December 5, 2024 Ms. Pooneh…

December 5, 2024

Ms. Pooneh Derakhshan
Municipal Services Office - Western Ontario
659 Exeter Road, Floor 2
London, ON N6E 1L3

Submitted via ERO website.

RE: APPROVAL TO AMEND A MUNICIPALITY’S OFFICIAL PLAN
CITY OF LONDON OPA 124

On behalf of my client please accept this correspondence with regards to the Ministry’s review of Official Plan Amendment No. 124 which was adopted by the City of London earlier this year. This letter is being submitted with regards to ERO posting 019-9332.

The purpose of OPA 124 and the corresponding amendments to the City’s Zoning By-Law was to “update policies on building heights, introduce new Transit Villages, and designate Strategic Growth and Major Shopping Areas to enhance housing and economic development.” Given that the OPA relates to Major Transit Station Areas I understand Ministerial approval of this amendment is required.

My client has conditionally purchased the property municipally known as 743 Richmond Street, London with the intention to develop the lands as a purpose built apartment building. The subject lands are located centrally in the City at the intersection of Richmond Street and Oxford Street, as shown below.

Figure 1: Site Location
The subject property has been designated ‘Rapid Transit Corridor’ since the enactment of the initial London Plan, recognizing the strategic location of the site along a potential future BRT corridor.

Figure 2: London Plan Place Types – Rapid Transit Corridor
As part of the heights review, City Planning Staff and SVN Architects who had been retained to lead the study, recommended the redesignation of the subject lands and broader area around the intersection as a ‘Transit Village’ given the contemplated potential future BRT stop at the intersection, as shown on Figure 3.

My client was supportive of this recommendation given that it correlated with the location of a planned future station stop and in recognition of the Transit Village corresponding to a major intersection within the City where additional density and building height is appropriate. Moreover the proposed Transit Village designation would provide for context appropriate infilling of a planned major transit station area at a scale/intensity supportive of the higher order transit service to be developed in this location.

Figure 3: Proposed Transit Villages – City of London
Notwithstanding the professional recommendations of staff and the retained planning / urban design consultant, at the September 10, 2024 City of London Planning Committee Meeting, a motion was made to remove the Transit Village place type from the subject lands and broader area. At its September 24, 2024 meeting, Council adopted the Official Plan amendment subject to these modifications.

As a result of these proposed changes, it is understood that the City will (subject to Ministerial approval) not apply the Transit Village place type to the subject lands and redesignate the lands and broader corridor as ‘Urban Corridor’. I view these modifications introduced at Council as significant, unfounded and contrary to the stated purpose of the project itself and professional staff recommendations, and likewise as contrary to the Provincial goals and policy framework aimed at protecting PTMSA. Beyond that, despite the significant impact of these modifications, no addition consultation was held by the City prior to this last-minute change and deviation from the recommendations of the City’s own professional staff and retained consultants who are industry-recognized experts in this field.

My client maintains their support for the proposed application of the Transit Village place type and the corresponding application of the Transit Station Area 3 (TSA 3) zone, and requests ministerial consideration to apply these planning controls as recommended by professional staff of the City of London and their retained consulting team.
Sincerely,

David Galbraith MCIP RPP
President – Up Consulting Ltd.