Charles O’Hara Ontario…

Charles O’Hara
Ontario Growth Secretariat
Ministry of Municipal Affairs
c/o Business Management Division, 17th floor
777 Bay Street
Toronto ON
M5G 2E5

Dear Mr. O’Hara:

RE: PROPOSED AMENDMENT TO THE GROWTH PLAN FOR THE GREATER GOLDEN HORSESHOE (2017) - ERO NUMBER: 013-4504

We are the owners of three properties in the Town of Milton under the following company names: Milton Britannia Development Corp.; Milton Fifth Line Development Corp.; and Fifth Line (5368) Milton Development Corp. Our landholdings are currently part of the Milton Phase 4 (MP4) West Landowners Group, located within the Milton Phase 4 Urban Expansion Area, also known as the Britannia East/West Secondary Plan area in the Town of Milton. The MP4 lands are located within the Urban Area of the Town of Milton, and comprise approximately 900 hectares of land within the Town of Milton.

We have reviewed the Proposed Amendment 1 to the Growth Plan for the Greater Golden Horseshoe, 2017, and would like to express our support for the changes the provincial government proposes as they relate to removing several significant challenges posed by the 2017 Growth Plan. Proposed Amendment 1 will support the advancement of good planning in the Province of Ontario by providing needed increased housing supply and employment opportunities, and removing the many challenges posed by the current policies of the Growth Plan.

Specifically, we would like to express our support for a number of the proposed changes to the Growth Plan, which are outlined below.

1. Intensification and Designated Greenfield Area Density Targets

 The proposed revisions in section 2.2.2.1 to the minimum intensification targets which will reduce the minimum intensification target applicable to Halton Region to 50 per cent to the 2041 planning horizon.
 The proposed revisions in section 2.2.7.2 to the minimum designated greenfield area density targets which will reduce the minimum designated greenfield area density target applicable to Halton Region to 50 persons and jobs per hectare.

 The proposed revisions in section 2.2.7.2 to allow councils of upper and single tier municipalities to request an alternative target where it can be demonstrated that the target cannot be achieved and that the alternative target will support the diversification of the total range and mix of housing options and the achievement of a more compact built form.

The changes proposed will support the advancement of well-planned communities in the Province of Ontario by providing flexibility to respond to local conditions that the previous intensification and intensity framework did not properly account for.

2. Settlement Area Boundaries

 The proposed revisions in section 2.2.8 which will enable flexibility to alter settlement area boundaries outside of an MCR subject to certain criteria, and up to a maximum of 40 hectares.

The changes proposed will allow greater flexibility for municipalities to address settlement area boundary issues, and will allow for settlement area boundary expansion that can respond to local conditions in a timely manner. It is recommended that the size threshold of 40 hectares be expanded to allow for further flexibility in the implementation of these policies.

3. Natural Heritage Systems

 The proposed revisions in section 4.2.2 which clarify that the provincial mapping does not apply until implemented within municipal official plans, and that refinement of provincial mapping can occur at the time of initial implementation through the Official Plan.

The changes proposed will allow for appropriate refinement to the provincial NHS mapping through municipal official plans, and provides greater clarity in regards to the role of provincial mapping which was a point of confusion in the 2017 Growth Plan.

4. Employment Planning

The proposed Provincially Significant Employment Zone mapping identified as part of the Proposed Amendment incorrectly identify a portion of the Britannia East/West Secondary Plan area as within the PSEZ. We request that this error be corrected, and that the PSEZ designation be removed from the northern portion of the Britannia East/West Secondary Plan area. The specific delineation of this area is also provided through the comments and submissions by the Town of Milton.

We understand that, among the proposed changes, the proposed amendment to the Growth Plan will allow employment area conversions to be approved prior to the next Municipal Comprehensive Review (“MCR”), affording flexibility to municipalities to support mixed use development and protect employment areas. We support this proposed change.

5. MTSA’s

The radius for a Major Transit Station Area (“MTSA”) is also recommended to be increased to include areas that are up to 800 metres away from the Major Transit Station through proposed Amendment 1. We support this revision to the policies.

As noted, we understand the staff of the Town of Milton prepared a submission to the Province in response to the Proposed Amendment 1 to the Growth Plan which was unanimously supported by the Town of Milton Council (attached). We concur with the Town’s comments and the MP4 West Landowners would like to express our support for the Town of Milton’s comments in regard to the proposed amendment including the mapping corrections.

Yours truly,

Eddie Lee P. Eng.
Vice President,
Construction and Land Development
State Building Group/Forest Hill Homes