On behalf of the New…

On behalf of the New Tecumseth Community Builders Inc. (“NTCBI”), Malone Given Parsons (“MGP”) requests that the Province modify Simcoe County Official Plan Number 7 (“COPA 7”) to include the Harvest Community into Simcoe County’s settlement area boundary.

NTCBI, through the work already completed by its consulting team and presented to the Town of New Tecumseth (the “Town”) and Simcoe County (the “County”) in 2022, has demonstrated that the inclusion of its lands within the settlement area will achieve the goals of the Town, County and Province, including:

1. Directing growth to the Primary Settlement Area of Alliston, where most of the growth should be focused,

2. A commitment to a robust Natural Heritage System including trails, multi-use paths, and recreational uses,

3. The early delivery of significant community parkland to the Town prior to development approvals so that it can be of benefit to the existing community as early as possible,

4. A financial commitment to fund approximately $380 million in water supply, sanitary treatment and road infrastructure for immediate and future community needs so that debt and financial risk are no longer a municipal concern,

5. A complete community that is comprehensively planned to provide a range of housing, transportation, education, recreation, shopping, and employment uses.

We have noted significant differences between our work and the County’s LNA, the latter of which has now been incorporated into COPA 7. It is our opinion that these issues should be addressed through corrections/modifications to COPA 7 prior to final approval by the Province. These include:

1. Correction to Table A by moving the following settlement areas from Category 3 to Category 4 recognizing they do not have full servicing: Atherly-Uptergrove, Colgan, Hillsdale, New Lowell, Nottawa, Stroud, Thornton.

2. Adjustment to the population and employment forecasts by local municipality contained in Tables B and C. In particular, the population and employment forecasts for the Town should be adjusted to approximately 112,000 people and 36,000 jobs respectively. This change would assign approximately 34% of population growth to 2051 in the County to the Town, reflecting the policy imperative to direct significant growth to Alliston as a primary settlement area in the Southern Market Area of the County, and the potential to realize this growth through commitments from the landowners to work cooperatively with the Town to front-fund servicing. The employment forecasts would reflect a laudable person to job ratio of 3:1, the strong local economy in Alliston, and the ability to attract new jobs through both employment lands employment and population-related employment uses.

3. Modification to policy 3.2.6 a) to replace ‘35%’ with ‘27%’ for the residential development occurring annually in the County within the delineated built-up areas to reflect the intensification rates currently being achieved in the County as demonstrated in the County’s Growth Management work. Similarly, policy 3.2.6 b) should be modified to reflect a 27% County-wide intensification target, as well as a 17% intensification target for New Tecumseth to reflect the intensification analysis and potential prepared by MGP.

4. Modification to policy 3.2.7 to replace ‘51’ with ‘37’ for the County-wide minimum designated greenfield areas density target, as identified in MGP’s Designated Greenfield Area Analysis. The minimum target for New Tecumseth should be modified to be a minimum of 43 which reflects the average of lower existing designated greenfield areas with the higher density new areas of the Harvest Lands.

5. Modification to Table F to revise New Tecumseth to allocate 780 hectares of Community Uses land and 270 hectares of Employment Lands with the required adjustments to the remainder of the table, and the inclusion of between 200-400 hectares in the primary settlement areas (particularly Alliston) in the Southern Regional Market Area to account for lands in the north that may not develop within the Plan horizon.

6. The deletion of policy 3.2.27 as it inappropriately identifies land requirements as maximums which could result in the failure to provide sufficient lands to meet the anticipated supply within the planning horizon of the Growth Plan.

7. Amendment to Schedule 5.1 of the County Official Plan to add the required settlement area boundary expansion in South Alliston as shown in Figure 3 of this letter.

For the reasons noted in this submission, we believe the Province should amend COPA 7 prior to final approval to include the Harvest lands as Settlement Areas to meet growth needs in the Town and County to 2051, and update COPA 7 with the suggested modifications contained herein.

In support of these request, we are attaching our prior submissions to the Town and County, which include:

• Letters to the County dated June 4, 2021, June 30, 2021, October 25, 2021, and June 13, 2022 providing comments on the Municipal Comprehensive Review, our 2016 Designated Greenfield Area Supply Analysis, and Settlement Area Boundary Request for the Harvest Lands in South Alliston, and our updated Land Needs Assessment and 2021 Designated Greenfield Supply Analysis and comments on the County’s draft Land Needs Assessment;

• Letters from NTCBI to the Town and County dated January 27, 2022 and February 4, 2022 providing comments on the County’s draft Land Needs Assessment (“LNA”) and response to the Town’s Settlement Area Boundary Expansion Evaluation Criteria, and an Infrastructure Financing Commitment proposal from the NTCBI to the Town for the Harvest Lands.

If you have any questions or wish to discuss this letter, please do not hesitate to contact the undersigned at any time.

Yours very truly,
Malone Given Parsons Ltd.

Matthew Cory, MCIP, RPP, PLE, PMP
Principal, Planner, Land Economist, Project Manager