HomeMy WebLinkAbout2014-055Ontario Municipal Board
Commission des affaires municipales
de I'Ontario
Ontario
ISSUE DATE: July 16, 2014 CASE NO(S).: PL140557
PROCEEDING COMMENCED UNDER subsection 17(36) of the Planning Act, R.S.O.
1990, c. P. 13, as amended
Appellant:
Barb Maddox
Appellant:
Adam Walker
Subject:
Proposed Official Plan Amendment No. 99
Municipality:
Town of Clarington
OMB Case No.:
PL140557
OMB File No.:
PL140557
PROCEEDING COMMENCED UNDER subsection 34(19) of the Planning Act, R.S.O.
1990, c. P. 13, as amended
Appellant:
Barb Maddox
Appellant:
Adam Walker
Subject:
By -law No. 2014 -057
Municipality:
Town of Clarington
OMB Case No.:
PL140557
OMB File No.:
PL140558
APPEARANCES:
Parties Counsel /Representative
Barb Maddox Brian Vogel
Adam Walker
Republic Live Inc. Paul DeMelo+
Town of Clarington Andrew Allison-
HEARING EVENT INFORMATION:
Hearing: Held in the Town of Clarington on July 15, 2014
2 PL140557
ORAL DECISION DELIVERED BY R. ROSS[ AND ORDER OF THE BOARD
INTRODUCTION
[1 ] Republic Live Inc. ( "Republic ") has proposed two planning instruments to
facilitate the annual Boots and Hearts Music Festival, which takes place July 31- August
3, 2094 at the Canadian Tire Motorsport Park: Official Plan Amendment No. 99 ( "OPA
99 ") to the Municipality of Clarington ( "Municipality ") Official Plan and Zoning By -law
Amendment No. 2014 -057, a Temporary. Zoning By -law ( "ZBA ") that amends the
Municipality's Zoning By -law No. 2005 -109, as amended. If approved, OPA 99 will
redesignate the property known municipally as 3730 Concession Road 10 in Orono
from "General Agricultural Area" to "Green Space ". The ZBA will permit vehicular
parking, ticket processing booths and ancillary uses (such as portable washrooms and
bus passenger loading) on the subject property.
[2] Municipality Council adopted OPA 99 and passed Temporary Zoning By -law No.
2014 -057 to facilitate the event. Subsequently, Appellants Adam Walker (representing
himself) and Barb Maddox (represented by her husband Brian Vogel) appealed the
instruments to the Board.
[3] Andrew Allison, counsel for the Municipality, advised the Board that just prior to
the commencement of this hearing, Municipality Council held a special session meeting
that removed the "H" (Holding) Symbol in the ZBA (recognizing that there will be a site
plan agreement and Special Event Permit process subsequent to this hearing) as well
as reduced the period of validity of the ZBA to permit vehicular parking from 3 years to 2
years in response to residents' concerns. There was no objection to these changes. At
this hearing, the Board next directed the Appellants to meet with the counsels for
Republic and the Municipality to scope further the appeals and ascertain whether a
resolution of some or all of the Appellants' concerns could be achieved. Partial success
followed a lengthy recess and Ms Maddox withdrew her appeal as the parties reached a
private settlement of her issues. The Board recognized and accepted the withdrawal of
Ms Maddox's appeal in the presence of all parties. However, no consensus was
achieved with Mr. Walker and his case proceeded.
[4] These are the oral reasons of the Board that were delivered at the hearing. The
Board reserved its right to amplify these reasons with references to the documentation
and evidence presented at this hearing.
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PL140557
[5] Mr. Walker presented no planning evidence in this case. He offered no
professional witnesses to refute the extensive specialized study documentation that
Republic presented. Despite various references by the Board, Republic's planner and
counsels for Republic and the Municipality to the evidence from the commenting
agencies that there were no concerns with the instruments, planning or otherwise, Mr.
Walker remained adamant that his concerns were not allayed. In its oral decision, the
Board noted this approach to the planning appeal process and made note of the failure
of the witness to present evidence to support his appeal. This failure, whether
accidental or purposeful, was reasonably characterized by the Board in its oral decision
as an abuse of its time and its processes. Much latitude was afforded to Mr. Walker
throughout the hearing in his presentation with the consent of the opposing counsels.
The Board directed Republic's planner Valerie Cranmer — the only planning witness at
this hearing — to take note of Mr. Walker's specific concerns as he raised them and the_
to respond to these which, in the Board's determination, the planner did directly and
satisfactorily. Notwithstanding the presentation of unchallenged and uncontroverted
evidence in the form of the planning instruments, expert evidence, support from the
commenting agencies and the highly persuasive arguments and submissions of
counsels for Republic and the Municipality, however, Mr. Walker remained unmoved.
(6] It is well known that the Board welcomes residents and private citizens from
across the Province of Ontario to participate in the planning appeal process. However,
it is a reasonable expectation of the Board that all persons having business before it will
prepare themselves sufficiently for the hearing. Mr. Walker's resolute obstinacy and
failure to acknowledge the overwhelmingly supportive evidence before the Board
impeded this important appeal process, delayed the proceedings unnecessarily and
otherwise caused the parties considerable time and financial expenditure, all by virtue of
an appeal that lacked substance. As Board jurisprudence holds, the mere recitation of
planning terms (and there were none in Mr. Walker's presentation) by an Appellant does
not raise legitimate planning grounds per se on which to hold a hearing. By extension,
an Appellant's dogged pursuit of issues without supporting evidence and in the face of
persuasive opposing evidence — as occurred at this hearing — is distinctly unhelpful to
the Board.
[7] Notwithstanding the extensive efforts invested by the Board as part of its
regularly - occurring adjudicative processes, the Board was heartened to witness two
things occur: first, an amiable solution worked out between Republic, the Municipality
4 PL140557
and Ms Maddox that led to her withdrawal of her appeal; and second and perhaps most
encouragingly, Mr. Walker's realization albeit late of the importance of evidence to
support an appeal before the Board. What is more, the Board was appreciative of Mr.
Walker's presence and this Appellant comported himself professionally, respectfully and
remained fully engaged in the hearing process despite his lack of preparedness and
planning evidence. Accordingly, there is no basis for the Board to entertain costs in
light of his earnestness and concern for his community, a fact appreciated by counsels
for Republic and the Municipality. The Board thanks them for their patience in this
regard.
[8] Ms Cranmer's contextual evidence informed the Board regarding site
characterizations, its location and the application's history. The subject property is
some 45 hectares in size and is located between Concession 10 and Regional Road 20
and is sited just west of Highway 115, some 3.5 kilometres from the Canadian Tire
Motorsport Park. There is no access on the property's frontage with Hwy 35. There is a
large woodlot at the front of the property that has been identified as a Significant Natural
Feature that is the subject of some conditions that will be considered in the site plan
(not before the Board).
[9] The Oak Ridges Moraine Conservation Plan designates the lands "Green Space"
while the Municipality of Clarington Official Plan designates the land "General
Agricultural Area ". OPA 99 simply seeks to provide the lands with a designation already
provided for, and reflective of, what the Conservation Plan recognizes. Durham Region
has already eliminated the Agriculture designation. The intention to redesignate the
area to Green Space is a permanent step although the ZBA is temporal in nature,
providing for vehicular parking on the subject property that will be reviewed after two
years. Ms Cranmer explained that the original zoning application was permanent in
nature but the Municipality subsequently proposed the temporary designation for the
parking and ancillary uses principally to address the changing nature of this music event
and to respond to residents' concerns from the year before. The Municipality will be
looking to Republic's capacity to address those concerns under the temporary rezoning
ZBA. This is something that both the site plan and Special Event Permit tools will
reflect.
[10] Turning then to the planning evidence, Ms Cranmer's expert opinion and
professional land use planning evidence were instrumental in enabling the Board to
5 PL140557
determine that OPA 99 and the ZBA represent good planning and should be approved.
Equally, work of the Municipality's planning staff must be singled out by the Board for its
degree of technical attention to all facets of the instruments as well as to the planning
process. The May 2014 planning report on file (Report No." PSD- 032 -14) of the
Municipality's Planning Department Services is an excellent example of the thorough
and capable work of the Municipality in assessing the planning merits of Republic's
instruments and thus formulating staff's recommendations to Council who subsequently
approved the instruments. Republic's preparation of studies and documents to support
the instruments — particularly for an item such as the ZBA whose temporal nature might
have given rise to a less - comprehensive approach by another entity — was persuasive
evidence of this party's desire to work with the community and to minimize impacts.
Coupled with its materials is the May 21, 2014 letter from Republic that sets out all of its
anticipated and planned efforts to hold a successful public entertainment event. In the
Board's determination, Republic's work and especially that of the Municipality went well
beyond what would reasonably be required of any municipality or private party to
facilitate a single four -day event this year and next. Additionally, Republic and the
Municipality will be entering into a Site Plan Agreement (not before this Board) and a
stringent Special Event Permit Approval issuance to further safeguard the area, the
land, the community and event attendees.
[11] The majority of Mr. Walker's concerns fell off as he made his presentation to the
Board and Ms Cranmer ably addressed his remaining points. Specifically, where he
expressed concerns with the identified bore holes (the immediate and surrounding area
is home to various aggregate operations as well as agricultural uses), the Board heard
that Republic has prepared 30 -metre buffer protection zones and will work carefully
subsequent to this hearing to identify other bore holes if necessary and to develop
protection zones so that any possible spillage does not impact those holes.
[12] Where the Board heard that there is an identified bore hole near the land of the
hearing's sole participant, Brent Moxam (the owner /operator of the nearby Oak Ridge
Equestrian Park who raised a concern with possible environmental impacts from parked
cars on the subject lands), Paul DeMelo, counsel for Republic reiterated the efforts that
will be taken (borne out fully.in the documentary evidence) to address impacts.. Mr.
DeMelo also explained that there is a question as to whether the bore hole as identified
by Mr. Moxam even appears on the subject property but if so, his client would be happy
to create a 40 -metre buffer protection around it. The Board places no such obligation
M
PL140557
on Republic in this regard, however, and will leave this matter to subsequent Site Plan
processes and to be addressed commensurate with its completed work on other
identified bore holes. That being said, neither Mr. Walker nor the participant raised any
environmental issues that would call into question the extensive efforts by Republic to
protect sensitive natural features found on or proximate to the proposed parking areas
of the site. And, as Mr. DeMelo explained, spillage and full contingency plans are
documented and in place to address these issues should they arise over the four days.
[13] . Where Mr. Walker expressed concern with the secondary containment of waste
and generator fuel on site, Ms Cranmer referenced the environmental study (the
Scoped Natural Heritage Evaluation) at Tab 7 of the join document book and noted
Section 9.5 fuel Handling, which provides recommendations for the handling of
generators on site and ways to minimize the potential for fuel spills and leaks from
vehicles. All of these will be captured by Republic in the subsequent instruments that
will guide event operations during the festival. Tab 12 goes farther wherein Oakridge
Environmental Limited addresses the modalities of dealing with leaking vehicles and the
role of event staff in responding to offending vehicles.
[14] Where Mr. Walker expressed concern with traffic and dust, Ms Cranmer
presented the Board with the Traffic Management Plan with its supportive
recommendations and conditions that confirm that successful management and control
of vehicular movements and traffic has been planned for strategically. It is evident that
the traffic to result from event attendance at Canadian Tire Motorsport Park will be
temporary and does not create adverse impacts or planning concerns. Where Mr.
Walker expressed concern with the dust that vehicles will create, Engineering Services
has also called for a dust control plan to limit and mitigate impacts of local road travel
for the event's four days.
[15] In plain terms, none of the commenting agencies expressed concerns or
objections (all documentation on the Board's file and in Republic's and the Municipality's
joint document book, Exhibit 1). Of note: the Ontario Ministry of Transportation had no
objection. The Ministry of Natural Resources had no concerns with the proposed
applications for land use change and proposed conditions that are acceptable to the
Municipality and Republic. Regional Planning Department had no objection to the
proposed uses. The Board heard that the Phase 1 Environmental Site Assessment
found no evidence of contamination on the site. Durham Works Department had no
7
PL140557
objection to the proposed amendments subject to the submission of an acceptable
traffic management plan, which has been done. Regional Health reviewed the
application and expressed no objection. Emergency and Fire Services had no objection
to the instruments.
[16] The Ganaraska Region Conservation Authority reviewed the application and the
Natural Heritage Evaluation and had no objections to the approval of the applications
and as an aside, as the lands are outside of the regulatory jurisdiction of the
Conservation Authority, no permits are even required from it for this event. As the
Board heard, Natural Heritage Evaluation recommendations will be implemented
through the conditions of Site Plan Approval, another means to guarantee a safe and
well -run and sustainable event. And, while the property is located on the Oak Ridges
Moraine, no impacts of consequence will be created and there are many planning
policies that provide protection to the area such that these planning instruments do not
offend those policies as the documentation establishes.
[17] Engineering Services also had no objections although it identified conditions to
be implemented through site plan approval and by means of the Special Event Permit to
minimize impact to residents on the adjacent and surrounding roads. A dust control
plan is also required as evidenced. Prominent signage has also been prepared.
Likewise, Building Division had no concerns; entrance permits will be required and as
the Board referenced previously, Republic's letter of May 12, 2014 represent clear intent
on the part of this party to produce, oversee and hold a well- supervised event.
[18] The Board heard no evidence that Mr. Walker, who lives approximately, 700
metres east of the subject property, will be unable to access his mailbox during the
festival. Whether having to produce identification for a peace officer or having to wear a
wristband to denote his local resident status in travelling along Concession 10, the
Board does not consider such measures for 96 hours to be egregious or to raise
legitimate planning concerns.
[19] The Minimum Distance Separation study and calculations raised no planning
issues for the Board and Mr. Walker presented no evidence to refute the findings of this
study or any other study. The materials are persuasive evidence of the planning merits
of the planning instruments,
[20] It is the Board's finding that both the Municipality and Republic have gone above
PL140557
and beyond what is reasonably expected to support these instruments. There is
persuasive and uncontroverted evidence of broad public and agency support for the re-
designation of the subject lands in support of the festival event.
[21] Not only does the Board find persuasive Mr. Allison's submission that this annual
event provides the Municipality with "tremendous economic development significance,"
the Board also sees a strong case for promotion of the public interest in holding this
entertainment event for local and broader area residents as well as the draw of a
significant out -of -town touristic and music -lover populations. Moreover, prominent arts
groups and municipal, academic and other groups are supportive of the event that these
instruments will facilitate. The instruments respond to the public interest on this point
and will also allow for the continual review and update of the Official Plan either through
site plan modifications or through the Special Event Permit process. The reduced term
of validity from 3 years to 2 years affords local residents with an opportunity to gauge
Republic's capacity to hold successful and non- impactful events as well as an
opportunity for Republic to show it can successfully stage this event in the manner it has
committed itself to in the documents. As Mr. DeMelo submitted, Republic is here for the
long term and it wants to work with the Municipality to offer a quality entertainment
event.
[22] The Board wishes to add that the event itself does not require planning approvals
to proceed as such music events are permitted. As the event will be held at the
Canadian Tire Motorsport Park, no zoning is required; zoning is necessary only to allow
for ancillary off -site parking. In the Board's determination, Republic's applications
address the transportation - related issues that arose during last year's event. With far
more planning in place and extensive anticipatory work having been completed, the
instruments represent an effective response to residents' concerns with the issues as
raised and it is clear that Republic and the Municipality have responded well to local
concerns.
[23] The Board prefers the only planning evidence presented at this hearing to the
anecdotal and rather disorganized references provided by the remaining Appellant.
Only the qualified planner referenced the in -force planning instruments and offered
planning rationales to support the adoption of these site - specific applications. Her
evidence and responses to Mr. Walker's concerns were unshaken in all respects and it
was the only persuasive evidence on which the Board could make its determination on
9 PL140557
the planning merits of these private applications.
Is] V9]4V
[24] The appeal against OPA 99 is dismissed. The Board approves OPA 99
(Attachment 1 to this Order), which amends the Municipality of Clarington Official Plan
by redesignating the subject lands from General Agriculture to Green Space. The
Board allows the appeal against the Temporary Use Zoning By -law Amendment to
Zoning By -law 2005 -109 (Attachment 2 to this Order) for the Oak Ridges Moraine in the
Municipality of Clarington to allow vehicle parking and ancillary uses associated with the
Boots and Hearts Music Festival in the following specified manner: by reducing the
validity of the event from 3 years to 2 years and by removing the "H" symbol. In all
other respects, the appeal against the Temporary Zoning By -law is dismissed.
"R. Rossi"
R. ROSSI
MEMBER
Ontario Municipal Board
A constituent tribunal of Environment and Land Tribunals Ontario
Website: www.elto.gov.on.ca Telephone: 416 -212 -6349 Toll Free: 1- 866 - 448 -2248
CORPORATION OF THE MUNICIPALITY OF CLARINGTON
BY -LAW NO. 2014-055
being a By -lain to adopt Amendment No. 99 to the Clarington Official Plan
WHEREAS Section 17 (22) of the Planning Act R.S.O. 1990, as amended, authorizes
the Municipality of Clarington to pass by -laws for the adoption or repeal of Official Plans
and Amendments thereto;
AND WHERE=AS the Council of the Corporation of the Municipality of Clarington deem
it advisable to amend the Clarington Official Plan to permit vehicle parking and ancillary
uses on the property with tax assessment roll no. 18- 17- 030 -070 -13500 located In Part
of Lot 23 -24, Concession 10, Former Township of Clarke;
NOW THEREFORE BE IT RESOLVED THAT, the Council of the Corporation of the
Municipality of Clarington enacts as follows:
I That Amendment No. 99 to the Clarington Official plan being the attached
Explanatory Text is hereby adopted.
This By -law shall come Into force and take effect on the date of the passing
hereof.
BY -LAW passed In open session this 264 day of May, 20-14.
I
Adrlan',F-astdf, Mayor
Aftne Gr' rea, De uty Clerk
AMENDMENT NO. 99
TO THE MUNICIPALITY OF CLARINGTON OFFICIAL PLAN
PURPOSE: To amend the Municipality of Clarington Official Plan to
permit parking, ticket booths and ancillary uses on parcel
030 - 070 - 13500, located in Part of Lots 23 -24, Concession
10, former Township of Clarke.
BASIS: The amendment is based on an application submitted by
Republic Live Inc. to permit parking, temporary ticket
processing booths and ancillary uses such as portable
washrooms, and bus loading and parking areas associated
with music festivals on Canadian Tire Motorsport Park lands.
ACTUAL
AMENDMENT: The Clarington Official Plan is hereby amended by:
i} Amending Map Al (Clarke), as indicated on Exhibit "A"
attached to this amendment by redesignating lands
from "General Agricultural Area" to "Green Space "; and
li }. Adding a new policy to Section 14.5 as follows;
14.5,8 Notwithstanding Section 14.5,2, permitted uses
on the property with tax assessment roll no, 18-17-030 -
070- 13500, also include parking, temporary ticket
processing booths and ancillary uses such as bus
loading and parking areas, accessory to nearby lands
that permit music festivals, subject to the following:
• Permanent buildings and/or structures related to the
temporary use are prohibited;
o Alteration to grades Is prohibited;
Natural heritage features will be appropriately
buffered;
• Site Plan approval will be obtained to address, such
matters as site layout; access; temporary fencing,
signage and lighting; and, monitoring of measures to
mitigate environmental impacts;
IMPLEMENTATION: The provisions set forth in the Municipality of Clarington
Official Plan, as amended, regarding the Implementation of
the Plan shall apply to this amendment,
INTERPRETATION: The provisions set forth in the Municipality of Clarington
Official Plan, as amended, regarding the interpretation of the
Plan shall apply to this amendment.
Exhibit "A", Amendment No. 99 To the Municipality of Clarington
Official Plan, Map Al, Laney Use, Clarke
CORPORATION OF THE MUNICIPALITY OF CLARINGTON
BY -LAW NO. 2014-
being a By -law to amend By -law 2005 -109, the Zoning By -law for the Oak Ridges
Moraine in the Municipality of Clarington
WHEREAS the Council of the Corporation of the Municipality of Clarington deems it advisable
to amend By -law 2005 -109, as amended, of the Corporation of the Municipality of Clarington
for ZBA 2014 -0016;
NOW THEREFORE BE IT RESOLVED THAT, the Council of the Corporation of the
Municipality of Clarington enacts as follows:
1. Section 15.0 "TEMPORARY ZONES" is hereby amended by adding the following:
°15.3 T -3 TEMPORARY ZONE THREE
a. Permitted Uses
Agriculture Uses
ii) Vehicle parking, portable washroom facilities, and temporary ticket
processing booths associated with a music festival permitted on Canadian
Tire Mosport Park parcels with tax assessment roll no. 18 -17 -010 -110 -1800,
18 -17- 010- 110 -1801, 18 -17- 010 -110 -1802 and 18 -17- 010 - 110 -1803.
b. Regulations
Yard setback to dripline of woodlot 30 metres
ii) Yard setback to west property line 20 metres
iii) Yard setback to adjacent residential lots 30 metres
iv) The lands may only be used for vehicle parking, portable washroom facilities,
and temporary ticket processing booths between July 251x' and August 151'
and for a maximum of 5 total and consecutive days.
2. Pursuant to the requirements of Section 39 of the Planning Act, 1990, as amended, the
vehicle parking use may be permitted for a period of two (2) years, ending on May 26,
2016.
3. Schedule "E° to By -law 2005 -109, as amended, is hereby further amended by changing
the zone designation from
"Agricultural (A) Zone' to "Temporary (T -3) .Zone ".
4. Schedule "A" attached hereto shall form part of this By -law.
6, This By -law shall come into effect on the date of the passing hereof, subject to the
provisions of Section 34 of the Planning Act.
BY -LAW approved by the Ontario Municipal Board on 2014.
CORPORATION OF THE MUNICIPALITY OF CLARINGTON
BY -LAW NO. 2014 -055
being a By -law to adopt Amendment No. 99 to the Clarington Official Plan
WHEREAS Section 17 (22) of the Planning Act R.S.O. 1990, as amended, authorizes
the Municipality of Clarington to pass by -laws for the adoption or repeal of Official Plans
and Amendments thereto;
AND WHEREAS the Council of the Corporation of the Municipality of Clarington deems
it advisable to amend the Clarington Official Plan to permit vehicle parking and ancillary
uses on the property with tax assessment roll no. 18 -17- 030 - 070 -13500 located in Part
of Lot 23 -24, Concession 10, Former Township of Clarke;
NOW THEREFORE BE IT RESOLVED THAT, the Council of the Corporation of the
Municipality of Clarington enacts as follows:
That Amendment No. 99 to the Clarington Official Plan being the attached
Explanatory Text is hereby adopted.
2. This By -law shall come into force and take effect on the date of the passing
hereof.
BY -LAW passed in open session this 26th day of May, 2014.
A P d
Adrian,Eos , Mayor
AMENDMENT NO. 99
TO THE MUNICIPALITY OF CLARINGTON OFFICIAL PLAN
PURPOSE: To amend the Municipality of Clarington Official Plan to
permit parking, ticket booths and ancillary uses on parcel
030 - 070 - 13500, located in Part of Lots 23 -24, Concession
10, former Township of Clarke.
BASIS: The amendment is based on an application submitted by
Republic Live Inc. to permit parking, temporary ticket
processing booths and ancillary uses such as portable
washrooms, and bus loading and parking areas associated
with music festivals on Canadian Tire Motorsport Park lands.
ACTUAL
AMENDMENT: The Clarington Official Plan is hereby amended by:
i) Amending Map Al (Clarke), as indicated on Exhibit "A"
attached to this amendment by redesignating lands
from "General Agricultural Area" to "Green Space "; and
ii) . Adding a new policy to Section 14.5 as follows:
"14.5.8 Notwithstanding Section 14.5.2, permitted uses
on the property with tax assessment roll no. 18- 17 -030-
070- 13500, also include parking, temporary ticket
processing booths and ancillary uses such as bus
loading and parking areas, accessory to nearby lands
that permit music festivals, subject to the following:
• Permanent buildings and /or structures related to the
temporary use are prohibited;
• Alteration to grades is prohibited;
• Natural heritage features will be appropriately
buffered;
• Site Plan approval will be obtained to address such
matters as site layout; access; temporary fencing,
signage and lighting; and, monitoring of measures to
mitigate environmental impacts;
IMPLEMENTATION: The provisions set forth in the Municipality of Clarington
Official Plan, as amended, regarding the implementation of
the Plan shall apply to this amendment.
INTERPRETATION: The provisions set forth in the Municipality of Clarington
Official Plan, as amended, regarding the interpretation of the
Plan shall apply to this amendment.
Exhibit "A ", Amendment No. 99 To the Municipality of Clarington
Official Plan, Map Al, Land Use, Clarke
3 1 32 31 1 30 29 1 28 27 1 26 25 1 24 23 1 22 21 20 19 1 18 17
N
, v -
Change from "General Agricultural
Area" to "Green Space"
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