See attachment for full…

See attachment for full comment letter and attachments.

We have been retained by 3621 Dufferin Storage GP Corporation on behalf of 3621 Dufferin Storage Limited Partnership (hereinafter “Dymon Storage”) to review the proposed Amendment 1 to the Growth Plan for the property municipally addressed as 3621 Dufferin Street, Toronto.

To become better informed and exchange comments on the Proposed Amendment 1 (hereinafter “Amendment”) to the Growth Plan, MHBC has attended a number of Regional Workshops hosted by the Province.

Based on our review of the Amendment, it is understood that conversion of employment lands will continue to require a comprehensive assessment and the implications for economic development by the Ministry of Municipal Affairs and Housing (MMAH). The most significant proposed change is the introduction of Provincially Significant Employment Zones (“PSEZ”) mapping across the GTA. We are concerned with the extent of this mapping and its accuracy vis-à-vis existing land uses and municipal Official Plan mapping.

Dymon Storage lands have been included within the proposed PSEZ 9 (400/407 Keele Dufferin). The subject lands are designated Regeneration Area in the City’s Official Plan. Furthermore, the lands are subject to the Dufferin-Wilson Regeneration Study Area and City Council approved Official Plan Amendment 362 (Figure 1). Attached are excerpts from OPA 362 showing the land use designation which designates the lands as “Mixed Use”.

The subject lands are designated as Mixed Use within a Regeneration designation which is to encourage a variety of uses, based on the permitted uses of Regeneration Areas designation in the Toronto Official Plan, which include but not limited to commercial, residential, live/work, institutional and light industrial uses to be mixed within the same block or building.

We recognize the intent of the Amendment is to reflect existing designations and not to make any land use changes. However, the Province’s mapping erroneously includes the subject lands within PSEZ 9 (400/407 Keele Dufferin). This is in direct conflict with the Official Plan designation and zoning for the subject lands, as well as the adjacent lands within the Dufferin-Wilson Regeneration Study Area, which consist of residential and mixed use developments. Furthermore, Dymon Storage has an active application with the City Toronto to permit a 10-storey mixed use development which consists of 166 residential units, retail at grade, office and self-storage.

The Province’s proposed Section 2.2.5.12 of the Growth Plan requires that lands within a PSEZ be protected for employment uses through Official Plan policies and related land use designations. If implemented, this provision appears to require that the City re-designate the subject lands for employment purposes as part of its Official Plan review, which would ultimately be carried through to the zoning. As such, this is in contrast to the current mixed use permissions for the subject lands and Dufferin-Wilson Regeneration Area. We request the subject lands and adjacent lands consisting of residential and mixed use developments within the Dufferin-Wilson Regeneration Area be removed from the PSEZ to enable these lands to realize the increased density and investment envisaged by the Toronto Official Plan.

In addition, we request that additional consultation be undertaken to ensure the accuracy of the PSEZ mapping. We request also request that should the mapping be modified that additional consultation is undertaking to ensure the mapping is accurate and request the Province undertake further consultation with affected landowners on PSEZ mapping where municipalities have requested increased PSEZ limits which was not subject this consultation.

We appreciate your attention to this matter and hope that our request to correct this mapping is
undertaken.