Why the rush? Facts show our current OP is up-to-date, exceeding provincial growth targets

Burlington downtown parksAnalysis & Insight — I’ve analysed the arguments given for adoption of the new Official Plan, including that the review has been under way for seven years, our current plan is outdated, we need to meet provincial growth targets, and the Ontario Municipal Board approval of the ADI tower at Martha/Lakeshore proves our plan is outdated.

The facts in each case suggest a different conclusion, namely that our current plan does meet and exceed provincial growth requirements, and though the OP review has been underway for a number of years, the most dramatic changes haven’t been. Precinct changes to the downtown plan, which allows up to 27 new towers, has been underway less than a year. The Area Specific Plan for the downtown isn’t complete. The Mobility Hub plans for the three GO stations, which will see thousands of new residents (but not enough parkland and community amenities), aren’t complete yet.

Analysis shows we’re exceeding growth targets under our current plan, our current plan has been regularly updated to incorporate provincial growth policies, and we’ll have to chase our plan with amendments after Halton Region updates its official plan and we need to conform.

So why the rush to overintensification?

An analysis of these points is outlined in more detail below.

We’re exceeding growth targets under our current plan

Multiple analysis by staff have also shown that we are not only meeting provincial growth targets under the existing Official Plan, we are set to exceed them by 2031, and have already surpassed the 2026 projected growth.

A city-wide analysis by staff of growth included in the Sept. 15 Council information Package (link below) noted that the Region’s Best Planning Estimates allocated to Burlington a population of 182,034 by 2026. Burlington’s population in 2016, according to the Census, had already surpassed that number with 183,000 residents. According to the staff report, Burlington is expected to “exceed the 2031 population forecast well in advance of 2031.”

Council Information Package Sept. 15, 2017: City Wide Population and Built-up Area Residential Unit Growth Analysis

We are set to exceed the recommended 1% per year growth

A recent report from the city manager recommends 1% population growth per year, which is also supported by the Conference Board of Canada as a suitable growth target. We are set to exceed that number also.

We are at 183,000 residents according to the 2016 census; 1% growth per year till 2031 would put us at roughly 212,456.

According to a staff presentation at a recent town hall, the proposed plan is expected to deliver 236,000 residents to 2031, well beyond this recommended 1% per year target.

Downtown meeting growth targets

The downtown needs to achieve 20,920 people and jobs by 2031 to meet provincial growth targets.

An analysis by staff included in the Sept. 8 Council information Package (link below) noted that the existing people and jobs count (according to the 2016 Census) is 16,379. Projects currently under construction will increase that number by 1944 people and jobs; approved projects under site plan review will increase that number by another 178 people and jobs, increasing the population to 18,562.

Applications under consideration (but not approved) could add up to 964 additional people and jobs.

The city can achieve its targets downtown with roughly 60% of proposed applications. So, we don’t need to change our current plan and overintensify on specific sites to meet provincial growth policies.

Our existing plan has been regularly updated to incorporate provincial growth plans

We’ve been told the existing OP is outdated and we need the new plan to conform to provincial mandates around growth. However, a staff review of our intensification history and updates to our current plan reveals otherwise.

Our existing Official Plan dates back to 1994, but has been regularly updated over the years to incorporate provincial growth plans.

In an intensification review contained in the staff report on the 23-storey tower at 421 Brant Street, staff outlined how the existing OP was updated in 2006, 2007, 2008 and 2009 to conform to provincial growth requirements introduced in 2005. These updates are detailed in Report PB-62-17, pp 17-19. The relevant section of the report is cut and pasted below.

“City of Burlington’s Intensification Strategy

Since the inception of the Provincial Growth Plan in 2005, Burlington has been developing a comprehensive intensification strategy to conform to the Growth Plan and achieve its density targets, as outlined below.

2006 – Official Plan Amendment 55

In 2006, Burlington staff refined the boundaries and population and employment estimates for Burlington’s Growth Centre in consultation with the Ministry of Public Infrastructure Renewal (MPIR), as part of the City’s Official Plan update (OPA No. 55). Burlington’s Urban Growth Centre analysis estimated a residential intensification increase of 2,200 dwelling units that would support an additional 3,750 residents by the year 2031.

2007 – Official Plan Amendment 59

Planning staff provided an update on various provincial, regional and municipal initiatives and provided an overview of the City’s intensification strategy which was approved by City Council on October 1, 2007. These initiatives included the following:

  • OPA 55;
  • GO Station Intensification Opportunity Study (which informed OPA 59 & Zoning By-law 2020-213);
  • Analysis of Intensification Potential (corridors, key sites, accessory units, infrastructure); and,
  • Implementation Measures (OPA/Rezoning, Design Guidelines, Infrastructure Improvements).

OPAs 55 and 59 included a series of amendments to the Official Plan that identified the Urban Growth Centre boundary; strengthened the policies for Mixed Use Centres and Mixed Use Corridors which serve as intensification areas; added policies for accessory dwellings units; addressed intensification around GO Stations and established a strategic approach to planning for and accommodating intensification within the built boundary.

2008 – Burlington Intensification Study

In 2008, Planning staff prepared the Burlington Intensification Study (Staff Report PL-1/08) with Preliminary 2031 Residential and Employment Intensification Estimates. This staff report described the components of residential intensification in Burlington which included the Urban Growth Centre, Urban Growth Corridors, Uptown and Regional Malls, low density infill and accessory dwelling units.

2009 – Official Plan Amendment 73

Following the completion of the 2008 Official Plan Review and the approval of OPA 73 in 2009, which included the City’s population forecasts to 2031, the City’s Official Plan policies presented a comprehensive and strategic approach to intensifying the two Mixed Use Centres (Downtown Burlington and Uptown) as well as a series of intensification corridors identified as Mixed Use Corridors. Staff notes that OPA 73 is currently under appeal, but the City’s population forecasts to 2031 are included in ROPA 37 which was not appealed and therefore the City’s forecasts were approved by the Region of Halton.”

Conclusion: Our existing plan anticipates and has been updated along the way to meet and exceed our growth requirements. There’s no need to rush adoption of the proposed Official Plan to conform with provincial plans, as the city has  been updating our plan along the way.

Review sought of ADI decision on Martha/Lakeshore because our OP conforms

We’ve also been told that the OMB decision granting the 26 storey tower at Martha and Lakeshore determined the city’s downtown plan was outdated, and so that’s why we lost the appeal. In fact, city evidence presented to the board was that the site could accommodate more height than what was in the current Official Plan, suggesting 11 storeys versus the 4-8 storeys in the plan.

In the absence of planning evidence for the alternative height proposed, the board went with the applicant’s plan. [Clauses 107,111,114,115]

Thus, the decision simply reflected back to us the evidence the city provided at the hearing, rather than the board independently concluding our Official Plan was outdated.

The relevant sections of the decision state:

“[107] The far more compelling evidence is that all of the land use planners and both urban designers testified that the Subject Site is not only suitable for development at heights that exceed the as of right four-storey height but is also suitable for development at heights that exceed the discretionary eight-storey height. In other words, all of these experts agreed that the Subject Site is suitable for development that is more transit-supportive than the four-storey, as-of-right OP designation.

[114] …Although the Board had clear evidence that the Subject Site is suitable for development in excess of the current OP designation, the Board had no expert planning evidence to assess the differential, if any, in the relative compatibility with and impacts on surrounding land uses between the proposed development and any of these alternate heights.

[115] Taken together, the evidence suggests to the Board that the current OP designation is no longer appropriate for the Subject Site and a proposal that is taller and more transit-supportive is both preferable and better implements the transit-oriented and intensification policies of the PPS 2014 and the GGH 2017.”

Furthermore, the city has requested a review of this decision, and one of the key arguments is that our plan is up-to-date. Read review letter the city sent to the board. The letter states the board made a “manifest error” in approving ADI’s application, and the board’s decision “ignores entirely the comprehensive planning exercise that the City undertook in order to conform to the Growth Plan and the direction provided by City Council through the Official Plan as to how and where growth should occur in the Downtown…The application must be judged within the contextual framework of the City’s Official Plan, which has long since implemented the direction of the Growth Plan.”

Our OP won’t conform to provincial plans until 2022, will require updating

Because Halton Region is our approval agency, we must first conform to the Region’s plan (which needs updating itself, scheduled for 2020), then to  provincial plans. Our new OP won’t entirely conform to provincial plans until the Region brings its own plan into conformity with provincial plans. The window to complete this conformity work is 2022.

Once the Region’s next Official Plan is approved Burlington will commence another Official Plan review to ensure conformity to the Regional Official Plan (source: Appendix P, Feedback and Staff Response p 5, para 8)

In addition, the planning horizon for our plan is to 2031, whereas new provincial plans are to 2041, and we haven’t received new growth numbers from the Region. These conformity matters are outlined more fully in staff report PB-04-18 on the April 24 agenda (pp 5 & 23).

So, why not wait till the Region conducts its work, rather than chasing our proposed OP with subsequent amendments to conform with updated provincial policy and the new Regional Official Plan?


Written by Marianne Meed Ward

A Better Burlington began in 2006 after my neighbours said they felt left out of city decisions, learning about them only after they’d been made.

As journalist for 22 years, I thought “I can do something about that” and a website and newsletter were born. They’ve taken various forms and names over the years, but the intent remains: To let you know what’s happening at City Hall before decisions are made, so you can influence outcomes for A Better Burlington.

The best decisions are made when elected representatives tap the wisdom of our community members, and welcome many different perspectives.This site allows residents to comment and debate with each other; our Commenting Guidelines established in 2016 aim to keep debate respectful.

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  1. The facts and reason don’t seem to count much with our current council on their apparent race to embrace over-intensification and enshrine it in a new OP. The average citizen is also wondering why, and becoming angry or cynical in the process. Hopefully, this situation will be turned around on October 22nd.

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