We are Hamilton homebuilders…

We are Hamilton homebuilders and developers. We own lands in the Elfrida, Twenty Road East and Twenty Road West/Garner Road areas. We are not land speculators. We are long-standing members of the Hamilton community and, collectively, have constructed a very significant proportion of Hamilton’s housing stock.

We continue to build homes and communities for Hamilton’s growing population. Today’s developments are smart, well-planned, complete communities. They make efficient use of land by incorporating a mix of residential densities, community facilities, open spaces, and environmental innovations.

With this context, we are writing to provide our comments on the proposed amendments to the Urban Hamilton Official Plan and Rural Hamilton Official Plan endorsed by Hamilton City Council in November 2021 and now before the Minister of Municipal Affairs and Housing for consideration (the “Proposed OPAs”). The Proposed OPAs are intended to implement a No Urban Boundary Expansion (“NUBE”) growth option to accommodate the City’s forecasted population and employment growth to the year 2051. Our overriding comment is that the Proposed OPAs should not be approved in their current form, and the Minster should instead modify and approve official plan amendments which include an urban boundary expansion that comprises the Elfrida, Twenty Road East and Twenty Road West/Garner Road areas as shown on the attached map and implements the Ambitious Density Scenario which is supported by the City of Hamilton planning staff and its consultants. The Elfrida, Twenty Road East and Twenty Road West/Garner Road areas are the only remaining Whitebelt lands contiguous to the City’s existing urban boundary, and they comprise approximately 1,330 gross developable hectares, the size of the urban boundary expansion required by the Ambitious Density Scenario. Long earmarked to accommodate growth, the City has spent or allocated hundreds of millions of dollars on infrastructure projects serving each of these areas in anticipation of a needed urban boundary expansion.

In support of this request, we are attaching a copy of our letter sent to the Mayor and Councillors of the City of Hamilton dated April 14, 2022. As set out in that letter, City Council’s decision to endorse the NUBE scenario does not conform to Provincial policy, does not represent good planning, is contrary to advice received from City and Provincial staff and, most importantly, does not address the acute housing supply shortage that currently exists in Hamilton.

As noted in our letter and the City of Hamilton’s own public reports, the Ambitious Density Scenario is, as the name suggests, ambitious. It has the effect of substantially reducing the amount of new urban expansion lands needed to accommodate growth and will require a substantial increase in residential intensification and shift to higher-density apartment forms to be realized. While there is no doubt that the Ambitious Density Scenario is a challenging growth management objective to begin with, as Hamilton homebuilders and developers we are up for that challenge.

For the reasons noted above, and those provided in our April 2022 letter, we believe that the Minister should promptly exercise its powers under the Planning Act and Places to Grow Act to approve an urban boundary expansion that implements the Ambitious Density Scenario and includes the Elfrida, Twenty Road East and Twenty Road West/Garner Road areas.

* This letter is also being submitted as a PDF. The PDF includes attachments, and, in particular, the April 2022 letter submitted to City Council and the map showing the lands that should be brought into the urban boundary under the Ambitious Density Scenario to meet growth needs to 2051, as noted above.