To Whom It May Concern:…

To Whom It May Concern:

Thank you for the opportunity to provide feedback on ERO posting 026-0312. Please see attached an electronic submission from the City of Burlington. Below are the key points extracted from the submission, c/o of City's Public Works Department.

While framed as administrative streamlining to support housing delivery, these changes represent a profound shift in city building responsibility away from municipalities. If implemented as proposed, they will have generational impacts, permanently negatively reshaping urban landscapes and eroding the public realm. Cities built without real, functional, publicly owned parkland do not evolve into complete communities. It will come at the irreversible cost of fewer real parks, diminished public space, heightened municipal liabilities and cities that are less healthy, less resilient, and less livable for generations to come.

Detailed technical comments from the City of Burlington are provided in Appendix 1.

Burlington is planning for significant intensification within three Major Transit Station Areas (MTSAs) along the GO Transit corridor. These areas are expected to accommodate sustained high density growth over decades. Their long term success depends on the proactive delivery of high quality, unencumbered, publicly owned parkland. The proposed framework severely compromises this outcome. Allowing developer identified parkland, encumbered lands, and POPS to replace traditional parkland dedication will result in fragmented, constrained, and often inaccessible spaces that do not function as real parks. These spaces lack the flexibility to support recreation, urban forestry, climate adaptation, cultural use or large scale community gathering. Over time, this approach effectively sterilizes the urban landscape, producing dense built form without the green infrastructure needed to sustain it and make it livable.

Moreover, POPS and encumbered lands shift long term costs and risks onto municipalities. Cities remain responsible for ensuring public access, resolving disputes, enforcing agreements, and managing liability (often with limited control and unclear authority). This results in increased cost and enforcement efforts.

In intensifying urban areas where land values are high and development pressures are extreme, the City’s ability to secure meaningful parkland is already constrained. This proposal removes one of the last effective tools municipalities have to ensure equitable access to open space. The result will be generations of residents living in highly urbanized environments with insufficient green space, degraded public realm, increased heat and health impacts, and declining overall quality of life.
These impacts are not theoretical. Once land is built out without securing real parkland, the opportunity is lost permanently. Retrofitting parks decades later is exponentially more expensive, disruptive and often impossible.

The City of Burlington strongly urges the Province to reconsider these proposed changes and restore municipal authority to require functional, publicly owned and unencumbered parkland as a non negotiable foundation of intensification and growth. Rather than mandating developer identified parkland, the Province should enable municipalities and developers to work collaboratively to achieve outcomes that balance housing delivery with the long term health, resilience and livability of Ontario’s cities both for current residents and future generations alike.

Given the short period for consultation, the attached comments have not been approved by City Council. This submission will be shared through an upcoming Council Information Package. Should Council determine any additional comments or refinements are required, the Ministry will be advised at the earliest opportunity.

In the interim, we look forward to continued collaboration on Bill 98, and please feel free to contact us should there be any follow-up questions or information required.

Regards,

City of Burlington
Public Works Department
Parks, Engineering