November 28, 2018 Via Email…

ERO number

013-3485

Comment ID

26760

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

November 28, 2018 Via Email and Courier Ministry of Municipal Affairs and Housing Municipal Services Division Municipal Office - Central Ontario 777 Bay Street, Floor 13 Toronto ON M5G 2E5 Dear Sirs/Mesdames: Re:Proposed City of Toronto Official Plan Amendment No. 406 (By-law 1111-2018) (the “Proposed Amendment”) EBR Registry Number: 013-3485 Ministry Reference Number: 20-OP-178646 We are counsel to two major downtown institutions - St. Michael’ s Hospital and Sinai Health System which have significant land interests within the area affected by the Proposed Amendment and have participated actively in the public consultation process that preceded the Proposed Amendment’s adoption by City Council. Both of these institutions previously provided written submissions in respect of their concerns to the City and met with Planning Staff to discuss the same in detail. Our clients acknowledge and are appreciative of the City’s overall receptiveness to date, to considering policy modifications required to ensure their respective institutional mandates can continue to be pursued within the Downtown. It is recognized that a number of the policies within the Proposed Amendment, as adopted, have incorporated changes based on comments provided by our clients to the City during the consultation process. However, a number of our clients’ key concerns, as described in the correspondence dated May 22, 2018 submitted on these institutions’ behalf by their planning consultant, Urban Strategies Inc., attached hereto, remain unaddressed. In the respectful view of our clients, in its current form, the Proposed Amendment, as adopted, is inappropriate from a land use planning policy perspective due to these and other outstanding concerns and requires modifications to address these issues appropriately, prior to approval, in whatever forum this may ultimately occur. In the absence of appropriate modifications, the Proposed Amendment in our clients’ view will discourage the desirable intensification of institutional uses, hinder the provision of key healthcare and educational public service facilities to meet current and projected needs and discourage economical and cost-effective use of existing public service facilities. It consequently does not represent good land use planning, is inconsistent with the Provincial Policy Statement and does not conform to the Growth Plan for the Greater Golden Horseshoe 2017. In our clients’ respectful submission, a further consultation program with institutional stakeholders in the downtown which includes our clients, St. Michael’s Hospital and Sinai Health System, should precede any approval of the Proposed Amendment to provide the opportunity to address their concerns. As an admittedly inferior alternative, we would suggest that the Ministry could refrain from rendering a decision to permit interested parties to appeal the non-decision to the Local Planning Appeal Tribunal where the matter could be mediated or, failing that, litigated. Yours truly, McCarthy Tétrault LLP Cynthia A. MacDougall NOTE: A hard copy of the correspondence referred to in this letter has been sent via courier to the Ministry of Municipal Affairs and Housing as of the date of this posting.