To Whom It May Concern:…

To Whom It May Concern:

Thank you for the opportunity to provide feedback on ERO posting 025-0462. Please see attached an electronic submission from the City of Burlington. Below are the key points extracted from the submission, c/o of City's Community Planning Department.

- Sun/shadow, wind, lighting, and certain urban design elements are characteristics of development that can be adjusted to mitigate the impacts of development. While staff prefer that they be left in as requirements for a complete application, there is an acknowledgement that these urban design elements are not necessarily threshold matters that need to be fully understood and accounted for at the application acceptance stage.
- Staff should be willing to remove these items from complete application requirements provided the City can still identify its expectations for lighting, sun/shadow, wind, and urban design and assess these impacts through the formal application review process, and that there is opportunity to receive these materials at a later date as conditions of approval.
- Staff note that compliance with these requirements has the potential to influence the design of a building and is preferable to be resolved at the front end of a development review process rather than at the end.
- Additional comments/concerns:

o Urban design should not be about building materiality, but rather, massing and context. When defined appropriately, urban design can be a tool to support innovation and to unlock and facilitate development permissions. It is also key to upholding the public realm and creating livable, sustainable, safe and inclusive communities, which contribute to a high quality of life.
o Requiring a wind and sun shadow study is not meant to stifle creativity or the development of new housing. As opposed to hindering new development, understanding wind and shadow implications can be a tool to rationalize greater building heights/forms and enhanced growth beyond current permissions.
o Similar to flood risk, wind studies can determine human health and safety risks and should continue to be assessed in some capacity through development approvals.
o Without these studies, quality-of-life concerns – not only at the individual level but cumulative impacts – may not be fully understood. Furthermore, there are Provincial directives and public expectations that systems are in place to support livable, sustainable communities. Without these studies, development applications could be reviewed in isolation from one another instead of at a community level.
o If the need for these studies is eliminated as part of a complete application, does it also eliminate the ability to consider these issues during application reviews?
o An alternative to removing from complete application requirements is to develop a provincial standard for wind/sun shadow study requirements.

- As long as these matters can be considered elsewhere or later in the development process, staff are supportive of removing from complete application requirements.

Given the short period for consultation, the attached comments have not been approved by City Council. The contents that supported the development of this letter have been shared with the City’s Committee of the Whole and will be considered by Council on June 17th. Should Council determine that changes to these comments are required, the Province will be advised at the earliest opportunity.