This submission is in…

This submission is in response to the posted Environmental Registry of Ontario’s posting number 019-6113 with respect to the County of Simcoe’s Official Plan Amendment No. 7.

This submission focuses on the lands known municipally as 1505 Silk Line within the Township of Severn, County of Simcoe. Our firm has been retained to act on the owner's behalf as a land use planner and project manager through the site plan approval process.

The active site plan application proposes the development of an end of life vehicle (ELV) procession facility.

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.

The purpose of this submission is to request that the province consider the difficulties created by the Growth Plan's natural heritage policies when generating employment on lands that are zoned for development.

This request is applicable to ERO posting 019-6113, as it is very likely that the provincially mandated employment forecasts and allocation will be difficult to achieve unless the Growth Plan's natural heritage policies are revised to enable ground truthing and offsetting policies.