Attn: Gabriel Kim, Municipal…

Attn: Gabriel Kim, Municipal Services Office – Western Ontario

RE: ERO number 019-5952
Regional Municipality of Waterloo Official Plan Amendment 6
Lammer Development Group
805395 ONTARIO LIMITED and 742825 ONTARIO LIMITED
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On behalf of the Lammer Development Group (“Owner”), CLS wishes to submit the following comments to the Ministry of Municipal Affairs and Housing (“MMAH") in response to its review of the Region of Waterloo Official Plan Amendment No. 6. The Regional Municipality of Waterloo adopted the Official Plan Amendment (OPA) as part of its Municipal Comprehensive Review on August 18, 2022. The OPA proposes to establish the planning framework to accommodate population and employment forecasts to 2051. The OPA also establishes new policies regarding land use, transportation, public transit, water and wastewater (amongst others). To assist the Province in its review, the following offers commentary on the proposed OPA specifically pertaining to the lands located at 241 Queen Street West, Cambridge (subject lands).

A development concept is being advanced for the subject lands which will assist in achieving the Region’s forecasted growth to 923,000 people and 470,000 jobs by 2051, of which 214,900 people and 120,700 are planned for the City of Cambridge. Although the subject lands are located within the Urban Areas, it is not designated residential. Instead, the Cambridge Official Plan designates the subject lands as “Business Industrial” and “Natural Open Space System” and locates the lands within a “Regeneration Area”. As illustrated within the appended concept plan (Appendix B), the proposed development has been designed to accommodate the “Natural Open Space System” and the proximity to the Grand River as well as the policies of the City and Conservation Authority.

Further, the “Regeneration Area”, as set out in the Official Plan, are to transition from one use, such as industrial, to another. Regeneration areas are not considered to be employment areas and would not require a conversion through a municipal comprehensive review. Regardless, the proposed development will drastically assist in achieving the established population and employment growth targets for the Urban Areas.

The subject lands and buildings were purchased from the City of Cambridge in 1987. The original Purchase and Sale agreement committed both parties to Mutual Assistance and co-operation in attempting to secure the necessary Municipal, Regional and other approvals required for the development of the lands. Further it committed the City to provide services and the developer to renovate the old industrial buildings to a minimum of 260 purpose-built residential rental units. This site has therefore long been envisioned to evolve into a residential use, capitalizing on the site’s river front setting and its potential to add significant economic benefit to Cambridge. It would contribute substantially to the renewal of the Hespeler core by bringing people and their economic and social vitality to the neighbourhood. It is also useful to note, residential zoning has been granted on the adjacent industrial property.

On February 24, 2021, the Lammer Development Group requested the City’s support for a Minister’s Zoning Order. On April 27, 2021, the City of Cambridge Staff Report 21-126(CD) was prepared in support of the proposed Lammer Development Group Minister’s Zoning Order (Appendix A). Due to timing, the MZO was not advanced and has since remained on hold.

As set out in Appendix A, the owner is proposing the development of the subject lands to include a mixed-use community consisting of approximately 1,500 to 1,800 residential dwellings including 260 purpose-built rental units, senior assessed housing units and affordable housing (Appendix B). Several medium and high-rise mixed use apartment buildings are proposed along Queen Street West as well as new road infrastructure. The overall development will activate 10 to 12 acres of green space, along the Speed River. To support of the proposed development, the Owner has advanced considerable technical work.

Given the subject lands proximity to the Hespeler downtown, it will offer a unique opportunity of creating a complete community on a former industrial parcel. The proposed development would create approximately 400 jobs per year, phased over 6-8 years, approximately $1 billion in new property assessment and approximately $10 million in additional annual tax revenue. The subject lands are also uniquely located adjacent to an existing rail corridor which has been assessed as an optimal connection for a future GO Train route into the GTA.

The Regional Official Plan Amendment brought into effect the first phase of the MCR to accommodate the region’s forecasted growth to 2051. Of the key components, the OPA promotes an intensification first approach to development, identifies where and how the region will grow to 2051, identifies minimum intensification targets, implements a series of employment lands to convert and provides direction to phase growth and infrastructure in a sustainably and financially responsible manner.

In support of the Ministry’s review of the Regional Official Plan, this development represents a significant achievement of Provincial, Regional and Local planning objectives. Further, it’s consideration for an MZO by municipal staff establishes it as a development which is supported and can immediately achieve housing subject to the implementation of certain planning provisions.

As such, it is requested that the Ministry consider the implementation of the following standards through its review:
a) Redesignate the subject lands to “High Density Residential” from its current designation to permit a high-density residential development including apartment buildings and accessory uses and:
b) Rezone the subject lands to Residential Multiple (RM3) and Institutional (N2) Zone with the following exceptions;
a. Maximum height of buildings and structures of 85 metres, inclusive of rooftop mechanical structures;
b. No maximum number of dwelling units per hectare;
c. Maximum lot coverage of 30 percent;
d. Minimum floor space index of 1.2;
e. Maximum floor space index of 2.9; and,
f. No minimum lot frontage.

It is the hope of the Lammer Development Group that the above comments will assist in the Province’s review of the Region of Waterloo Official Plan Amendment and to incorporate policies that establish immediate solutions to address the housing supply crisis. Should there be any questions or a need for further information, feel free to reach out to the below.
Sincerely,

John Corbett
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John B. Corbett, MCIP, RPP
President
Corbett Land Strategies Inc.
john@corbettlandstrategies.ca
416-806-5164