City of Burlington staff…

City of Burlington staff does not support the creation of an open-for-business planning tool as proposed, for the following reasons:

a. The tool undermines the city’s goals to achieve coordinated and sustainable planning, as delivered through the application of the Provincial Policy Statement, Growth Plan, and Greenbelt Plan. Allowing major employment uses in areas not intended for such uses will fragment Agricultural Systems and Natural Heritage Systems and could lead to a creep of land use pressures to introduce residential, ancillary and other supportive uses to support the major employment use;

b. The tool undermines provincial investments in infrastructure, such as the transit projects identified in the Metrolinx Regional Transportation Plan. The tool could also undermine Regional investments in infrastructure. Major employment uses should be directed to locate within existing urban areas that are supported by transit and other infrastructure investments, such as near Major Transit Station Areas. Locating major employment uses within the Greenbelt Plan
area, and other areas not intended for or compatible with such uses will result in the inefficient use of existing infrastructure and contribute further to traffic congestion;

c. Businesses want certainty and clarity regarding land use permissions. The tool introduces uncertainty in the planning framework that could increase land speculation and contribute to affordability challenges;

d. The tool contradicts the climate change goals articulated in the Province’s draft Environmental Plan, by potentially increasing the greenhouse gas emissions associated with sprawl, and the potential for long term increased costs in environmental remediation and the impacts to water resources and drinking water; and

e. The open for business planning tool will create a competition amongst municipalities that rewards those that will accept the weakest planning, environmental and health and safety regulations. The province should ensure that all municipalities are raising the bar to achieve quality and sustainable developments, to ensure health and safety and to reduce long term cost impacts that would result to address environmental issues and to maintain unsustainable investments in infrastructure.

f. Eliminating the requirement for notification and consultation with the community, other agencies or municipalities may speed up the approval process, but will not necessarily result in good decisions or faster completion of a development. Residents want and ought to be involved in planning decisions that will impact the communities they live in. Local planning decisions that will impact the service delivery of others cannot be made in isolation. Not including Halton Region in Burlington planning decisions where new regional services are required will not result in jobs coming to Burlington faster, in fact, bypassing the Region could result in delays and additional costs.

g. Allowing major trip generators (such as employment developments), to by-pass council approved transportation policies and directions will mean that municipalities will be responsible for meeting conditions that developers would usually be responsible for. For example, if a developer asks for relief in the amount of parking which they are required to provide, and this relief is granted through this proposed policy, only to realize once the project is constructed and operating that there are insufficient parking spaces. The overflow parking becomes an issue the municipality must address.

Instead of an Open for Business Bylaw, please consider the following tools:
a. Tools to incent the creation of innovation districts located near Major Transit Station Areas and other areas that are serviced by transit. Innovation Districts are a type of business and or industrial district to attract and promote clusters of private and public-sector firms and organizations engaged in the development of new products, materials, services and knowledge. An Innovation District at its core must be driven by existing assets and an economic development strategy. A Provincial program to support and build upon existing businesses and organizations within a municipality would be a more prudent approach to using existing specialization and resources. Such a program could include support for creation of economic development strategies for local Innovation Districts;

b. The tools proposed in the open-for-business planning tool do not address our barriers to economic development. An example of a barrier to the development and redevelopment of employment lands is the timely and coordinated issuance of MTO permits. Approximately 80% of the City’s employment lands are within the MTO development permit area. Addressing this barrier would assist in the timely development of serviced and transit oriented employment lands; and

c. The province should consider the use of the MZO tool as an alternative. This tool already exists at a provincial scale. The Planning Act could be amended to expressly identify the attraction of a major employment and economic growth opportunity as a matter of provincial interest. Consideration of these types of uses should be done at a provincial scale to ensure coordinated planning and use of infrastructure.

The following items require more clarity to understand how the tool will be implemented:
a. What is the evidence/data that demonstrates that these sections of the Planning Act are the barriers to locating major employment uses?
b. Please define major employment and economic growth opportunities.
c. What are the prescribed criteria referenced in Section 34.1(2) of the Planning Act?
d. How does the use of this tool apply to Upper Tier vs. Lower Tier municipalities? Are there criteria for determining what is of Regional interest or local interest?