Thank you for the…

Thank you for the opportunity to provide feedback on the proposed narrowed study area for a future electricity infrastructure corridor in the Greater Toronto Area, as well as input on the guiding principles you will consider in conducting the study. Planning and Economic Development staff have worked in collaboration to prepare comments outlined in the attached memorandum as the ultimate location of the electricity infrastructure corridor has potentially significant land use planning and economic development implications.

Town of Halton Hills Comments and Concerns with the NWGTA/IESO Transmission Corridor Study:

• The proposal highlights that corridor routing should minimize impacts on existing municipal plans in the study area, including impacts on existing built up areas, cultural heritage, planned developments and airports. The Town of Halton Hills Premier Gateway Phase 2A and western portion of Phase 1A lands are located in the area that differs from the GTA West Focused Analysis Area (FAA). These lands are strategically located along the Hwy 401/ Hwy 407 Corridor (south of Steeles Avenue, east of Eighth Line and west of Winston Churchill Boulevard). The lands have been identified by the Ministry of Municipal Affairs and Housing (MMAH) as a Provincially Significant Employment Zone (PSEZ), which emphasizes their key role in helping drive job growth and prosperity across the region. It is also worth noting that there is existing development already located in the area west of Eighth Line and south of Steeles Avenue (i.e., Toronto Premium Outlets). While the Town understands the importance of planning for a transmission corridor of this nature, there is a significant concern that the additional areas contemplated for connection infrastructure that are outside the GTA West FAA, will sterilize the development potential of these lands. Any further delays in finalizing this and other provincial studies impacting lands in the Premier Gateway will have substantially negative impacts on the Town’s economy and finances, with associated negative impacts on the broader region due to delays in economic development.

To allow for development, the Town requests that the Province identify alternative areas for infrastructure connection and explore other approaches/technologies such as the burial of connection infrastructure.

• The proposal indicates that MENDM will align the timing of this study with milestones related to the Ministry of Transportation’s Environmental Assessment. There is significant concern that there are no set timelines for completion of the NWGTA/IESO Transmission Corridor Study. The indefinite nature of study completion introduces significant uncertainty and risks, thereby undermining the ability of investments to move forward in the area, including major active files. This puts non-residential investment and associated jobs at risk at a time when they are urgently needed, both locally and regionally.

The Town respectfully requests that the appropriate planning, scheduling work and coordination between GTA West and NWGTA/IESO Transmission Corridor teams take place to establish more definite timelines for the completion of the study. Complex projects of this nature always incorporate a tentative date of completion so it is unusual for a project of this magnitude to not have an end in sight.

• The uncertainty related to the timing of study completion will potentially result in a number of missed major economic development opportunities for the Town. For example, a major development and job creation proposal by Conestoga Cold Storage is currently impeded by the development freeze on certain lands within the additional lands identified as necessary for NWGTA/IESO connection infrastructure. This situation is described in more detail within the attached letter sent from the Mayor of Halton Hills, Rick Bonnette, to Minister Steve Clark (MMAH) on March 25, 2020 (see Appendix 1).

• In addition, the Town is in the process of initiating the Premier Gateway Phase 2B Employment Area Integrated Planning Project to proceed with the development of approximately 257 hectares of employment lands located north of Steeles Avenue, between Eighth Line and Winston Churchill Boulevard. The Project is expected to be completed in approximately three years. Considering that these lands are designated for employment uses in the Official Plan and have been identified as a Provincially Significantly Employment Zone by the Ministry of Municipal Affairs and Housing (MMAH), it is the intent of the Town to ensure that the lands are ready to be developed as soon as the required planning studies are completed. The uncertain timing of the NWGTA Transmission Corridor Study means that a large portion of the Premier Gateway Phase 2B Secondary Plan could be under corridor protection policies for a long period of time. This can cause a delay in developing the lands in a timely fashion and leveraging the economic potential of the area.

Economic development implications and risks being caused by the Study need to be carefully considered and the study process refined accordingly to minimize these risks.

We thank the Ministry for the opportunity to comment and look forward to continuing to participate in this study and other related Provincial initiatives.

If you have any additional questions, please do not hesitate to contact me.