See attached letter,…

See attached letter, including planning justification report.

Request for Employment Area Conversion submitted to Region of Durham, and comments reiterate that request to designate the RioCan Lands (1629, 1635, 1650, 1741, 1751, and 1761 Victoria Street East in Whitby) as Community Areas.

The Draft PPS and the amendments to the Planning Act represent a significant change to Provincial Employment Areas policies, which include clear direction that “areas of employment” do not include retail or commercial uses, unless accessory to a primary employment function such as warehousing and manufacturing.

Under Bill 97 and the Draft PPS, the RioCan Lands and the existing commercial services provided would not be considered as Employment Areas intended for manufacturing, research and development uses in connection with manufacturing, warehousing, goods movement, associated retail and office, and ancillary. Further, due to their context in isolation from the broader Employment Area, and given the existing site characteristics as a retail centre, it is not anticipated that the RioCan Lands will feasibly redevelop for expanded standalone employment uses such as warehousing or manufacturing, which results in limited intensification opportunity under the existing context. In our submission, the continued identification of the RioCan Lands as Employment Areas is inconsistent with their context as a retail centre, and may indeed jeopardize their long-term viability as an established commercial node, in the emerging context of what the Province considers as employment.

In the context of the Provincial Policy Statement, Growth Plan, Region of Durham Official Plan, Town of Whitby Official Plan, Draft PPS (and the Proposed Implementation Approach), as well as the previously submitted Planning Justification Report, in our submission redesignating the lands to Community Areas is appropriate. Accordingly, it continues to be our opinion that the RioCan Lands are appropriate for a Community Areas designation, and suggest that the Map 1 of the New Region of Durham Official Plan be modified to redesignate the RioCan Lands to Community Areas from Employment Areas.