PARENTE GROUP HOLDINGS…

PARENTE GROUP HOLDINGS LIMITED
35 Jerseyville Rd West, Ancaster, Ontario, L9G 1A1

May 10, 2023

Ministry of Municipal Affairs and Housing
Provincial Land Use Branch
13the Floor, 777 Bay St
Toronto, Ontario, M7A 2J3

RE FILE NO: 019-6813
Dear Ministry of Municipal Affairs and Housing of Ontario,
I am writing to express my thoughts and suggestions regarding the new draft Provincial Policy Statement. I believe the proposed changes are a step in the right direction for Ontario and I appreciate the effort put in by the Provincial Land Use Branch to improve land use policies.
However, as with any new policy or statement, there is always a concern regarding the implementation and enforcement of these policies. Therefore, I would like to suggest some measures to ensure that the proposed policies are realized for their intended purposes, and not left unenforced by the Municipality.
My group owns property on Twenty Road West in Hamilton, and we are grateful the Ministry advanced our INFILL parcel into the urban boundary for housing. But in order to deliver housing, we need to deal with the City of Hamilton and as such require some tweaks to the language of your very much improved polices so that the City cannot slow-walk, stage, or delay much needed housing which appears to be what could occur.
Firstly, it is essential to provide adequate and strict direction and enforcement to the Municipality on the issue of NEF noise contour limits and using the latest updated noise data. This is currently a problem in Hamilton as the City does not do either of these things and as such is impeding maximizing residential infill. The PPS new infill residential development and other sensitive lands uses are permitted up to 30 NEF. Further the PPS advises that redevelopment or infilling of residential land uses may occur above 30 NEF subject to airport conditions. These polices already exist but the language must be stronger through explicit direction that the municipalities MUST be in compliance on the threshold and the latest data. We ask that the Ministry add language that enforces the NEF contours and regular updated data that advise the NEF
Secondly, as we have lands that straddle an residential and employment line. As such, part of these employment lands are suitable for residential as they fit much better with the proposed community, and comply with the 30 NEF (as referenced above). We have requested an Employment Conversion of the area in question and are at the mercy of the municipality. It would be much more efficient if the ministry add polices that allow us, as the applicant to have first-party appeal rights for employment land conversions if certain tests, such as the achievement of draft PPS Sec 2.8, have been demonstrated. This would allow protection of the employments areas while still allowing broadening of the uses in an appropriate fashion.
Thirdly, it is recommended that the proposed PPS be updated to acknowledge the importance of privately initiated secondary plans, subject the participation of the municipalities. Without a privately initiated process, housing that can commence immediately can be delayed for many years, perhaps decades. A privately led plan also makes it more economical for the municipality and certainly supports the premise that development pays for development. This ultimately allows the municipality to not require more staffing and better allocate which areas to focus on growth and the resources that needs to be allocated appropriately. We request that the ministry devise language to enforce the permission of privately initiated secondary planning on the municipalities subject to reasonable terms.
Lastly, it is crucial to monitor and evaluate the implementation and enforcement of the new policies regularly. This will help to identify any issues or areas of improvement and allow for adjustments to be made accordingly.
In conclusion, I believe that the proposed changes in the draft Provincial Policy Statement are a positive step for Ontario. However, it is essential to ensure that the policies are implemented and enforced effectively to achieve their intended purposes. I hope that my suggestions will be considered and incorporated into the final version of the policy statement.
Thank you for your consideration.
Best Regards
Paul A. Parente
905 512-4107
paul.parente17@gmail.com

PARENTE GROUP HOLDINGS LIMITED
35 JERSEYVILLE ROAD WEST, ANCASTER, ON, L9G 1A1