This submission represents…

This submission represents the City of Burlington’s comments in response the proposed Land Needs Assessment Methodology for A Place to Grow: Growth Plan for the Greater Golden Horseshoe (ERO – 019 – 1679).
The submission includes a high-level discussion of key comments and a detailed comment table is provided in Appendix A: Detailed Comments.

City of Burlington Comments:

• The City of Burlington generally supports the simplified Land Needs Assessment (LNA) methodology.

As noted in the joint Halton Area Planning Partnership (HAPP) submission, the City of Burlington reiterates earlier comments to the Province with respect to the introduction of “market demand” to the PPS, 2020, the 2019 Growth Plan, and now the proposed LNA methodology. It is critical to emphasize that “market demand” is only one consideration amongst many considerations such as protecting natural hazards and natural heritage with respect to implementing the Growth Plan, and in particular, planning for settlement area expansions.

Further, the City of Burlington notes that the proposed new Land Needs Assessment methodology has been provided for review with high level information, which makes it difficult for municipalities and stakeholders to provide detailed comments. Some concepts have been introduced without clarification on their interpretation such as “market contingencies”. The City requires more information from the Province in order to better understand the implications of the proposed Land Needs Assessment methodology.

The City requests that the Province provide more funding as well as tools to support municipalities in their ability to plan for and provide public infrastructure such as schools, community centres, libraries, etc. over the long term to meet complete communities objectives to the 2051 planning horizon.

• The City of Burlington provides further comments on the Components of the LNA methodology related to the incorporation of forecasting for cemetery land needs. Please see Appendix A: Detailed Comments for further details.

• The City of Burlington provides further comments on the Population Forecasts of the LNA methodology. The City of Burlington would prefer the term “housing market area” be replaced with “Regional Market Area” to align with the PPS, 2020.

Thank you for providing the opportunity for the City of Burlington to provide comments on these proposed changes to the Land Needs Assessment methodology.