Malone Given Parsons Ltd. (…

Malone Given Parsons Ltd. (“MGP”) are the planning and land economics consultants for Syrier Holdings Inc. and Birdland Developments Inc., owners of lands (“Subject Lands”) identified for future residential development in the community of Elmira in the Township of Woolwich (the “Township”), one of the lower-tier municipalities in the Regional Municipality of Waterloo (the “Region”). I am writing to provide commentary on the ERO Posting of the Region of Waterloo Official Plan Amendment No. 6 (“ROPA 6”).

The Subject Lands have been identified in the ROP for residential development since 2009. They have been precluded from development on the basis of outdated growth restriction policies in the Township OP which are not in keeping with the modern Provincial mandate and stated priorities.

The lands abut the Built Up Area and have existing municipal services at the property limits, allowing them to develop in an efficient manner in a very short timeline. Appendix 1 provides an overview confirming serviceability of the lands and the presence of sufficient infrastructure capacity.
The proposed plan of subdivision (Appendix 2) would allow for 350 new homes to be constructed, providing additional housing capacity for a population of about 950 people.

It is our expectation that through an eventual conformity update to the Township OP following provincial approval of ROPA 6, that conformity with Policy 2.A.5 will require amendments to the restrictive Township OP growth management scheme as it exists today.

Given the pressing need to construct new housing in Ontario, including in smaller urban municipalities such as Elmira, a site specific solution which supercedes existing restrictive growth management policies would allow the Subject Lands to form part of the solution to building 1.5 million new homes by 2031.

The Subject Lands are positioned to be developed as part of a complete community and will provide multi-modal connectivity and completion of adjacent built neighbourhoods.

As noted in this letter, development of the subject properties is long overdue; expediting development on them will assist the Township, Region, and Province in providing much needed housing. The properties can proceed to development with densities that assist in the achievement of the Region’s designated greenfield density target.

Development can occur on the properties concurrent with the Region’s realization of its intensification targets and will represent the orderly progression of development that is a logical extension of the existing settlement pattern in Elmira. The properties will be served by infrastructure and public service facilities required to meet resident’s needs.

The scale of the properties allows future development to provide a range of housing choices to achieve a 15-minute neighbourhood, where the provision of this housing should be encouraged comprehensively and concurrently.

It is therefore our opinion that the properties should proceed immediately to development, and that any delay in development approvals relating to growth management or the phasing policies imposed by the Region or Township is not good planning and would be counter to the planning intent of the
Province to expedite the delivery of homes and is not appropriate to impose under the policies of the
Provincial Growth Plan or the Provincial Policy Statement.

The properties can and should move forward to development without further delay, and accordingly we request that a site-specific policy be included in the Region’s official plan exempting the properties from any requirements for phasing.

We request that the Minister implement the following amendment to ROPA 6:

"2.J.10 Notwithstanding any policies to the contrary, for the lands shown on Figure 18 within the Township of Woolwich (Part of Lot 86, German Company Tract) generally located north of Listowel Road, east of Timber Trail Road, south of South Parkwood Boulevard and west of Arthur Street North, development applications can proceed immediately and shall not be subject to any growth management or phasing requirements and any development on the lands shall not be required to be phased or staged."

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,

Matthew Cory, MCIP, RPP, PLE, PMP
Malone Given Parsons Ltd.
Principal, Planner, Land Economist, Project Manager