Comments on behalf of 218…

Comments on behalf of 218 Powerline Road:
Request for Inclusion of the C9 Potential Settlement Area Boundary Expansion to achieve a market-based supply of housing to 2051

Malone Given Parsons Ltd. (“MGP”) is the planning consultant for the owners of 218 Powerline Road. The property is located in the C9 potential settlement area boundary expansion that was considered by the City as part of its Municipal Comprehensive Review process.

This letter (attached) requests that the Province revise the City’s Official Plan to include the C9 area within the Settlement Area Boundary to 2051 and revise the Natural Heritage System policy to allow further refinements based on fieldwork.

To achieve a market-based supply of housing to the extent possible, the City should have used a Designated Greenfield Area density of 50 persons and jobs per hectare (as opposed to the density of 52 used in the adopted Official Plan) to match the minimum target required by the Provincial Growth Plan. Using the slightly lower density would enable the city to provide a market-based supply of housing to the extent possible while still conforming to the Growth Plan.

The Land Needs Assessment Methodology of the Growth Plan REQUIRES that settlement expansion calculations be based on a Market forecast. That market forecast is to be adjusted ONLY TO THE EXTENT NECESSARY to meet the density target in the Growth Plan (i.e. 50 units and jobs per hectare). By going past that target, the resulting mix of housing is more of a departure from the Market forecast than is necessary. Alternatively, the housing mix from 2016-2051 could have been adjusted to more closely reflect the market-based forecast while still achieving policy targets.

Thus, in our opinion, the Official Plan is not in conformity with the Growth Plan for the Greater Golden Horseshoe, its Land Needs Assessment (“LNA”) Methodology and the Provincial Policy Statement for Land Use Planning requirements for a market supply of housing. This is easily remedied by an adjustment to the Greenfield Density to the 50 jobs and people per hectare contemplated by the Growth Plan.

This density adjustment requires the housing mix to be adjusted and would necessitate additional land to accommodate the housing required to 2051 that would at least necessitate the inclusion of the C9 expansion area (55.3ha). It is our opinion that the C9 area is the next logical area to be included beyond that currently recommended settlement expansion, resulting in a complete and connected neighbourhood in the northeast area of Brantford.

Lastly, the City has not completed fieldwork or ground truthing for all of the Natural Heritage System, and in particular this work was not completed on the subject property. Consequently, we believe that the limit of the NHS cannot be finalized as part of the Draft Official Plan and the draft Official Plan policy (5.6.1 q) should be modified to allow refinements to the Growth Plan Natural Heritage System if supported by an EIS that completes the ground-truthing required to finalize the extent of this designation in the draft Official Plan.