SmartCentres is pleased to…

SmartCentres is pleased to submit comments as one of the largest real estate investment trusts in Canada.

SmartCentres, which is publicly traded on the TSX with an asset value of over $9.4 Billion, is a fully-integrated real estate provider with expertise in acquisition, asset management, planning, development, leasing, operations, property management, and construction under one roof. SmartCentres owns and manages 34 million square feet of retail space across Canada; approximately 70,000 jobs are associated with SmartCentres’ landholdings.

We appreciate the Province’s genuine interest in considering our comments as a significant landholder. To be better informed and exchange comments on the Proposed Amendment 1 (hereinafter “Amendment”) to the Growth Plan, SmartCentres together with MacNaughton Hermsen Britton Clarkson Planning Limited (“MHBC”) attended 5 of the 6 Regional Workshops hosted by the Province.

SmartCentres is appreciative and supportive of the Province reviewing the current policy regime to enhance and protect employment lands within the Province of Ontario. It is our understanding the policy framework aims to:
 increase and promote economic growth;
 reduce congestion and provide residents easy access to business and services; and
 build communities that maximize infrastructure investments, while balancing local needs for the agricultural industry and natural areas.

Furthermore, the Amendment of the Growth Plan will allow employment area conversions to be approved prior to the next Municipal Comprehensive Review (“MCR”), allowing flexibility to municipalities to support mixed use development and protect employment areas.

Based on our and MHBC’s 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 Greater Golden Horseshoe. We have some concerns with the extent of this mapping and its accuracy vis-à-vis existing land uses and municipal Official Plan mapping.

We understand that a number of parties have made submissions to the Province, including upper and lower tier municipalities. Some municipal submissions that we have reviewed have proposed additional PSEZs (for example, the City of Toronto has proposed new areas, many of which we believe are not accurate and/or should not be included as they do not meet the criteria). To ensure a fair, reasoned, and open process to mapping changes, we request that additional consultation occur with landowners where changes to the mapping are proposed.

On a matter of principle, we submit that the current conversion process under the Growth Plan which can only occur through an MCR is cumbersome, expensive, and unresponsive to changing market conditions. In order to ensure Ontario remains competitive and resilient to global market forces, including both employment and housing, flexibility to allow for conversions is needed. We have proposed a number of detailed changes to the Growth Plan policies accordingly, specifically:

1. The importance of Major Transit Station Areas (“MTSA”) to provide for a mix of uses in an intensified built form to ensure full utilization of transit infrastructure investments is recognized in our proposed policy modifications. A policy has therefore been proposed to allow private applications to convert employment lands where employment lands are within a MTSA without the need for an MCR.

2. We are proposing a policy which would allow for the “layering” and “addition” of uses in a
development proposal without the need for an MCR. This will allow for new housing and
employment opportunities to occur at intensified levels while maintaining and / or enhancing the
creation of jobs on a property.

3. A policy is proposed to allow applications to convert employment lands without the need for an
MCR for up to 10% of a municipality’s employment lands outside of MTSAs. This would allow for a
municipality to collaborate in a positive manner with the private sector to unlock employment lands
in response to changing market conditions.

We request further discussions occur with the Province on these modifications.
The following comments on the proposed Growth Plan Amendment 1 are being submitted formally in
response to the Environmental Bill of Rights Notice. To assist, we have identified key themes to guide our discussion with regards to our recommendations.

RECOMMENDATIONS / CLARIFICATIONS

1. We request the removal of 11 sites which are located in MTSAs from being within PSEZ due to:
 Intent for increased densities within a MTSA through Municipal Official Plan Policies;
 Existing Land Use Designation (not employment);
 Planning Infrastructure (high-order transit and intensification corridors); and
 Create complete communities close to higher order transit.

2. We request nine sites outside of MTSAs be removed from PSEZ due to:
 Existing Land Use Designation (not employment);
 Surrounding Context;
 Identified as an intensification and/or transit corridor within Municipal Official Plans.

3. We propose the following policy modifications and/or request clarifications to existing and
proposed policy with the rationale as outlined in the attached letter (PDF).

SUMMARY

As noted above, we are appreciative and supportive of the Province reviewing the current policy regime to enhance and protect employment lands within the Province of Ontario. We request that should the mapping be modified that additional consultation is undertaking to ensure the mapping is accurate.

We hope our formal submission in response to the Environmental Bill of Rights Notice is received and
considered by the Province.

Respectfully Submitted,

SMARTCENTRES REIT