Attn: Honourable MPP Paul…

March 28, 2024

Ministry of Municipal Affairs and Housing
777 Bay Street
Toronto, ON
M5G 2G2

Attn: Honourable MPP Paul Calandra
Minister Municipal Affairs and Housing

Re: Schlegel Urban Developments (Township of Woolwich- Elmira and St. Jacobs)
ERO # 019-8273
Get it Done Act, 2024 – Amending the Official Plan Adjustments Act, 2023

Dear Minister Calandra:

On behalf of our client, Schlegel Urban Developments, I am writing to provide commentary on the
ERO posting of the Get It Done Act, 2024 - Amending the Official Plan Adjustments Act, 2023.
Further to the previous correspondence submitted to MPP Steve Clark through ERO #019-5952
January 4, 2023 regarding ROPA 6 (see attachment 1), I am requesting that the lands in Elmira and
St. Jacobs be prioritized for housing approvals. I agree with the December 5, 2023 submission by
the Township of Woolwich Mayor and endorsed by Township Council regarding the settlement area expansion for residential development in Elmira and St. Jacobs (see attachment 2).

However, Woolwich Official Plan staging and phasing policies restrict development of these lands.
Implementing a Settlement Area boundary adjustment is not sufficient to ready the lands for
residential development. The lands have sufficient servicing and are contiguous to existing
development. Appropriate planning approvals (e.g. Draft Plan of Subdivision) will ensure that they
are planned in accordance with good planning principles and consistent with the Provincial Policy
Statement, providing for housing choices within a complete community. In the absence of the
staging and phasing policies, construction could start as early as 2025 and could help achieve the
2031 housing targets.

The Township of Woolwich Official Plan staging and phasing policies predate the Places to Grow
Growth Plan for the Greater Golden Horseshoe. Of note, the 2023 MMAH decision on ROPA6
introduced policy 2.J.12 which required the Township of Woolwich to review and update its staging
and phasing of development policies in Elmira to expedite development applications for housing
projects. Thus, the previous MMAH decision therefore appropriately recognized that the phasing and staging of development policies in the Woolwich Official Plan are in need of an update.

While I agree with the principle of orderly growth (no leap-frogging, for example), the Woolwich
staging and phasing policies preclude applications from advancing and prevent Township housing
targets from being achieved. The existing staging policy creates a condition of uncertainty for the subject lands (e.g. during the period until the Woolwich OP is updated and the manner in which the
Woolwich OP may update its phasing and staging policies).

As such, I request that the Province modify ROPA6 to provide site-specific exemptions to the
subject lands in Elmira (see attachment 3) and St. Jacobs (see attachment 4) from the
phasing and staging policies of the Township of Woolwich Official Plan to facilitate
expediting their residential development.

Thank-you for your thoughtful consideration and commitment to the timely building of homes, seniors housing and well-planned residential communities in this Province.

Sincerely,
GSP Group Inc.

Heather Price, MCIP, RPP
Vice President, Development Planning Manager
Encl. (4)