We act for the owners of…

Aird & Berlis LLP acts for the owners of lands municipally known as 218 Powerline Road in the City of Brantford. We appreciate the opportunity to make a submission to the Minister regarding the City of Brantford Official Plan, which was adopted by Council on March 23, 2021.

For the reasons set out in the enclosed letter, it is our submission that:

(a) the Minister of Municipal Affairs should amend the Brantford Official Plan by adding an additional 55 hectares of settlement area land; and

(b) 218 Powerline Road (and the C9 Potential Expansion Block more generally) represent the best location to accommodate the additional growth needs of the City of Brantford.

Through revisions to the Provincial Policy Statement, Growth Plan, and Land Needs Assessment Methodology, the Province has made clear that a municipality must adopt a market based approach to planning and housing growth in order to meet current and projected land needs. The Brantford municipal comprehensive review did not properly follow this clear Provincial direction. Accordingly, the resultant Official Plan is not consistent with the Provincial Policy Statement, and does not conform to the Growth Plan.

Malone Given Parsons are leading professional planners with particular expertise in the Province’s Land Needs Assessment Methodology. They have conducted a Land Needs Assessment on the City of Brantford following entirely the current required methodology from the Growth Plan. Their analysis, which is summarized in the enclosed letter, demonstrates a need for an additional 55 hectares of community area above and beyond the settlement area expansion included in the municipally adopted Official Plan.

We submit that 218 Powerline Road, and the other lands in the C-9 potential settlement area block (approximately 55.3 hectares of potentially developable land) should be included within the Settlement Area boundary. Block C-9 is the next logical area to be included beyond the currently recommended Settlement Area. It is entirely appropriate, and is good planning, for 218 Powerline Road, and Block C-9, to be included as part of the Settlement Area Boundary.

As set out in more detail in the attached letter, the Brantford Official Plan is not consistent with the Provincial Policy Statement, and does not conform with the Growth Plan. As a remedy the Minister should modify the proposed Official Plan by adjusting the Settlement Area boundary to include the additional 55 hectares necessary for the density target to meet the appropriate level of 50 persons and jobs per hectare. Doing so is in the public interest, as the Province will ensure that housing in the City of Brantford meets the needs and wants of its residents.

It is further submitted that the Subject Lands represent the best and most appropriate location for accommodating additional community area land to provide for a sufficient supply of housing to 2051.

We thank you in advance for considering this submission, and for the opportunity to participate in this consultation process.