My name is Joshua Morgan. I…

My name is Joshua Morgan. I am a registered professional planner, and the principal of MORGAN Planning & Development Inc.

MORGAN Planning & Development Inc. has been retained by 2539814 Ontario Inc., the owner of 1505 Silk Line (Township of Severn) to act on its behalf as land use planner and project manager through the site plan approval process. The property was purchased by 2539814 Ontario Inc. in 2016 to be used as an end of life vehicle (ELV) processing facility.

The development of the site is required to ensure that the facility is able to operate in accordance with provincial guidelines which pertain to all ELV processors in Ontario.

Summary of Comment
We support the province's initiative to integrate the PPS and A Place to Grow. It is understood that one of the core elements of this new policy instrument could include a streamlined policy direction related to natural heritage, which will empower local decision making, while providing more options for reducing development impacts via an ecological offsetting policy.

We feel that an ecological offsetting policy is a prudent approach as it could enable lands that are zoned and/or designated for development to proceed, while at the same time establishing a net gain with the respect to the extent and quality of natural heritage features and their functions.

Background pertaining to 1505 Silk Line, Township of Severn

ELV processing facilities are defined in Township if Severn's Zoning By-law as a ‘salvage or wrecking yard’. The entire subject property is zoned General Industrial (M2). A 'salvage or wrecking yard' is permitted as of right within the M2 Zone.

The only Planning Act approval that is required to facilitate the proposed ELV processing facility is site plan approval.

The entire property is covered by the provincial natural heritage system.

Despite the permissive M2 zoning of the entire property, section 4.2.2.3 of A Place to Grow includes very prescriptive direction which restricts disturbance on site to a maximum of 25% of the total developable area, and directs that the impervious surface will not exceed 10% of the total developable area. This policy dramatically decreases the development potential of lands within the natural heritage system, even if those lands are not deemed to be key natural heritage features.

As it pertains to 1505 Silk Line, section 4.2.2.3 of A Place to Grow results in a disturbed area of a mere 3,850 square metres, and an impervious surface of only 400 square metres, on a property with a lot area of 203,535 square metres (20.3 ha).

This strict policy approach makes it very difficult to generate employment even on lands that are zoned and/or designated for employment growth.

Concluding Remarks
The implementation of an ecological offsetting policy via the integration of the PPS and A Place to Grow will enable lands that are zoned and/or designated for growth to be developed responsibly and appropriately.

Respectfully,
MORGAN Planning & Development Inc.

Joshua Morgan, RPP
(705) 327-1873