Re: ERO #026-0551 – Proposed…

Re: ERO #026-0551 – Proposed Minister’s Zoning Order for 2155 Country Club Drive and 4274 Dundas Street, Burlington

I am a long-time Burlington resident and homeowner in the Millcroft community. I appreciate the opportunity to comment on this proposal.

I want to be clear that I support responsible housing development. Ontario needs more housing, and Burlington will continue to grow. My concern is not about growth itself. My concern is whether a Minister’s Zoning Order is justified in this case.

The Province has said its goal is to build more homes, build them faster and ensure communities have the infrastructure needed to support that growth. I support those objectives. However, I am not convinced this proposal demonstrates that an MZO is necessary to achieve them.

The Province states that this MZO is intended to expedite housing approvals. Yet Phase 1 of the Millcroft redevelopment has already received planning approval, while Phase 2 continues to move through Burlington’s normal planning process. Based on the publicly available information, it has not been demonstrated that planning approvals are the primary barrier preventing homes from being built. If approved projects are not yet under construction, why is another extraordinary planning approval necessary?

This proposal would also override Burlington’s Official Plan and existing zoning for lands currently designated primarily as Major Parks and Open Space, while exempting downstream approvals from the Provincial Planning Statement and the City’s Official Plan. These planning documents exist for a reason. They represent years of technical work, public consultation and long-term planning. Before setting them aside, the Province should clearly demonstrate why doing so is in the broader public interest.

The Ministry has specifically asked for comments regarding environmental risks and financial impacts on the municipality. Those issues deserve careful consideration. Burlington has publicly expressed concerns regarding environmental matters associated with this proposal, including regulated lands and the need for further technical review. Once an MZO is issued, opportunities for municipal planning review become much more limited. Questions relating to stormwater management, flooding, environmental impacts and long-term infrastructure should be fully addressed before extraordinary provincial authority is exercised.

I am also concerned about the financial implications for the City of Burlington. New development requires roads, stormwater infrastructure, water and wastewater services, parks, emergency services and ongoing maintenance. These are long-term obligations. Before overriding the City’s planning framework, the Province should clearly demonstrate how these costs will be managed and whether they will ultimately be borne by existing taxpayers.

One fact deserves particular attention.

The City of Burlington has publicly stated that it can achieve its provincially assigned housing targets through its existing planning framework while preserving the remaining Millcroft greenspace. City Council has gone so far as to ask the Province to protect these lands rather than approve the requested MZO.

Whether one agrees with the City’s position or not, I believe it deserves significant weight. The City is responsible for managing growth, maintaining infrastructure and implementing the planning decisions that will affect Burlington for decades to come.

I also believe this proposal should be measured against the Province’s own stated objectives. The Ontario government has repeatedly emphasized building homes, supporting housing with appropriate infrastructure and reducing unnecessary delays. Those are important goals. The question is whether this MZO has been shown to advance those goals better than Burlington’s existing planning process.

That leads me to one question that I believe sits at the heart of this application.

If the City of Burlington has publicly stated that it can achieve its provincially assigned housing targets through its existing planning framework while preserving the remaining Millcroft greenspace, and if Phase 1 has already received planning approval, what compelling provincial interest justifies overriding Burlington’s Official Plan and exercising one of Ontario’s most extraordinary planning powers in this case?

Until that question can be answered with clear, evidence-based justification, I respectfully submit that the requested Minister’s Zoning Order should not be approved.

Thank you for considering my comments.