Middlesex County Official…

Middlesex County Official Plan Amendment 4 includes flawed policies - especially growth forecasts that understate the amount of growth that can be anticipated to the planning horizon. An alternative Appendix B is included with the attached submissions to correct these flaws. The adopted amendment makes flawed assumptions regarding the location of future growth within the Regional Market area, and the mix of housing units that will be required to satisfy the needs of current and future residents as required by the Provincial Planning Statement policies. It also allocates that growth inappropriately within the Regional Market Area. The result of the adopted policies will be to produce a further shortage of housing to meet market needs in the future, deepening the shortage of housing locally and across the Province, and further driving up its cost due to a lack of supply. These deficiencies will be corrected through a modification adding the alternative forecasts included in the attached submissions.

The modifications requested also include the use of a 30 year planning horizon to accommodate growth consistent with the Provincial Planning Statement. This will ensure that an adequate supply of housing is provided in the County where some local municipalities are aggressively pursuing approaches and tactics to discourage growth.

In addition, modifications are sought to make the housing policies in the Official Plan realistic and achievable. As adopted, they are not viable - and paradoxically, will actually end up suppressing both the overall housing supply and that of affordable housing specifically, through the application of unworkable policies. The attached submissions provide recommended modifications that will correct the flawed policies.

Another modification is required to introduce more flexibility to servicing options. The adopted amendment effectively prohibits innovative servicing solutions - contrary to the policies in the Provincial Planning Statement. The adopted policies will further frustrate the ability to deliver new housing. The modifications recommended in the attached submissions ensure alignment with Provincial Policy, and do not unduly restrict innovative servicing solutions where appropriate.