February 3, 2023 …

February 3, 2023 Project: PB.BW

Re: ERO number 019-6113 – 3412 Line 8, Town of Bradford West Gwillimbury- Request for Policy Recognition and Additional Employment Numbers to support inclusion of additional lands inside the Bradford West Gwillimbury Strategic Settlement Employment Area

On behalf of 3412 BRD REM Ltd.

(content to be uploaded to EBR site)

RE: 3412 Line 8, Bradford West Gwillimbury (Assessment Roll Nos. 431202000522400 and 431202000522500)

Introduction

This submission provides comments regarding County of Simcoe Official Plan Amendment No. 7 (SCOPA7) with respect to adding lands to the Bradford West Gwillimbury Strategic Settlement Employment Area (BWGSSEA) to reflect the accelerated timeline of the Bradford Bypass.

We respectfully request that the Minister consider amending SCOPA7 to facilitate the expansion of the BWGSSEA to include the subject lands as they directly abut the proposed Bradford Bypass alignment. Recognition in SCOPA7 of an expansion will also support future Minister Directions issued under the Places to Grow Act

Background and Context:

3412 BRD REM Ltd., our client, owns approximately 62 Ha lands just east of the proposed interchange at Highway 400 and the Bradford Bypass, immediately south of the proposed alignment (Refer to submitted Context Map). The subject lands have significant development potential to accommodate large format employment uses - consistent with uses already permitted in the BWGSSEA that rely on goods movement along Highway 400 and eventually Highway 404.

Amending SCOPA7 to prepare the subject lands for inclusion in the BWGSSEA represents a logical progression of development along the Bradford Bypass. The progression east will also serve to better connect employment lands with the Bradford Primary Settlement Area (PSA) and its Major Transit Station Area.

The site’s inclusion in the BWGSSEA will support the significant investment of the Province into the Bradford Bypass. A prominent site in proximity to a primary interchange will reinforce the importance of the east-west link and encourage further investment and growth in the area.

The inclusion of additional lands and greater certainty of future uses will accelerate additional public and private infrastructure investment. More jobs, supporting a complete community, will create opportunities for responsible growth.

SCOPA 7 Requests:

1) MTSAs are already recognized in Section 3.2.12 of SCOPA7, however, there are no specific policies in SCOPA7 for SSEA’s. The inclusion of proactive policies reinforcing employment lands along key infrastructure is appropriate. The importance of SSEAs is critical for complete communities and will help ensure more balanced employment and residential growth in the south Simcoe region that is expecting a large influx of housing.

Laying the groundwork now for more specific policies that protect and expand the BWGSSEA will guide future land use planning decisions, including Minister Directions issued under the Places to Grow Act.

New SSEA policies in SCOPA7 could mirror those already established in the existing BWGSSEA Minister Direction. Facilitating land uses on the subject site, consistent with those already permitted nearby in “Area C”. Highway and goods movement related uses will also leverage significant transportation infrastructure serving the south Simcoe region and wider GTA.

To reiterate the permitted uses in Area C of the BWGSSEA, we consider the following uses appropriate for the subject lands:
a. Permitted employment uses: Distribution centre, food processing, manufacturing, outdoor storage as an accessory use, research facility including laboratory, warehouse, and training facility. Data centre if total gross floor area is less than 7,500m2. Ancillary office. Ancillary retail sales with a maximum of 10 per cent of the gross floor area of the total gross floor area of the building or structure.
b. Permitted office uses: To a maximum gross floor area of 7,500 m2.
c. Permitted employment supportive uses: Automobile service station, bank, convenience store, day care facility, fitness centre, machinery and equipment sales and rental, personal service shop, restaurant, service shop and private training centre.
d. Other permitted uses: Parks and open space and public uses.

2) We respectfully request that Section 3.2.5 of SCOPA be amended to clarify and reinforce that employment numbers in Table C can be exceeded when considering land use policy changes. Policy changes at the local and upper levels could then establish employment uses sooner and utilize existing and future infrastructure investments.

The Highway 400 corridor is already experiencing increased demand for serviced and well-located employment lands. This demand will only increase as residential growth pushes north. Fueling this demand is lower employment densities associated with warehousing and logistics uses that leave municipalities, like BWG, needing more land to meet the employment targets in SCOPA7 and the Growth Plan.

A policy alternative for justifying planning applications, beyond the current Table C numbers, would be including higher employment forecasts for those municipalities with SSEAs. Higher numbers would provide clear guidance on the importance of employment lands for complete communities.

Summary

Amendments to SCOPA7, as suggested above, will allow for additional lands to leverage significant infrastructure investment and increase prosperity in the south Simcoe region. The inclusion of policies that recognize the importance of SSEAs (including opportunities for expansion and establishing employment land uses) will promote responsible growth in more complete communities.