This submission represents…

This submission represents the City of Burlington’s comments in response the proposed Amendment #1 to the Growth Plan for the Greater Golden Horseshoe, 2019 (ERO – 019 – 1680).

The submission includes a high-level discussion of key comments and detailed comment tables are arranged by theme in Appendix A: Detailed Comments.

1. It is proposed that policy 2.2.5.10 c) be updated to allow conversion of employment areas to non-employment uses within a provincially significant employment zones that is located within an MTSA, outside of a municipal comprehensive review.

City of Burlington Comments:

• Staff have concerns about the implementation of this policy.

In general, the City supports the intent of this policy change, but notes, this proposed policy presents challenges related to a municipality’s ability to plan for its MTSAs in a timely manner. This proposed policy is only effective if and when the upper-tier municipality has delineated the MTSAs.

Further direction and clarity are needed regarding the appropriateness of employment conversion within MTSAs where a municipality hasn’t identified an opportunity for conversion.

While this proposed policy has the potential to create more housing more quickly in MTSAs, it does not provide any further clarity around prioritizing employment uses or mixed-use development within MTSAs to ensure that complete communities can be realized in these areas.

• There are remaining concerns about meeting the objectives of the MTSA and PSEZ and the mechanisms to modify the PSEZ mapping.

The Province should ensure that property owners and other stakeholders such as municipalities understand the role and the opportunities presented by the PSEZ. The City expects more guidance from the Province on the PSEZ mapping and may request further modifications as the PSEZ objectives and policy framework become clearer. As noted in previous submissions, the City will respond and adapt to new information.

The City needs more tools to ensure the development of complete communities in MTSAs, such as policy direction that requires the retention of a minimum gross floor area and/or minimum employment density for employment uses after an employment conversion has occurred.

2. It is proposed that policy 4.2.8.2 a) be revised to delete “habitat of endangered species and threatened species” from the list of key natural heritage features and key hydrologic features that no new mineral aggregate operation, new wayside pits and any ancillary or accessory use will be permitted.

City of Burlington Comments:
• Staff have concerns with the revised policy. There is insufficient rationale for the removal of this clause.

• Staff do not support the revised policy.

3. It is proposed to revise the planning horizon from 2041 to 2051.

City of Burlington Comments:

• Staff have several comments with regards to the proposed planning horizon to 2051, including timing of conformity exercises, impacts on local planning and a need for progressive targets:

Timing of Conformity Exercises:
With regards to the timing of conformity exercises, it should be recognized that many municipalities are currently undertaking their 2041 conformity exercises and working towards the July 2022 conformity deadline.

Changing the planning horizon in the midst of these exercises, some of which are well underway, has the potential to cause delays to the project timelines. As such, there should be some flexibility or options given to municipalities with respect to the conformity deadlines.

Impact on Local Planning:
Continuous changes are challenging for municipalities to develop and implement a local planning vision. This allows developers to speculate on how and where growth should be allocated throughout a Region and City and proceed on that basis. The resulting development pressures without local planning being completed puts strain on local infrastructure, services, resources, etc.

Need for Progressive Targets:
The City of Burlington notes that it is not progressive to have the same percentage target of development in the built-up areas over a 31 year period. Progressive target increases to the percentage of units required within the built-up area and progressive density targets for Designated Greenfield Areas should be proposed alongside this modification. In order to manage sprawl, the additional growth post-2041 should have a higher target for development in the built-up areas.

• The City of Burlington proposes a policy modification to 2.2.2.1 a) and a new policy to 2.2.2.

o Need for Progressive Targets – Policy Modification:

 2.2.2.1 a) By the time the next municipal comprehensive review is approved and in effect, and for each year thereafter, the applicable minimum intensification target to 2041 is as follows:
a) A minimum of 50 per cent of all residential development occurring annually within each of the Cities of Barrie, Brantford, Guelph, Hamilton, Orillia and Peterborough and the Regions of Durham, Halton, Niagara, Peel, Waterloo and York will be within the delineated built-up area;

o Need for Progressive Targets - New Recommended Policy to 2.2.2:

 The applicable minimum intensification target from 2041 to 2051 for all Upper-tier and Single-tier municipalities is a minimum of 60% of all residential development occurring annually will be within the delineated built-up area.

4. It is proposed to update growth forecast numbers for the Greater Golden Horseshoe.

City of Burlington Comments:

• The City of Burlington is concerned with the length of the time frame.

• With each upper- and single-tier municipality able to establish their own growth targets and the forecasts being cast as minimums, there could be decisions made in the coming years that set out extensive urban boundary expansions.

• Additional guidance is required to ensure that this policy would be used appropriately and would require appropriate planning arguments for increased growth targets beyond the minimums established in A Place to Grow.

5. It is proposed to include additional policy language allows for higher population and employment forecasts than contained in Schedule 3 if established by the applicable upper- or single-tier municipality through a municipal comprehensive review

City of Burlington Comments:

• This approach is consistent with the approach to targets in the Growth Plan which are minimums. However, there should be a requirement for those municipalities that establish higher forecasts on Schedule 3: Distribution of Population and Employment for the Greater Golden Horseshoe to 2041 that they are also required to exceed the minimum Delineated Built-Up Area and Designated Greenfield Area targets in the Growth Plan.

• The City recommends that the Province add a policy requirement that municipalities that establish higher forecasts than those contained in Schedule 3, should also establish higher Delineated Built-Up Area and Designated Greenfield Area targets, in keeping with the guiding principles of the Growth Plan.

6. It is proposed to update definitions including, Cultural Heritage Landscape, Ecological Function, Habitat of Endangered Species and Threatened Species, Municipal Water and Wastewater Treatment, On-Farm Diversified Uses and Public Service Facilities, as well as add a new definition: Impact of a Changing Climate.

City of Burlington Comments:

• The City of Burlington is generally supportive of the proposed changes especially where updates are proposed to align definitions with the PPS, 2020.
• Please note that the City has provided proposed alternative language with regards to the Ecological Function definition. Please see Appendix A: Detailed Comments for further details.

7. It is proposed to add a new policy 2.2.6.1 d) that directs Upper- and single-tier municipalities to “address housing needs in accordance with provincial policy statements such as the Policy Statement: Service Manager Housing and Homelessness Plans”.

City of Burlington Comments:

• The City of Burlington is supportive of this change for consistency with the PPS, 2020.

The City also requests that the Province provide stronger tools to assist municipalities in delivering more housing to a broad range of demographics and income levels.

8. It is proposed to update 5.2.3.3 to remove “First Nations and Metis communities” from the list of groups that municipalities are encouraged to engage with in local efforts to implement the Growth Plan. Engagement with Indigenous communities is now specifically referenced in new proposed policy 5.2.3.4.

City of Burlington Comments:

• The City of Burlington supports additional policy language to strengthen requirements to engage with Indigenous communities.

• As outlined in the joint Halton Area Planning Partnership (HAPP) submission, the City of Burlington requests that the Province provide additional guidance to municipalities on what constitutes “appropriate engagement” in various planning contexts and/or geographic areas of the Province. There is a pressing need for Provincial guidance to support the implementation of these policies by providing municipalities with clear direction on what will be expected through consultation and which applications will require consultation with Indigenous communities. The City of Burlington also recommends that the Province develop consultation guidelines so that there is a mutual understanding of what constitutes meaningful engagement.

9. It is proposed to revised policy 5.2.3.3 to change the co-ordination of planning matters with Indigenous communities from an encourage to a shall. Revised policy also removes specific language regarding building relationships and facilitating knowledge sharing in growth management and land use planning processes.

City of Burlington Comments:

• The City of Burlington is supportive of proposed changes that strengthen the policy from an “encourage” to a “shall”; however, the policy should maintain the specific language regarding building relationships and facilitating knowledge sharing in growth management and land use planning processes.

• Further, as outlined in the joint Halton Area Planning Partnership (HAPP) submission, there is a need for the Province to both provide resources to Indigenous communities and guidance to municipalities on how to fulfill this policy direction.

10. It is proposed to complete several minor policy language changes on a variety of topics.

City of Burlington Comments:

• Generally, the proposed changes are to provide alignment with the PPS 2020 and, given that, the City of Burlington has no concerns.

• Please note that the City does provide a technical comment related to the proposed deletion of Schedule 7 reference in 5.2.4.6 and 6.5.2. Please see Appendix A: Detailed Comments for further details.

Thank you for providing the opportunity for the City of Burlington to provide comments on these proposed policy changes.