September 30th, 2022…

September 30th, 2022

Ministry of Municipal Affairs and Housing
777 Bay Street, 17th floor Toronto, Ontario
M7A 2J3

RE: ERO File No: 019-5684
Regional Official Plan Review No. 49
Amendments to the Regional Plan Official Plan for the Halton Planning Area Regional Municipality of Halton

Corbett Land Strategies (CLS) has been retained by Romano-Franco Georgetown Inc. with respect to the subject lands located at 15392 Tenth Side Road, 9258 10th Line, and 14354 Fifth Side Road, located within Halton Hills. Please refer to Appendix A for a Location Map. This letter addresses policy and mapping changes within ROPA 49 that pertain to these subject properties.

This letter has been submitted in response to Halton Region’s Regional Official Plan Review Amendment No. 49 (ROPA 49). The amendment contains new policies to guide growth and development within the Region to the year 2041 and then establishes a framework to plan for growth to the year 2051.

PART 1: SUMMARY OF COMMENTS/ MODIFICATION REQUESTS:

CLS has conducted a review of the draft ROPA 49 and determined the following high- level comments and recommendations. Please refer to Appendix D for a detailed policy analysis of the draft ROPA 49:

• Although the Modified Growth Concept (MGC) (March 2022) is supported by the Land Needs Assessment, the Region is proposing to implement a ‘No Urban Boundary Expansion’ growth management strategy despite the identification of New Community Areas proposed to support Halton Hills and Milton.

• This decision to endorse this strategy questions the Region’s ability to provide a market-based approach as approximately 75 – 80% amount of housing will be accommodated within the Region’s urban areas and a total unit mix that will support approximately 50% of apartment buildings.

• The Region’s ability to provide for such intensification is based on a multitude of factors such as timing of updated municipal Zoning By-laws to permit uses that support intensification, City’s/ Town’s servicing capacity and infrastructure equipped to support high to mid-rise development. The timing involved in providing such intensification will not improve the current housing supply issue.

• With the removal of ground-oriented development options up to the identified time frame, the Region must ensure the existing approved Designated Greenfield Areas (DGA) can meet the current market demand.

• Halton Hills Expansion Area – based on the comments provided by Halton Hills through this review process (May 2022), the approved planned growth to 2031 set out within the Halton Hills Official Plan is now being extended over a planning horizon to 2041. There is concern if Halton Hills will have enough existing DGA to provide for the anticipated population growth and rising community development needs. In addition, through the Preferred Growth Concept (PGC) provided by the Region in February 2022, the Integrated Growth Management Strategy indicated that the urban land supply across the Region would last a little after 2031.

• Extending development from 2031 to 2041 should provide additional time for the Region to provide adequate servicing, however, the Town of Halton Hills has pointed out that Secondary Plans such as the Vision Georgetown Secondary Plan are under appeal. This could affect the number of planned units anticipated for the 2021 – 2031 growth horizon as less residential units will not be built or delayed.

• In addition to implementing the New Community Area as per the PGC, Halton Hills should receive an additional phased new DGA area. It was intended that Halton Hills was to receive 410 hectares and Milton the remaining 710 hectares. As a large amount of growth has occurred within Milton within the last decade, Halton Hills should receive the full 1,120 hectares. Through our analysis, Halton Hills would receive the planned 410 hectares but then an additional expansion area of approximately 750 hectares. This Designated Greenfield Area would be planned for planning horizon 2031 to 2051. This option can be described as Option 1 (Appendix B) for expansion options in Halton Hills.

• Through further analysis, we are proposing an Option 2 (Appendix C) for expansion in Halton Hills. This option will include a New Community Area as well but works with the anticipated future employment areas and the new corridor of ROPA 49 to promote new growth in Halton Hills. This option will provide an expansion area that will coordinate with these precincts and recommends a growth pattern that makes sense from a servicing capacity. It is recommended that approximately 422 hectares of New Community Area be included and approximately 867 hectares of Designated Greenfield Area to be included for the 2031 to 2051 planning horizon.

PART II: BACKGROUND AND CONTEXT

ROPA 49 (June 2022)

CLS understands that ROPA 49 is considered the 2nd Amendment considered by Regional Council as part of the Regional Official Plan Review (ROPR), which builds on the urban structure policies of ROPA 48. ROPA 49 is to provide a framework for accommodating growth in Halton to the 2051 planning horizon. The purpose of this Amendment is to implement the results of the Region’s Integrated Growth Management Strategy (IGMS). This strategy considers how to accommodate growth in Halton to the year 2051 as part of the municipal comprehensive review process.

Within the IGMS process, a Draft Preferred Growth Concept (DPGC) was provided for review in November 2021. Based on this draft, a Preferred Growth Concept (PGC) was provided to Council in February 2022. Upon review, Council provided direction on February 16th, 2022, to provide a Modified Preferred Growth Concept (MPGC) motion. The MPGC builds on the IGMS by continuing to implement an approach that promotes a significant shift to more compact, mixed-use communities. It directs growth in Halton to be planned up to 2041 (within the existing Regional Urban Boundary) and to the years 2041 – 2051, which will require a subsequent amendment based on more detailed growth policies and assessment.

Modified Growth Concept (March 2022)

In March 2022, the Region released the Land Needs Assessment to support the implementation of the Modified Preferred Growth Concept. The report provided confirmation to Regional staff that there is sufficient land within the Region’s existing urban area, which can accommodate the projected population and employment growth to the year 2041. However, post 2041, additional land outside of the current urban boundary would be required to accommodate the growth projections from 2041 – 2051.

Preferred Growth Concept (February 2022)

This PGC provided the Region’s planning strategy to achieve growth targets for housing, population and employment to the year 2031 – 2051. Within the Preferred Growth Concept released in February 2022, a “New Community Area” was proposed to the south of Halton Hills and within other strategic areas within the Region. Within the latest Modified Preferred Growth Concept and as per Council’s direction, this area is no longer included within the latest mapping changes and policies within ROPA 49 mapping.

The concept growth plan does support intensification like the Modified Growth Concept, however it set out New Community and Employment Area lands required to accommodate growth to 2051. More specifically, it established a Regional Urban Structure of Strategic Growth Areas for Designated Greenfield Areas along with Major Transit Station Areas, Regional Nodes and Corridors, and Urban Growth Centres.

Within the figure below, the New Community Area is shown located adjacently from Georgetown and is identified in orange, which is located just outside of the Halton Hills existing DGA. The existing DGA area was approved within Halton Region’s ROPA 38 settlement area.

Figure 1 – Preferred Growth Concept (Feb 2022) – New Community Area

The New Community Areas were designed to contain more uses than residential and intended to include commercial, institutional and community supportive uses. This area was intended to provide a market-based supply of ground-oriented housing as per Provincial policy. In total, only 14% of housing unit growth allocation was projected to be provided within the PGC for the Region.

The New Community Areas in total were to provide 1,120 gross hectares of urban expansion for residential and related community uses. The areas proposed for urban expansion within the Halton Hills area is approximately 410 hectares and is anticipated to accommodate 13% of population growth. The new DGA would provide 17% of ground-oriented housing. This planned area was anticipated to dedicate approximately 50 hectares for town-wide community uses.

Halton Hills Expansion Area Justification

The Region’s goal for intensification for new housing units in the Built-Up Area between 2022 – 2041 is to achieve 53,300 units with 3,600 within Halton Hills. This projection would meet the Region-wide target that 45% of new housing units annually be within the Built-Up Area. Within the Designated Greenfield Area for Halton Hills, the DGA Density Target is 53 (by 2041). As the “New Community Area” is no longer planned, Map 5 – Regional Phasing illustrates the Urban Area with Regional Phasing between 2021 and 2041.

Based on the Town of Halton Hills intensification and planned new growth, the Town was approved to provide a minimum intensification target of 5,100 units to the year 2031 timeframe. Based on comments received from the Town during the review process in May 2022, the Town’s updated Intensification Opportunities Study proposed that a range of 5,177 – 7,575 units is possible. ROPA 49 set a minimum intensification target of 3,600 units inside the built-up area to the 2041 planning horizon, where regional phasing suggests approximately 3,730 units. Based on these numbers and the uncertainty surrounding these planned unit forecasts, additional intensification opportunities for the Town may be needed. Thus, flexibility for the Town is needed to accommodate any changes in population estimates versus the number of units required as well accommodate changes in the market demand.

PART III: PROPOSED EXPANSION AND MAPPING CHANGES

To continue to support growth and development within Halton Hills as per the recommended Preferred Growth Concept in February 2022, it is proposed that additional phased urban boundary or new DGA lands be dedicated within Halton Hills. Based on the amount of existing DGA lands dedicated to Milton within the last ROPR, Halton Hills should absorb the next phased New Community Area/ DGA.

For example, 1,120 hectares of land split between Halton Hills and Milton was previously recommended to be provided as a New Community Area. To continue this growth concept strategy, Halton Hills should also receive the amount of land dedicated to Milton instead. Based on the proposed expansion area in Appendix B (Option 1), a phased Regional approach of land with approximately 1,160 hectares of land should be included, allowing for growth to be more evenly distributed throughout the Region.

In addition, it is proposed that the planned New Community Area would be phased for 2021- 2041 as a means to provide flexibility for Halton Hills in achieving the required community development and market-demand for housing based on an increasing population. With having this area converted to urban at this time, would eliminate the need for another amendment to take place in years from now to discuss the next phased approached. Also, the additional expansion lands (~750 ha DGA) would be phased for the 2031 – 2051 planning horizon. The map in Appendix B shows this area as a natural progression of growth and can be considered Option 1.

15392 Tenth Side Road

In Appendix B, this property is located at the corner of Tenth Side Road and Ninth Line. As these lands are located adjacently to an existing urban area, it makes sense for the New Community expansion area to naturally progress to include the subject lands and provide a total approximate area of 410 hectares. This is in keeping with the Preferred Growth Concept that was presented to Council in February 2022. The Regional Phasing for this area would be for 2021 – 2041, adding to Map 5 – Regional Phasing. Also, the need for a proposed planning horizon of 2022 – 2031 should be included. As the proposed New Community Area follows the planned pattern and timing of the PGC, the Region needs to dedicate more growth to the 2031 timeframe for flexibility purposes.

This growth option (Option 1) maintains a previously recommended expansion area within Halton Hills. The Designated Greenfield Area of 750 hectares will continue to connect Halton Hills to Oakville and allow for the Region for more future employment areas if more employment lands are needed in the future. This option therefore spreads growth more evenly through the Region and can help support the future servicing connections for Halton Hills.

9258 Tenth Line and 14354 Fifth Side Road

These lands are located outside of any currently planned DGA. However, when reviewing the existing DGA and growth that has occurred in Milton, the proposed and planned growth is unevenly distributed. As new employment areas are proposed, like the new Employment Area abutting Highway 401 between Eighth Line and Winston Churchill Blvd, growth will naturally progress upwards towards Halton Hills.

Through a more fulsome review in context with provincial policies and priorities, a second option has been prepared for consideration (please refer to Appendix C - Option 2). This option includes a New Community Area where the subject lands located at 15392 Tenth Side Rd and 9258 Tenth Line would be encompassed. This New Community Area of approximately 422 hectares is located adjacently to a future Strategic Employment Area. The DGA area of approximately 867 hectares connects Halton Hills to the existing Employment Area and future Strategic Employment Area as well as the future planned corridor. This new DGA is proposed for the 2031 to 2051 planning horizon. In total, Halton Hills would receive roughly 1,289 hectares to dedicate towards future growth that will support the community and surrounding employment precincts. From a servicing and planning perspective, this option helps to connect and implement more provincial priorities. Therefore, option 2 (Appendix C) is proposed for consideration.

To reflect the requested expansion areas (Option 1 and Option 2), mapping changes should occur to the following maps. On each map, the New Community Area and additional DGA area should be shown as Urban Area. Illustrations of these mapping changes are provided in Appendix D.

Map 1: Regional Structure (includes Maps 1B – 1H)
Map 3: Functional Plan of Major Transportation Facilities
Map 4: Right-of-Way Requirements of Arterial Roads
Map 5: Regional Phasing

PART IV: POLICY ANALYSIS

In support of the above section, please see Appendix D for a detailed breakdown of the Region’s proposed policies and CLS responses/ recommendations.

CONCLUSION

CLS is of the opinion that focusing on densification within the Region is an appropriate strategy for the Region to take, however, the Land Needs Assessment Methodology and the Provincial Policy Statement require the consideration of a market-based supply for housing. The proposed New Community Area with the planning horizon of 2021 – 2041 is also appropriate as it will allow the Town of Halton Hills the flexibility needed to resolve any supply issues in the future. Moreover, a New Community Area and supporting DGA areas that are proposed can help provide the much-needed community-based development that in turn achieves the development of complete communities. The additional new DGA areas proposed with a planning horizon of 2031 to 2051 is to allow the Town and Region to plan accordingly in anticipation of an increased population and natural expansion within the urban area fabric.

It is the hope of our client that the above comments will assist in the province’s review of ROPA 49. Should there be any questions or a need for further information, feel free to reach out to the undersigned below.

Sincerely,

John Corbett

John B. Corbett, MCIP, RPP
President
Corbett Land Strategies Inc.
5045 South Service Rd, Suite 301 Burlington ON L7L 5Y7
john@corbettlandstrategies.ca
416-806-5164

The full pdf submission letter has been submitted to ERO contact Jennifer Le.