February 9, 2021

Town of Goderich 57 West Street Goderich, ON N7A 2K5

Attention: Ms. Janice Hallahan, Chief Administrative Officer

RE: HM Aero Inc. Aeronautical Review: 33862 and 33884 Airport Road, Township of Ashfield-Colborne-Wawanosh Application Nos. ACW OPA No. 10 and ACW Z02-21

Dear Ms. Hallahan, HM Aero is pleased to submit our enclosed review of Application Nos. ACW OPA No. 10 and ACW Z02-21 that are to be considered by the Township of Ashfield-Colborne-Wawanosh. The analysis provided herein is limited to the consideration of the merits of the Planning Applications from an aviation standpoint. This letter should not be interpreted as a fulsome analysis of the consistency and conformity of the Planning Applications against the Planning Act, Provincial Policy Statement, and other applicable plans and policies. Thank you for the opportunity to support the Town through this assignment. If you have any questions, please do not hesitate to contact the undersigned.

Sincerely,

HM Aero Inc.

R. Adam Martin, M.Sc., PMP Ben Crooks, RPP, MCIP President Aviation Planner cc: Sean Thomas, Director of Operations Andrea Fisher, Clerk / Planning Coordinator

Aeronautical Review: 33862 and 33884 Airport Road i

Table of Contents 1 INTRODUCTION ...... 1 1.1 Goderich Municipal Airport ...... 1 1.2 Subject Properties ...... 1 2 PLANNING POLICY CONTEXT ...... 2 2.1 Provincial Policy Statement (2020) ...... 2 2.2 County Official Plan ...... 2 2.3 Township Official Plan ...... 3 2.4 Zoning By-law ...... 3 3 PLANNING APPLICATIONS ...... 4 3.1 Official Plan Amendment ...... 4 3.2 Zoning By-law Amendment ...... 4 4 ANALYSIS ...... 5 4.1 Airport Land Use Compatibility ...... 5 4.1.1 Part I – Obstacle Limitation Surfaces ...... 5 4.1.2 Part II – Telecommunications and Electronic Systems ...... 7 4.1.3 Part III – Bird Hazards and Wildlife ...... 7 4.1.4 Part IV – Aircraft Noise ...... 7 4.1.5 Part V – Restrictions to Visibility / Part VII – Exhaust Plumes ...... 8 4.1.6 Foreign Object Debris ...... 8 4.1.7 Airport Land Use Compatibility Summary ...... 9 4.2 Airport Security and Access Implications ...... 9 4.2.1 Regulatory Requirements ...... 9 4.2.2 Recommended Practices ...... 10 4.2.3 Security and Access Summary ...... 10 4.3 Airport Land Use Planning ...... 11 4.3.1 Existing Airport Plans ...... 11 4.3.2 Proper and Orderly Airport Planning ...... 11 4.3.3 Airport Land Use Planning Summary ...... 14 5 PLANNING OPINION ...... 15 6 RECOMMENDATIONS ...... 16 6.1 Future Aeronautical Approvals ...... 16 6.1.1 Aeronautical Approvals – Transport Canada Aeronautical Assessment Form ...... 16 6.1.2 Aeronautical Approvals – NAV CANADA Land Use Submission ...... 16 6.2 Conditions of Site Plan Approval ...... 17 6.3 Review of Municipal Planning Hierarchy ...... 17

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1 INTRODUCTION

HM Aero is pleased to submit our enclosed review of Application Nos. ACW OPA No. 10 and ACW Z02-21 (the “Planning Applications”) that are to be considered by the Township of Ashfield-Colborne- Wawanosh (the “Township”). The analysis provided herein is limited to the consideration of the merits of the Planning Applications from an aviation standpoint. This letter should not be interpreted as a fulsome analysis of the consistency and conformity of the Planning Applications against the Planning Act, Provincial Policy Statement, and other applicable plans and policies.

1.1 Goderich Municipal Airport

Goderich Municipal Airport (the “Airport”) is a registered aerodrome that is owned and operated by the Town of Goderich. The Airport supports daytime and nighttime aircraft operations with infrastructure that includes two paved runways, one turf runway, a terminal building, three taxiways, and an apron adjacent to the terminal building. The Airport is located approximately 1 km north of the Town boundary in the Township of Ashfield-Colborne-Wawanosh; accordingly, the Township is the lower-tier land use planning authority with respect to the Airport.

1.2 Subject Properties

While the Airport is owned by the Town, several parcels were legally subdivided at an unknown time and are currently held in private ownership. Of interest to this review are 33862 and 33884 Airport Road (the “Subject Properties”) which are owned by Colborne Property Holdings Inc, as shown in Figure 1. 33884 Airport Road (the “Eastern Parcel”) is located east of the terminal building with frontage on Airport Road and the aircraft apron. 33862 Airport Road (the “Western Parcel”) is located to the west of the terminal building and similarly has frontage on Airport Road and the apron. It is understood that both parcels were most recently used by an aircraft painting business, with hangars and infrastructure located on both sites that supported this activity. Based on the documentation submitted by the applicant to the Township, it is understood that this use ended in 2011. Figure 1 - Site Context

RUNWAY 10-28

TAXIWAYS

APRON

WESTERN EASTERN PARCEL PARCEL

AIRPORT ROAD

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2 PLANNING POLICY CONTEXT

2.1 Provincial Policy Statement (2020)

The Provincial Policy Statement1 (PPS) is issued under Section 3 of the Planning Act and came into effect on May 1, 2020. The PPS provides policy direction on matters of provincial interest relating to land use planning and development. The legislative authority of the PPS is established in Section 3(5) of the Planning Act, which requires that planning decisions of municipal councils “shall be consistent with the [Provincial Policy Statement]…” Section 1.6.9.1 of the PPS addresses planning for land uses in the vicinity of airports, stating that such planning shall be undertaken so that “…[their] long-term operation and economic role is protected.” Section 1.6.9.1 highlights that the Province considers the economic role of airports to be a matter of significant interest and acknowledges that adjacent land uses (such as the Subject Properties) can have an impact on that role.

2.2 County Official Plan

As the Township is a lower-tier municipality, the policies of the upper tier municipality (Huron County) must also be considered. The County of Huron Official Plan2 provides guidelines to municipalities for the development of local Official Plans. Local communities are to use the guidelines of the County Official Plan to bring their plans into conformity. The sole policy with respect to airport land use compatibility is provided in Section 7.3.6 – Industrial and Commercial. Policy 3 states that airports are to be (emphasis added): “…designed, buffered and/or separated from sensitive land uses such as residential areas, and education, community and health facilities to prevent or mitigate adverse effects from odour, noise and other contaminants, minimize risk to public health and safety, and to ensure the long-term viability of major facilities.” As described below, the land uses requested for the Subject Properties would not be deemed “sensitive” per Policy 3. However, Section 7.3.6.3 of the County Official Plan reflects the importance of ensuring the long-term viability of major facilities such as airports and acknowledges that nearby land uses can have an impact on viability.

1 Province of Ontario. (May 1, 2020). Provincial Policy Statement, 2020. 2 County of Huron. (September 24, 2015 Consolidation). County of Huron Official Plan.

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2.3 Township Official Plan

Schedule ‘B’ of the Township of Ashfield-Colborne-Wawanosh Official Plan3 designates the Subject Properties as “Airport”. Per Section 8.7.3, the goals for the Airport designation are: • To protect the airport from incompatible development; and • To encourage the establishment of airport-related services on airport lands. Policy 2 of Section 8.7.4 further states that: “Airport related services, including commercial and industrial uses, are permitted on airport lands.” What constitutes an “Airport related service” is not defined in the Official Plan. By extension of Policy 2, uses that are unrelated to Goderich Airport are not permitted within the Airport designation. Accordingly, the Township Official Plan clearly acknowledges that incompatible land uses adjacent to Goderich Airport can negatively impact its growth and development. Further, the Official Plan establishes a vision for future aviation-related development at the Airport which implicitly acknowledges that the aeronautical opportunities at the facility are not available elsewhere in the municipality.

2.4 Zoning By-law

The Township Zoning By-law4 implements the high-level direction of the Township Official Plan and designates the Subject Properties as Airport Lands – Related Uses (AL2). Section 28.1 of the Zoning By-law establishes the following permitted uses within the AL2 zone: • An airport terminal; • An aircraft hangar; • A control tower; • Aircraft maintenance facilities; • An airport related industrial facility; • An airport related commercial facility; • An airport related service facility; • An aircraft taxiway; [and] • Uses accessory to the permitted uses. Summarized, the AL2 zone does not currently permit primary or accessory uses that are not related to the core aeronautical functions of Goderich Airport. This is aligned with the Township Official Plan which directs that incompatible uses should be sited at locations other than the Airport, and that the priority should be aeronautical uses that are able to capitalize on the unique infrastructure and opportunities of Goderich Airport.

3 Township of Ashfield-Colborne-Wawanosh. (2003, October 7). Township of Ashfield-Colborne-Wawanosh Official Plan (as amended – July 28, 2016). 4 Township of Ashfield-Colborne-Wawanosh. (March 2020 Consolidation). Township of Ashfield-Colborne-Wawanosh Consolidated Zoning By-law 32-2008, As Amended.

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3 PLANNING APPLICATIONS

Official Plan Amendment (ACW OPA No. 10) and Zoning By-law Amendment (ACW Z02-21) applications have been submitted to the Township for the Subject Properties. Both applications were deemed complete by the Township on January 15, 2021 and a public meeting will be held on February 16, 2021. The project team’s review is based on the January 26, 2021 Notice of Public Meeting package and January 11, 2021 Planning Applications submitted to the Township.

3.1 Official Plan Amendment

Per the draft Official Plan Amendment, referred to by the Township as the “Official Plan Amendment No. 10 By-Law”, it is understood that Section 8.7.4.2 would be amended through the addition of the following (emphasis added): “Part Block A, Western Division (Reference Plan 22R2001, Parts 1,2,3, Subject to ROW), Colborne Ward, and Plan 564 Part Lot 7 (Reference Plan 22R4442 Part 1 With ROW), Colborne Ward, may also be used for commercial and industrial uses not related to the airport as set out in the zoning by-law.” The Official Plan Amendment would create the policy framework for the implementation of the Zoning By-law Amendment described below, which specifically enumerates the commercial and industrial uses requested.

3.2 Zoning By-law Amendment

The draft Zoning By-law Amendment would rezone the Subject Properties from Airport Lands – Related Use (AL2) to Airport Lands – Related Uses – Special Provisions (AL2-1). The effect of this Amendment would be to add the following land uses as being permitted in the AL2-1 zone: • Warehouse; • Manufacturing; • Motor vehicle, mobile home, and recreational vehicle sales, servicing, and repair; • Agricultural sales and service establishment; • Technical training facility; and • Commercial sand blast and paint facility.

Outdoor storage and offices accessory to the above-noted uses would also be permitted, the former through the granting of relief from Section 28.4.6. From the text of the draft Zoning By-law Amendment, it is understood that the land uses listed above would be permitted in addition to those airport-related uses previously described for the AL2 zone.

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4 ANALYSIS

The merit of the Planning Applications requested for the Subject Properties must be considered through the consistency and conformity tests articulated in the Planning Act. The project team’s analysis of the Planning Applications considers their impacts on the long-term operation and economic role of Goderich Airport based on three subject matter areas: 1. Land use compatibility between the Subject Properties and Airport operations; 2. Security and access implications; and 3. Airport land use planning best practices and the highest and best use of the Subject Properties from an aviation perspective.

4.1 Airport Land Use Compatibility

Transport Canada has published guidance material on airport-compatible land use planning in TP1247 – Land Use in the Vicinity of Aerodromes (9th Edition). Per its abstract, TP1247 is intended to describe “…different types of land uses outside the aerodrome property boundary and recommends, where applicable, guidelines for those land uses in the vicinity of aerodromes.” TP1247 provides guidelines that may be implemented by municipalities; however, TP1247 is not a federal law or standard. TP1247 is structured to provide guidance across eight thematic Parts. With the exception of Parts VI – Wind Turbines and Wind Farms and VIII – Solar Array Installations, which are uses that are not being contemplated for the Subject Properties, these themes are explored below. Additionally, while TP1247 does not include a discussion of Foreign Object Debris, the requested addition of outdoor storage as a permitted use warrants an overview of this matter.

4.1.1 Part I – Obstacle Limitation Surfaces Part I of TP1247 considers maximum development heights to protect the airspace around airports, as delineated through Obstacle Limitation Surfaces. Three types of Obstacle Limitation Surfaces are typically defined for airports, as shown in Figure 2 and described below: • Approach Surfaces: An inclined plane that extends upwards and diverges outwards from the end of a runway strip; • Transitional Surfaces: A complex inclined plane that extends upwards and outwards from the edge of a runway strip; and • Outer Surface: A common plane established at 45 m above the airport that extends outwards for 4,000 m.

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Figure 2 - Example Obstacle Limitation Surfaces

Goderich Airport does not have federal Airport Zoning Regulations governing development heights, and as a registered aerodrome, it is ineligible for such Regulations. Accordingly, maximum development heights must be addressed in the municipal planning hierarchy. Section 28.4.1 of the Zoning By-law addresses maximum building and structure heights within the AL2 zone based on their proximity to the Airport Lands Facilities (AL1) zone, stating that: “…no building or structure may be higher than a height calculated based on the ratio of 1:7 from the side perimeter of an AL1 zone.” With respect to the Subject Properties, the effect of Section 28.4.1 is to delineate a Transitional Obstacle Limitation Surface for Runway 10-28 (previously shown on Figure 1). The northern boundaries of the Subject Properties abut an AL1 zone and accordingly are subject to this provision. Based on a preliminary review by the project team, the existing structures on the Subject Properties appear to be non-conformant with the provisions of Section 28.4.1. Additionally, while the intent of Section 28.4.1 appears to be to protect the Airport’s Obstacle Limitation Surfaces, the Zoning By-law errs in its application of Transport Canada’s standards / guidelines by basing its height calculations off the edge of the AL1 zone as opposed to the runway strip.

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4.1.2 Part II – Telecommunications and Electronic Systems Canada’s air navigation system is reliant on a complex network of electronic navigation aids, radar units, and telecommunication systems. Goderich Airport no longer has any electronic navigation aids physically located on-site following the decommissioning of its Non-Directional Beacon by NAV CANADA, and the project team is not aware of any radar units on-site. Two GPS-based Instrument Approach Procedures are provided for Runway 14 and Runway 32 for operations during Instrument Meteorological Conditions. The specific impacts of non-aeronautical development on the Subject Properties to the facility’s Instrument Approach Procedures will be identified by NAV CANADA through its Land Use Submission process, which is described in Section 7.2.2.

4.1.3 Part III – Bird Hazards and Wildlife Part III describes how certain land uses can attract birds and wildlife that pose a hazard to aircraft operations, and how appropriate siting and mitigation controls can be used to reduce this risk. For example, ponds, vegetation, and garbage storage can attract birds and increase the risk of in-flight bird strikes. Given their location at Goderich Airport, the Subject Properties are located within TP1247’s Primary Hazard Zone which includes airspace in which aircraft are below altitudes of 1,500 ft. Above Ground Level. The uses requested in the Zoning By-law Amendment were reviewed against TP1247’s land use acceptability table. The six requested uses are not identified in TP1247’s scale of Potentially Limited Risk to Potentially High Risk land uses. Accordingly, TP1247 does not recommend that the requested land uses should be prohibited outright on the basis of bird and wildlife hazards. Instead, bird and wildlife hazards should be assessed during the Site Plan Control process and mitigation measures should be implemented as required.

4.1.4 Part IV – Aircraft Noise A significant component of airport land use compatibility is aircraft noise and perceived annoyance. Appropriate planning that separates sensitive land uses from areas of high noise exposure can proactively minimize future conflicts. In Canada, the Noise Exposure Forecast (NEF) system is used to predict the overall subjective annoyance and reaction levels caused by aircraft operations on specific land uses. Through inputs such as the number of aircraft movements, day / night split, runway usage, and other factors, the NEF system outputs contours which represent constant levels of perceived annoyance. To the project team’s knowledge, an NEF study has not been completed for Goderich Airport. TP1247 provides guidance on the acceptability of various land uses in relation to different NEF contours. The project team has reviewed Transport Canada’s guidance on land use acceptability within the most restrictive NEF 40 and NEF 35 contours. Given the proximity of the Subject Properties to the Airport, this represents a reasonable approach in the absence of NEF contours prepared specifically for Goderich Airport. Where a land use identified in the Planning Applications does not have a direct equivalent in TP1247, a suitable proxy is chosen. As shown in Table 1, several of the requested land uses would be acceptable within the most restrictive NEF 40 contour. Other uses, such as offices and outdoor sales, may be acceptable pending the completion of a detailed noise analysis, the provision of acoustic insultation, or when the use is ancillary to an otherwise acceptable use (e.g., an office ancillary to a warehouse). Accordingly, the land uses requested may present minimal compatibility concerns from a noise perspective – however, the completion of a detailed noise analysis and the implementation of acoustic mitigation measures may be required at the time of Site Plan Control.

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Table 1 - Noise Exposure Forecast Review Requested Land Use TP1247 Proxy Land Use NEF > 40 NEF 35 – 40 Warehouse Warehouse YES YES Manufacturing Factories YES (I) YES (I)

Vehicle Sales, Servicing, Outdoor Sales E K and Repair Machine Shops YES (I) YES (I)

Agricultural Sales and Outdoor Sales E K Service Establishment Machine Shops YES (I) YES (I) Technical Training Facility Offices F E Commercial Sand Blast Factories / Machine YES (I) YES (I) and Paint Facility Shops Offices (Ancillary Use) Offices F E E – When associated with a permitted land use, an office may be located in this zone provided that all relevant actors are considered and a detailed noise analysis is conducted to establish the noise reduction features required to provide an indoor environment suited to the specific office function. F – It is recommended that this specific land use should be permitted only if related directly to aviation-oriented activities or services. Conventional construction will generally be inadequate and special noise insulation features should be included in the building design. I – Many of these uses would be acceptable in all NEF zones. However, consideration should be given to internally generated noise levels, and acceptable noise levels in the working area. K – It is recommended that serious consideration be given to an analysis of peak noise levels and the effects of these levels on the specific land use under consideration.

4.1.5 Part V – Restrictions to Visibility / Part VII – Exhaust Plumes Certain land uses generate exhaust plumes, smoke, dust, or steam in sufficient volumes to negatively impact aerodrome visibility, which represents a risk for pilots. Of the uses requested for the Subject Properties, the majority are anticipated to result in minimal to no restrictions to visibility through the generation of smoke, dust, or steam. It is premature to identify a requested use that would definitively result in restrictions to aerodrome visibility. Accordingly, it is recommended that potential restrictions to visibility be identified during the Site Plan Control process with conditions added to mitigate any issues.

4.1.6 Foreign Object Debris While not addressed in TP1247, Foreign Object Debris (“FOD”, also known as Foreign Object Damage) is a considerable risk to aviation safety at airports. FOD is any object or substance that causes, or has the potential to cause, damage to an aircraft. At airports, examples include loose pavement; gravel and sand; garbage; construction debris; and baggage, clothing, and personal items. Given the expansive definition of what constitutes FOD, all new development, whether aviation or non- aviation in nature, should include provisions for limiting and mitigating FOD. Of the uses requested in the Planning Applications, several have the potential to generate FOD that can enter the Airport’s movement areas such as manufacturing, warehouses, and commercial sand blasting and painting facilities. The requested addition of outdoor storage as a permitted use is also a source of potential FOD, as stored items or components thereof can be blown onto the airfield. Similar to the preceding discussions, the potential negative impacts of FOD will vary based on the specific use(s) proposed in the future. At the time of Site Plan Control, FOD potential should be evaluated and satisfactory mitigation measures imposed – these mitigation measures should form part of the Site Plan Agreement to allow for future enforcement.

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4.1.7 Airport Land Use Compatibility Summary From a land use compatibility perspective, the following conclusions can be made: 1. By introducing new commercial and industrial uses to the Subject Properties that are unrelated to the Airport, their compatibility with Airport operations must be considered to ensure the facility’s future viability and to mitigate potential conflicts; 2. The development of new structures should comply with the Airport’s Obstacle Limitation Surfaces. Development height restrictions in the Zoning By-law currently result in the buildings on both parcels being non-conforming uses; 3. Development or redevelopment will trigger the need for an assessment of the impacts to the air navigation system by NAV CANADA and Transport Canada; 4. Conditions to address bird and wildlife hazards should be required at the time of Site Plan Control; 5. The requested uses may present minimal concerns from an Airport noise perspective – however, the completion of a detailed noise analysis and the implementation of acoustic insulation should be required at the time of Site Plan Control if required; 6. Potential restrictions to aircraft visibility from exhaust plumes, smoke, and dust should be addressed at the time of Site Plan Control; and 7. Foreign Object Debris should be evaluated and controlled with all future development.

4.2 Airport Security and Access Implications

The Subject Properties abut and have direct access to the aircraft apron of Goderich Airport. Consideration must be given to the airside access and security implications of the Subject Properties being used for non-aeronautical purposes. The project team was not provided with information on whether easements or access agreements exist providing unrestricted access to the airfield from the Subject Properties. The presence of such easements and agreements should be verified.

4.2.1 Regulatory Requirements The Canadian Aviation Regulations (CARs) enumerate the regulatory requirements for registered aerodromes in Subpart 301. With respect to security, CAR 301.08(a) states that: “No person shall: (a) walk, stand, drive a vehicle, park a vehicle or aircraft or cause an obstruction on the movement area of an aerodrome, except in accordance with permission given (i) by the operator of the aerodrome…” The CARs do not specifically require the provision of perimeter fences, gates, or other similar access control infrastructure at registered aerodromes to accomplish the requirements of CAR 301.08. Additionally, Goderich Airport is not a designated Class 1, 2, or 3 Aerodrome in the Canadian Aviation Security Regulations, and the requirements imposed through Part 7 – Other Aerodromes do not include the establishment of the above-noted access control infrastructure.

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4.2.2 Recommended Practices While physical access controls are not required for Goderich Airport, the project team has encountered several instances in their professional practice that underscore the need to exceed minimum regulatory standards. Transport Canada’s Aeronautical Information Manual5 captures this consideration, stating that (emphasis added): “Aerodrome operators are encouraged, in the interest of aviation safety, efficiency, and convenience, to improve their aerodromes beyond the basic regulatory requirements...” As the Airport’s perimeter fence is discontinuous with multiple publicly accessible gaps, it is unlikely that the introduction of non-aeronautical uses to the Subject Properties will substantially increase the threat of unauthorized access by compromising the facility’s discontinuous Primary Security Line. However, future non-aeronautical users of the Subject Properties may not be knowledgeable with respect to airside safety and aircraft operations. Both parcels abut an apron used for aircraft taxiing, parking, and fuelling. Unauthorized use of the apron by persons and vehicles (e.g., delivery vehicles, construction activity) can result in safety and efficiency risks through conflicts with aircraft operating on the apron. Accordingly, while Goderich Airport does not have the regulatory requirement to implement physical access control measures, taking such measures is strongly recommended to limit conflicts between aircraft operating on the apron and the potential future non-aeronautical users of the Subject Properties. Implementing perimeter control measures around the boundaries of the Subject Properties is an advisable practice, which may be considered at the time of Site Plan Control.

4.2.3 Security and Access Summary With respect to airside access and security: 1. The Canadian Aviation Regulations direct that unauthorized access should be limited, although Goderich Airport is not required to have physical access controls based on the Canadian Aviation Regulations and Canadian Aviation Security Regulations; 2. To limit future conflicts between non-aeronautical users of the Subject Properties and aircraft operating on the apron, perimeter fencing is recommended to be installed around both parcels as a condition of the Site Plan Control process; and 3. The project team is unaware if easements are in place to provide unrestricted access to the airfield from the Subject Properties. If a non-aeronautical use seeks to develop on the Subject Properties, the Town should investigate the feasibility of removing such easements.

5 Transport Canada. Aeronautical Information Manual – AIM 2020-2 (Effective 0901Z, October 8, 2020 to 0901Z, March 25, 2021).

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4.3 Airport Land Use Planning

4.3.1 Existing Airport Plans Based on information provided by the Town, it is understood that there is currently no Master Plan, Development Plan, or Land Use Plan prepared for Goderich Airport to guide future growth and development. The most recent study for the Airport was commissioned by Huron County and was completed in 2017, which examined opportunities and development projects to diversify revenues, reduce operating costs, and improve the facility’s financial sustainability6. Among the opportunities for Goderich identified in the 2017 Feasibility Study were new airside hangars, groundside commercial development, and aviation-related manufacturing. With respect to the last opportunity, the 2017 Feasibility Study identified the Eastern Parcel as an appropriate site for commercial and light industrial aerospace activities. In January 2020, an Airport Task Force was established by the Town of Goderich to examine the future growth and development of Goderich Airport, including representatives from the Township and Huron County. It is understood that as part of the Airport Task Force’s mandate, a detailed business plan and land use / development plan is to be prepared in the future.

4.3.2 Proper and Orderly Airport Planning Proper and orderly airport planning involves the consideration of numerous factors, such as aviation safety, compatibility between land uses, and making efficient use of existing and planned infrastructure. Matters of aviation safety and land use compatibility were addressed in the preceding discussions. New development at Goderich Airport requires several types of supporting infrastructure, including: • Groundside roadway access; • Servicing and utilities; and • Airside access via a taxiway or apron. A comparison can be made to planning for efficient municipal development. Throughout the Provincial Policy Statement, a recuring theme is that new development should utilize existing municipal infrastructure where possible to limit the need to expand such assets. Examples of this direction are provided in Sections 1.1.3.6 and 1.1.5.5 of the PPS, directing that (emphasis added): 1.1.3.6 New development taking place in designated growth areas should occur adjacent to the existing built-up area and should have a compact form, mix of uses and densities that allow for the efficient use of land, infrastructure and public service facilities. 1.1.5.5 Development shall be appropriate to the infrastructure which is planned or available, and avoid the need for the unjustified and/or uneconomical expansion of this infrastructure. The Subject Properties currently provide the three primary types of infrastructure necessary to support aeronautical development, including: • Groundside access via Airport Road; • Municipal potable water, private septic, stormwater sewers and ditches, and electrical servicing7; and • Access to the Airport’s runways via the apron and taxiway.

6 Explorer Solutions. (2017, January 3). Feasibility Study for Goderich Municipal Airport and Richard W. Levan Municipal Aerodrome: Final Report. 7 This information is based on the January 11, 2021 Planning Applications submitted to the Township.

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Figure 3 - Existing Use of AL2, AG1-22, and AG4 Zoned Lands (Huron County GIS) BLUEWATER HIGHWAY BLUEWATER

TAXIWAYS

RUNWAY 10-28 LAKE AVENUE LAKE

APRON

AIRPORT ROAD

Orange shaded areas denote the Subject Properties Red shaded areas denote occupied AL2, AG1-22, and AG4 lands Blue shaded areas denote vacant AL2 lands

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Figure 3 illustrates the existing use of AL2, AG1-22, and AG4 zoned lands accessible from Airport Road, including: • The Subject Properties, shown in orange; • Private and Town-owned lands that are currently occupied for aeronautical and non-aviation uses (shown in red); and • Vacant lands without airside access, shown in blue. As shown in Figure 3, save and except for a small area west of the general aviation hangars and the Subject Properties, there are no vacant lands available with airside access via a taxiway or apron. Assuming the Subject Properties are removed from potential aeronautical usage through their sale and development for one of the uses requested in the Planning Applications, any new development needing airside access would require the construction of a new taxiway and / or apron. As with the extension of other forms of municipal infrastructure, this has asset management implications such as: • The capital costs of planning, designing, and constructing the taxiway or apron; • The operating costs of maintaining the asset, such as increased snow clearing and pavement maintenance requirements; and • The capital costs of rehabilitating or reconstructing the asset at the end of its useful life. Additionally, the vacant AL2 zoned lands, while potentially developable based on a preliminary review, are subject to constraints that include the Runway 05 and Runway 32 Approach Obstacle Limitation Surfaces, and the eastern lands are designated as a Significant Groundwater Recharge Area. The project team notes that the Subject Properties have been vacant for over five years following the closure of their previous aviation service uses, and the development proponent states the following in their Planning Applications: “The aircraft industry world wide is suffering and more specifically locally. The existing land and structures are well suited for other uses which could promote local job opportunities.” The project team has not been requested to analyze the development opportunities of Goderich Airport or to comment on the 2017 Feasibility Study. The challenges faced in attracting new aviation purchasers of the Subject Properties highlights that future growth at Goderich Airport will require proactive marketing and action, potentially by the Airport Task Force. However, from an airport planning perspective, both parcels represent strong opportunities for future aeronautical development given their existing airside access, groundside access, and servicing. While permitting the requested non-aeronautical uses will not guarantee that such development will occur in the future, the potential for such an outcome is introduced. In doing so, future aeronautical growth at Goderich Airport while be constrained through the removal of ideal development lands (the Subject Properties) and will require the extension of airside infrastructure with associated asset management implications. While non-aeronautical development is common at airports across Canada, appropriate planning involves directing this activity away from areas where an aviation end user represents the highest and best outcome based on available infrastructure and regional opportunities.

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4.3.3 Airport Land Use Planning Summary Goderich Airport is a unique regional economic asset; while non-aviation users do not require aeronautical infrastructure, an aviation business seeking to develop in the Township is limited in its siting choices to Goderich Airport. Accordingly, the following conclusions can be made from an airport planning perspective: 1. There are no existing plans or studies to guide development at the Airport. It is understood that an Airport Task Force has been established by the Town, Township, and County to undertake such a study in the future; 2. Proper and orderly airport planning involves making efficient use of infrastructure required to support development. The Subject Properties are the only vacant lands at the Airport with airside access, groundside access, and servicing, and accordingly represent the highest priority for new aviation development; and 3. Adding new non-aviation commercial and industrial permitted uses may result in the parcels being removed for future aeronautical use, hindering new aviation development, and making inefficient use of the Subject Properties from a highest and best use perspective.

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5 PLANNING OPINION

Based on the preceding discussions, it is our professional opinion that the land uses requested for the Subject Properties are not defensible from an aviation planning perspective. This opinion is based on the following conclusions made throughout the report: 1. Planning decisions by Council are to be consistent with the PPS. Section 1.6.9.1 of the PPS articulates that the economic role of airports is a matter of provincial interest and states that planning for nearby land uses shall be undertaken so that their long-term operation and economic role is protected. 2. In their current form, the Township Official Plan and Zoning By-law create a clear policy direction that prioritizes the development of aeronautical uses that can capitalize on the unique infrastructure and opportunities of Goderich Airport, and directs incompatible land uses elsewhere in the municipality. 3. From an aviation land use compatibility and security perspective, the requested land uses may be acceptable provided that detailed assessments of aeronautical constraints are completed, and appropriate mitigation measures are required at the time of Site Plan Control. 4. Developing the Subject Properties for non-aeronautical purposes represents an inefficient use of the existing airside infrastructure that is unique to Goderich Airport and that aviation users require for development. By removing the Subject Properties through non-aviation redevelopment, future aeronautical land development at Goderich Airport will require the Town to undertake capital infrastructure expansion projects through the extension of taxiways and / or aprons, with associated operating cost and initial / lifecycle capital cost implications. This is generally inconsistent with the direction provided in the Provincial Policy Statement regarding the efficient use of existing infrastructure and the protection of the economic role of Ontario’s airports.

Aeronautical Review: 33862 and 33884 Airport Road 15

6 RECOMMENDATIONS

As stated in Section 5, it is our professional opinion that the land uses requested for the Subject Properties are not defensible from an aviation planning perspective. Accordingly, it is our recommendation that the Planning Applications should not be approved by Township Council. In the event that Township Council approves the Planning Applications, identified herein are the future aeronautical approvals required prior to development, and recommended conditions of Site Plan Approval. Lastly, a recommendation is made on updating the manner in which off-Airport land use compatibility is addressed in the municipal planning hierarchy.

6.1 Future Aeronautical Approvals

In the event the Planning Applications for the Subject Properties are approved by the Township and development of one of the requested non-aviation uses is proposed through the Site Plan Control process, additional actions will be required to ensure that impacts to Goderich Airport are minimized. These include future approvals required from Transport Canada and NAV CANADA.

6.1.1 Aeronautical Approvals – Transport Canada Aeronautical Assessment Form Future construction and / or alterations to the existing structures on the Subject Properties will require that the development proponent reviews the criteria for the submission of a Transport Canada Aeronautical Assessment Form. The Form will be used by Transport Canada to determine whether the proposed development requires lighting and / or markings per Standard 621 of the CARs. Per Standard 621, an AAF must be submitted at least 90 days prior to construction. If a response is not received by Transport Canada after the 90-day period expires, construction can commence. However, if markings and / or lighting are subsequently required by Transport Canada, it is the developer’s responsibility to make the requested additions and bring the building into compliance.

6.1.2 Aeronautical Approvals – NAV CANADA Land Use Submission A General Submission Form must be provided to NAV CANADA for the organization to identify any impacts that the proposed development may have on the air navigation system, such as Goderich Airport’s Instrument Approach Procedures. NAV CANADA attempts to respond to General Submission Forms in 8 to 12 weeks. However, the organization also states that processing times can reach 12 to 18 months in certain instances. There is no cost incurred to the proponent in the NAV CANADA General Submission Form process. If granted, the approval is valid for 18 months.

Aeronautical Review: 33862 and 33884 Airport Road 16

6.2 Conditions of Site Plan Approval

Through the Site Plan Control process, the following conditions should be applied where relevant for a non-aeronautical development proposal on the Subject Properties: 1. Access controls (i.e., perimeter fencing) should be installed along the property perimeter limiting access to the airfield. Any easements granting access from the Subject Properties to the airfield should be released; 2. Pending the completion of an assessment of restrictions to pilot visibility from smoke, dust, exhaust plumes, or other sources, satisfactory mitigation measures should be implemented; 3. Following the assessment of potential bird and wildlife hazards, satisfactory mitigation measures should be implemented; 4. Based on the completion of a noise impact study, recommended acoustic insultation measures should be implemented; and 5. Conditions related to FOD control should be imposed.

6.3 Review of Municipal Planning Hierarchy

Beyond our review of the Planning Applications, the project team has had the opportunity to consider how the existing municipal planning hierarchy addresses land use compatibility in the vicinity of Goderich Airport. The project team commends the Township for proactively defining the AL2 zone and making provisions for matters such as maximum development heights. As noted above, while it appears that the Zoning By-law has been informed by Transport Canada’s standards in how it addresses maximum development heights, the By-law provisions do not correctly interpret and implement this direction. It is recommended that the Township’s policies with respect to airport land use compatibility be reviewed with the assistance of a qualified party and expanded in their scope, to address other matters examined above such as bird hazards, restrictions to visibility, and NEF contours.

Aeronautical Review: 33862 and 33884 Airport Road 17