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ERO number

019-5952

Comment ID

82077

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

Waterloo Region Home Builders’ Association (WRHBA) participated in the process leading up to the adoption of Regional Official Plan Amendment No. 6 (ROPA 6), including the submission of two written comments. Unfortunately, the adopted version of ROPA 6 does not address WRHBA’s concerns, which include:

1. Consumer choice in housing, including the provision of a range and mix of housing types and tenures.
2. The provision of a range of affordability and attainability in housing choice throughout the Region, which is in part, dependent on Item 1 above.

Bill 23, as recently enacted by the Province, gives strong direction to municipalities for the provision of housing over the short term. ROPA 6, in its current form, will not properly implement the objectives of Bill 23, or the objectives of WRHBA, as stated above.

These objectives, coupled with the ten-year housing targets recently assigned to the Cities of Kitchener, Waterloo, and Cambridge by the Province, will require an aggressive growth management strategy that includes an appropriate and achievable intensification target and significantly more designated greenfield areas (DGAs) than have been proposed by ROPA 6. In fact, based on the Region’s Land Needs Analysis (LNA), significantly more land is required than has been allocated through any of the three growth scenarios proposed by the Region’s Municipal Comprehensive Review (MCR) and LNA. From WRHBA’s perspective, there are obvious and fundamental flaws in the Region’s LNA.

WRHBA is therefore requesting that the Region be directed to reconsider its LNA and MCR. Alternatively, we would ask that the Ministry expeditiously undertake to identify the appropriate land requirements, including intensification and density targets, in consultation with appropriate industry stakeholders. The necessary modifications should be made to ROPA 6 in short order, to provide the additional tools and permissions that the industry requires to help ameliorate the ongoing housing crisis and fulfill the objectives set out above.