Climate Action London is a…

Climate Action London is a grassroots volunteer group in London focused on our collective response to the Climate Emergency. Urgent climate action is necessary to prevent catastrophic and irreversible damage to our planet and secure a liveable future for all generations. This is not a far off crisis. We are currently experiencing many impacts of a warming planet. The impacts from a loss of natural areas,a loss of farmland and continuing to reinforce car-dependent development are being felt now. A continuation of these patterns puts us at risk of greater negative impacts in the future.

With respect to the request for an Official Plan Amendment (OPA 166) from the City of London in which it proposes to expand the Urban Growth Boundary for the City of London by redesignating select lands to accommodate both future residential and industrial growth over a 30-year planning horizon to 2054 we offer the following comments.

We strongly oppose the current request to amend the official plan from the City of London on the following grounds;

1. The underlying population estimates used for the land needs assessment were too aggressive (too high) to begin with and are now significantly out of date based on more recent information that shows even lower population growth. The first draft of the land needs assessment by staff forecasted a significantly smaller UGB expansion as it used current housing densities and types in London rather than historical. The final version of the report altered the forecast to dramatically increase the requirement of lands needed for development. The proposed expansion is based on a significantly too high population increase projection. A motion put forward by Councillor Franke on October 7,2025 to revisit the Urban Growth Boundary using updated population projections (Attachment 1) was rejected but makes a legitimate point. By NOT using the most current data and the best quality of evidence, which is significantly different from the data used in the initial proposal, the request as submitted is not made based on sound planning practices.

2. The request is contrary to the primary pillars of the City’s own official plan. Based on the London Plan documents and the City of London’s own website (Supporting link below: https://london.ca/government/council-civic-administration/master-plans-…. Also included as Attachment 2 (screen capture) London emphasizes growing inward and upward, protecting farmland, reducing greenhouse gases and energy consumption. The unnecessary magnitude of this expansion is directly contrary to the official plan. There are sufficient lands within the current urban growth boundary to accommodate 25 years of growth.

3. There was no prior consultation with First Nations on land use planning that may negatively impact First Nations land and treaty rights. We do not speak on behalf of any First Nations however attached is a letter (Attachment 3) by the Chippewas of the Thames First Nation that was included in the Public Participation Meeting on June 3,2025 that indicates that they were not consulted and have concerns in relation Minister Zoning Orders where they are removed from consultations. We believe that a review should be completed to determine if there was a violation of the municipal duty to consult (see link 2 below: CBA reference https://www.cba.org/sections/municipal-law/resources/municipal-duty-to-…).

4. Land within the current urban growth boundary that removed from the Land Needs Assessment should have been considered. The draft excluded 300 hectares from the City's vacant land inventory pending completion of an Environmental Assessment (EA). This EA for Dingman Creek is nearing completion and the equivalent 300 hectares will be added according to staff at a recent Public Update Meeting (Link 3 below: https://getinvolved.london.ca/dingmancreek)(YouTube https://www.youtube.com/watch?v=fzHIzAVNUJc)

The magnitude of the unnecessary additional land included in the Urban Growth Boundary expansion will undoubtedly lead to leapfrog development. Despite developer representatives stating the newly included lands won’t be developed for years, the historical experience locally and elsewhere in Canada indicates that leapfrog development will occur where developers will bypass contiguous land and build farther out. This leads to a significant loss of nature and farmland. It will also lead to inefficient and costly infrastructure requirements that are not covered by development fees. London is already one of the most car dependent cities in Canada and this will only make the problem more pronounced which will result in an increase in Greenhouse Gas emissions. All of these impacts are contrary to the London Plan and sound planning decision-making.

We recommend that the current request be rejected and that the City re-engage in the process of prior consultation with First Nations regarding their concerns and that a new land needs assessment be established based on up-to-date population estimates, current housing density trends and an updated calculation of land available for development within the current urban growth boundary.