gormley
Dear Ms. Gormley:
RE: Reply to the Report of Dr. Michael Ircha - March 2009
Please find enclosed my reply to the report of Dr. Michael Ircha. Please
distribute a copy of this reply to the Mayor and Councillors in advance of the
meeting scheduled for 5:00 p.m, tonight.
I apologize for the late hour in providing this reply.
Y
S pin F. Horgan
r
Planning Advisory Committee
City of Saint John
Imlg
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March 91h, 2009
To the Mayor and Council of the City of Saint John
15 Market Square
City Hall
Saint John, NB
Your Worship and Councillors;
Reply to the Report of Qr. Michael Ircho - March 2049
1. I first read the report titled Expediting Saint John's Planning and
Development Process authored by Dr. Michael C. Ircho on Wednesday, March
4th, 2049. 1 have read through the report several times since then and I feel it's
important that no timers lost in responding to certain portions of the report
dealing with the Planning Advisory Committee of Saint John (PAC).
2, 1 am currently the Chair of PAC, a position I have held since January 2007.
This is my ninth year on PAC and previously I was the Third Executive Member
(2001 - 2003) and vice-Chair (2004 - 2006). The PAC executive is elected each
year by PAC members.
3. 1 am a lawyer by profession and I have appeared on behalf of clients
before various PACs in the greater Saint John region. 1 have also appeared
before the Assessment Planning Appeal Board (APAB) on behalf of clients on
various occasions. One such case is noted by Dr. Ircha in his Endnote Wl -
"Dean Construction Limited v. Town of Grand Bay - Westfield Planning Advisory
Committee". I mention this only to point out that I am familiar with the principles
of administrative law and natural justice and how important they are.
4. This response is mine and I accept responsibility for it. There has not been
sufficient time to prepare a response and circulate it among the other members
of PAC. Some members of PAC have contacted me to advise that they feel a
response is necessary.
5. Last week I spoke to the Planning Commissioner, Ken Forrest, and he
advised that a written response to Dr. Ircha"s report would be requested from
PAC. This is not that report. This initial response Is to address Dr. Ircha's comments
which 1 believe have incorrectly and unfairly characterized PAC and its
members.
b, As a general comment, I note that Dr. Ircha's view of the ideal
composition and functioning of PAC is different from mine-
7. On a positive note, issues raised by Dr. Ircha such as orientation sessions
and continuing education for PAC members, the review of PAC administrative
procedures, and others are valid and important. I look forward to developments
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in these areas. Anything that can be done to improve the functioning of PAC is
welcome. There is always roam for improvement. I do not suffer from the
delusion that the operation of PAC and my actions as Chair have been perfect.
I am sure that no one has ever said or implied that.
8. 1 feel that the pu'blic's confidence in the PAC of the City of Saint John
requires that the issues in this document be raised immediately. There is a public
meeting of PAC tomorrow, March 10, 2009 and PAC will continue to meet white
Dr. Ircha"s report is reviewed and debated. What confidence would an
applicant or an interested person have in PAC if no response is provided to the
subjective and negative comments about PAC included in Dr. Ircha's report? I
suggest the answer would be very little of best.
9. My primary concern is Dr. Ircha's contention that there is can "obvious
dysfunctional relationship between PAC and planning staff". PAC is further
described as heaving "little regard for the City's planners, their reports and
analyses, and their recommendations... Staff is rarely questioned in public on the
substance of the application and why they made their recommendations.
Planning staff seems to have little input on the terms and conditions that PAC
may impose when they choose to differ with the planner's recommendations.
The result is PAC setting its awn terms and conditions. This can leave the
applicant with inconsistent and undeliverable conditions to be met." (Page 19 of
Dr. Ircha's report)
10, This relationship is further referred to in terms such as "Overcoming the
current dysfunctional relationship between PAC and staff (as well as between
PAC and Council)..." (page 21) and "As discussed above, the community
perceives a dysfunctional relationship between planning staff and PAC" (page
37) and finally, "Stakeholders raised many concerns about the apparent
dystunctional relationship between PAC and planning staff, and between PAC
and Common Council" (page 53),
11. Dr. Ircho repeats additional negative comments about PAC in his report
such as;
(a) "Some stakeholders reported that PAC has stated can occasion that
they do not care what the Municipal Plan and Zoning By-law say (sic) they
are doing what the Committee thinks is right." Dr. Ircha follows this up with.
a statement that suggests that the above remark is factual: "PAC's
decisions cannot ignore the City's existing planning legislation. They
cannot recommend to Council or decide on variances on the basis of
what they would like the City's plans and by-laws to be." (Page 20);
(la) ",..concerns were raised about how PAC has treated outside
development firms in the past. Stakeholders suggested that PAC has
sought to deter outside developers, essentially creating new barriers for
them." (Page 24); and
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(c) one stake holder spoke of the burdensome PAC conditions set
without planning staff input. Council subsequently had to modify the
terms and conditions" (page 19)
12. Dr. Ircha presents his conclusions about the relationship between PAC and
planning staff and between PAC and Council based on statements from
unspecified "stakeholders". The identity of the "stakeholders" is not connected to
any particular allegation. Sufficient details are not provided to identify a
particular application. No apparent attempt was made to verify the allegations.
Dr. Ircha made no attempt to present these allegations to PAC for a response
prior to the publication of his report.
13. Dr. Ircha met with PAC on one occasion only, on October 2111, 2008 at
PAC's supper meeting prier to the public session. The meeting began at 4:30, a
half hour earlier than normal. Beside the ordinary business of PAC (there were
nine items on the agenda that night) far. Ircha expressed his views on many
aspects of PAC composition and operation. Some of Dr. Ircha's
recommendations concerning PAC's procedures seem to have been drawn
from his previous experience as Chair of Fredericton's PAC. That experience
does not necessarily bear any resemblance to the experience of Saint ,John's
PAC and it leaves me with the strong sense that Dr. Ircha's report is not objective
and that many of Dr. Ircha's conclusions were prejudgments. Many of these are
now included almost verbatim as recommendations in his report. Dr. Ircha also
attended' the public hearing of PAC can October 21, 21)08 as an observer.
14. When did it become accepted' practice to repeat allegations which
have not been substantiated and to quote a group of stakeholders (each with
their own self-interests) without giving any of the context of their comments or
without giving the group against whom the allegations are made, a chance to
respond? Words such as "apparently" proceeding many of these statements is,
in my opinion, an attempt to avoid responsibility for the statements on the part of
the author. It is analogous to the snowball thrower saying "I didn't make the
snowballs, l just threw them."
15. When one reviews the allegations against PAC reproduced in Dr.. Ircha'S
report collectively (and in some cases individually), it is hard to imagine a more
damning description of a planning committee's method of operation. This
damning description is based on allegations for which little specifics have been
provided' and to which the PAC was given no opportunity to respond prior to
publication. In my opinion these allegations are a fundamental
misrepresentation of the actions of PAC. The damage caused by what, in my
opinion, is the irresponsible publication of such allegations cannot easily be
undone. You cannot un-ring a bell.
16. 1 think it's critical to set the record straight on a number of points in r.
Ircha's report.
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17, In 2008, PAC dealt with a total of 197 applications. I have reviewed the
minutes relating to 192 of those applications (the minutes of the 5 items from the
June 171h,2008 meeting were not immediately available to me). Of the
reviewed applications, PAC followed Staff's recommendation without
modification 149 times (77 6); PAC followed Staff's recommendations with some
modification 30 times (1 A), and, PAC disagreed with Staff's recommendations
14 times (7%). In total, PAC actually agreed with Staff's recommendations 93% of
the time. Further, the minutes indicate that in 73 cases (38%) PAC specifically
requested Staff's input on various aspects of their reports. There may also have
been interaction with Staff on other applications, which is simply described as.
"Discussion ensued" in the minutes. I note that my percentage calculations
could be subject to marginal corrections.
18. Of the 15 applications decided by PAC in 2009, PAC followed staff
recommendations without modification with some modification 3 times (20%).
No recommendations have been turned down in 2009 to date. PAC has agreed
with all of Staffs 20109 recommendations to date.
19. Does this describe a PAC which has "little regard for the City's planners,
their reports and analyses and their recommendations"? My response is no..
20. Some of the allegations of stakeholders reproduced in his report do
contain enough information for me to be reasonably sure that I recognize the
application in question. I would like to address two such allegations and a direct
observation of Dr. Ircha:
(a) (i) According to a statement on page 19 of Dr. Ircha's report: "Another
stakeholder, as a residential lot owner, spoke of PAC imposing a condition
on their application that they ensure the developer has an approved
drainage plan for the entire subdivision". Dr, Ircho notes that 'This is
Engineering's responsibility, not that of an individual applicant for a
subdivision loft variance.,'
(il) As I recall, in this particular matter a neighbour of the applicant
attended the meeting of PAC in order to express concern with respect to
the run off of water from lots in this subdivision on to her property, The
variance sought by the applicant was large (73%). Staff had
recommended the variance be approved. In discussion with the planner
responsible for this application during the public hearing, PAC was
advised by the planner that it was entitled to place a condition on the
approval. The application was approved subject to the condition that it
be verified that a drainage plan was in fact in place and the applicant's
lot conformed to that plan. In my opinion, this condition could hardly be
considered as onerous or beyond the jurisdiction of PAC when it was
intended as a precaution against the possibility of damage being done to
a neighbouring property as a result of a variance approval, (PAC minutes
October 30, 2007). Further, it should be noted that it was PAC's
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understanding that the Applicant had not purchased the lot and would
not have to if the variance was denied,
(b) (1) On page 26 of the report, Dr. Ircha notes: "...several stakeholders
spoke of a PAC approved application involving a sewer running beneath
a proposed swimming pool. Apparently, in this case, Engineering input
was missing, but PAC proceeded without it and approved the variance
request,"
(ii) what actually happened was that PAC approved the application
subject to confirmation that there were no easements in place
(prescriptive or otherwise). If an easement such as the one described
above had existed the variance was not to be approved. (PAC Minutes
August 26, 2008) If PAC had simply been consulted about this application,
or if Dr. Ircha had taken the time to verify what did take place prior to Dr.
Ircha's report being published, the allegation could have been clarified
and the negative comment as to PAC's conduct avoided.; and,
(c) (i) On page 22, Dr. Ircha describes, an application involving for c'a
variance to construct an oversize garage - possibly one of the most
common types of variance applications dealt with by PAC. Dr. Ircha was
present at this public meeting of PAC. Dr. Ircha objects to the question
being asked of the applicant whether he was related to a certain person.
Dr. Ircha also states that members of the public might wonder why such a
personal question was being asked. It was obvious to the person
questioned, who responded readily that he did not do business with this
relative (who runs a construction company). The applicant did
acknowledge that he himself owned a "-gravel truck that he does
repairs on as well as a rubber tired back hoe and a couple of plough
trucks. (Name deleted) understood the variance did not give him the
right to carry on any activities that are not permitted in the existing
zoning." (PAC minutes October 21, 2008), This meeting took place on
October 21, 2008 and not on October 2, 2008 as stated in Dr. ircha's
report.
(ii) Dr. Ircha describes the question as inappropriate and states that it
could have been asked in another way. In the context in which it was
asked, l do not agree with dr. Ircha. The question was asked and the
following discussion was meant to directly confirm on the record that the
Applicant was aware of certain inappropriate uses of the garage. I
submit that members of the public in attendance would have no problem
determining why the question was asked.
(iii) Dr. Ircha further states that, "Alternatively, and more appropriately,
specific terms and conditions could have been placed can the variance to
prevent the oversized garage from being used to store construction
equipment. Planning Staff could have provided appropriate wording to
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assist PAC in setting such terms and conditions, had they been asked."
(Page 22) (underlining added).
(iv) Ear. Ircha is apparently unaware that PAC is used to dealing with this
type of application, and had previously discussed with Staff at various
public hearings whether it was necessary to add such a condition as Dr.
Ircha described to variance approvals of this kind. Planning Staff on a
number of occasions confirmed that they did not think it was necessary
and PAC followed the advice provided. Dr. Ircho's response reflects an
unwarranted attitude of condescension toward PAC. A negative
portrayal of PAC could have been avoided, if to paraphrase Dr. Ircha,
PAC had been asked.
21, In conclusion I note that preparing this response has not been a pleasant
experience. It has also consumed a fair amount of time that could have been
spent can other things. However as stated previously 1 believe it to be necessary
to respond to the unwarranted disservice Dr. Ircha's report has done to PAC and
its members. I disagree with the methods used by Dr. Ircha as I have previously
noted.
22. The members of PAC take their responsibilities seriously. In my opinion,
they deserve better than this.
23. PAC will provide a more comprehensive response dealing with the various
recommendations contained in Dr. Ircha's report in due course.
Dated at Saint John, New Brunswick this
h, 2009.
t p en F.Uhiorgan, Chair
Planning Advisory Co tee
City of Saint John
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