Glen Schnarr & Associates…

Glen Schnarr & Associates Inc. (GSAI) is the planning consultant to the Heritage Heights 52-5 Landowner Group (HHSP 52-5 LOG) who own most of the lands bounded by Winston Churchill Boulevard to the west, the CN Railway corridor to the north, the Highway 413 Transportation Corridor to the east, and Bovaird Drive West to the south in the City of Brampton (City). These lands are known as the Heritage Heights 52-5 Precinct Planning Area. On behalf of the HHSP 52-5 LOG, we appreciate receiving the notification of the proposed reduction to the transmission corridor protection area. A detailed comment letter is included as a supporting document.

We do, however, have serious concerns with the location of the proposed scoped study area and we respectfully request that:

• The scoped future electrical transmission corridor study area be shifted immediately abutting the west side of the MTO’s preferred Hwy 413 route as shown on Attachment 2 (refer to supporting letter).

In reviewing the proposed refinement of the Northwest GTA Transmission Corridor, the new 150-metre corridor is now proposed outside of the current protection area and bisects the middle of the 52-5 Precinct planning area through future key community spine roads and future developable land. The proposed alignment is inconsistent with the area that has been protected for this very purpose for many decades and significantly disrupts long-historical good planning practise and
progress that has occurred outside of the current protection area. All of which was done without any consultation with the public or affected landowners. An overlay showing the proposed alignment and impact through the Development Concept is attached as Attachment 3.

From a planning and development perspective, we advise that the proposed alignment through the 52-5 Precinct Plan has a very detrimental effect on the City’s and the HHSP 52-5 LOG’s vision for a well-planned community for the following reasons:

1. The proposed alignment would surround itself with sensitive, generally low-density residential land uses on both sides. This can be substantially mitigated by locating the transmission corridor adjacent to the Highway 413 right-of-way and limiting its interface impacts with the residential community.

2. The proposed alignment would cross through an existing cemetery, existing place of worship (Assembly Hall of Jehovah’s Witnesses) on the north side of Bovaird Drive, and through lands owned by the City intended for active recreational purposes, immediately south of the Precinct 52-5 area. An alignment adjacent to the Highway 413 right-of-way, as has always been shown and expected, would avoid impacts to these land uses and their current and future operations.

3. The proposed alignment would fragment Precinct 52-5 into an inefficient and undesirable development, whereas the community is intended to be walkable, well-connected, and accessible. This could otherwise be avoided by locating the transmission corridor adjacent to the Highway 413 right-of-way.

4. The location of the new proposed alignment through the middle of the residential community provides for a poor aesthetic, creates a less attractive place to live and would be riddled with land use incompatibility challenges.

5. Multiple road and pedestrian crossings of the corridor would be required to provide access through and connectivity with the community. Such crossings increase unwanted exposure and access to the transmission corridor and affect public safety.

The HHSP 52-5 LOG is very concerned, and it is our professional planning opinion that the new proposed alignment outside the current protection area is based on poor planning and is unacceptable, particularly when such corridor protection was contemplated as part of the future Highway 413 route selection process. We request that the transmission corridor alignment through the 52-5 Precinct Plan area be maintained within the current protection area and placed immediately adjacent to the Highway 413 right-of-way corridor, where it results in the least amount of impact to the proposed community and public safety.

The proposed revision to the Narrowed Area of Interest for the Northwest GTA Hydro Corridor constitutes a material and unjustified departure from both Provincial policy and established planning direction. The new proposed alignment introduces a separate, four-kilometre hydro corridor west of Heritage Road within the Heritage Heights Secondary Plan area in the City, an area that had been comprehensively planned and approved based on a co-located corridor with Highway 413.

This unilateral change directly contradicts the guiding principles of the Provincial corridor identification process and the policy direction set out in the Provincial Planning Statement (PPS, 2024), which emphasizes efficient land use, co-location of linear infrastructure, and the minimization of adverse impacts on surrounding lands and communities.

Contravention of Co-Location Policy

Section 3.3.5 of the Provincial Planning Statement explicitly directs that “the co-location of linear infrastructure should be promoted, where appropriate.” The proposed separation of the hydro corridor from Highway 413 disregards this clear policy directive and undermines the coordinated infrastructure planning approach that has been the hallmark of the Provincial process to date.

The principle of co-location serves to reduce the cumulative footprint of major infrastructure projects, limiting their encroachment on agricultural and natural heritage systems and minimizing disruption to established and planned communities. The decision to abandon this approach introduces unnecessary increase in adverse land use impacts and stands contrary to the objectives of efficient, integrated infrastructure planning.

Inconsistency with the Province’s Own Guiding Principles

The March 23, 2020, Environmental Registry posting titled “Proposal to Identify and Protect a Corridor of Land for Future Electricity Infrastructure in the Greater Toronto Area” identifies colocation with other linear infrastructure as the first guiding principle of corridor identification.

No technical evidence, consultation or rationale has been provided to justify deviating from this principle, nor has the Province demonstrated that co-location through Heritage Heights is not feasible. The absence of such justification undermines the transparency, integrity, and evidence based foundation of the corridor identification process.

Undermining the Integrity of Established Municipal and Tribunal-Endorsed Planning

The Heritage Heights Secondary Plan, approved by the Ontario Land Tribunal (OLT), was explicitly structured around a single, co-located transportation and transmission corridor. The Province previously acknowledged the adequacy of this approach by declining party status during the OLT hearing, recognizing that the plan appropriately protected both the FAA and NAI.

Introducing a new, independent hydro corridor through Heritage Heights would invalidate years of coordinated planning between Provincial ministries, the City, the Region of Peel and affected landowners, as well as substantial public and private investment in the development of a fully integrated community structure.

We appreciate the opportunity to provide these comments and respectfully request that the MEM give due consideration to the issues raised. The recent change to the corridor alignment represents a fundamental shift in Provincial direction and policy consistency that warrants immediate reconsideration.