This letter is submitted to…

This letter is submitted to respectfully request your support in re-opening the review of the proposed development of the Millcroft Golf Course in Burlington, Ontario.

Phase 1 of the development was approved by the Ontario Land Tribunal (OLT) in 2024, reference OLT-22-004149, authorizing the construction of 90 luxury residences currently priced between $2 and $3 million, exclusive of options and condominium fees. This approval also included condominium units on Dundas Street. It should be noted that the approved condominiums are not the subject of this request, as their location and land use are considered appropriate. The concerns set out herein pertain exclusively to the residential development on the former golf course lands.

We have reviewed numerous flood assessment reports submitted to both Conservation Halton and the City of Burlington, spanning October 1977, August 1985, October 1993, and July 1997. These reports consistently document the flood risks posed to the Millcroft community, south Burlington, and Oakville from Appleby and Sheldon Creeks. To mitigate these risks, certain lands within the original Millcroft subdivision were designated as open space for stormwater management purposes. Those lands subsequently came to serve as the golf course. Notwithstanding the implementation of the reports' recommendations, serious flooding has continued to affect Millcroft and south Burlington, most notably in 2014 and again in 2024.

Critically, none of the substantive flood risk evidence was presented at the OLT hearing. Bill 23 altered the mandate of conservation authorities, with the result that Conservation Halton neither submitted its updated floodplain mapping and reports nor testified at the hearing. By the time the City of Burlington and Millcroft Against Bad Development (MABD) were informed of this change in Conservation Halton's role and responsibilities, the opportunity to introduce flood photographs, updated floodplain mapping, and relevant reports had passed. Consequently, the OLT proceeded with materially incomplete information regarding flood risk in Millcroft and south Burlington. We are confident that, had Conservation Halton, the city, and MABD been permitted to submit and testify on this evidence, the Tribunal's decision would have been substantially different.

Furthermore, at the OLT hearing, the Applicant, Millcroft Greens Corporation, significantly understated the number of flooding incidents attributable to Appleby Creek — citing one incident where the documented record reflects 961. This material misstatement of fact, in and of itself, warrants a review of the Tribunal's decision. This concern is compounded by the fact that the City of Burlington is recognized as one of Ontario's municipalities most vulnerable to flooding. Many Millcroft residents are presently unable to obtain flood insurance; where coverage is available, it is prohibitively expensive. Additionally, the Applicant relied upon historical flooding data and failed to account for the projected impacts of climate change on future flood risk.

We also draw attention to the Applicant's proposed use of underground stormwater storage tanks, installed beneath homes and roads, as the primary flood mitigation measure. This technology has not been tested in a residential context situated on a floodplain. Given that many residents have already experienced flooding of their properties, we submit that it is unreasonable to subject this community to an unproven approach to flood management.

As of June 5, 2026, Millcroft Greens Corporation has submitted an application to the City of Burlington and a request for a Minister's Zoning Order (MZO) to the Province for Phase 2 of the development. This is particularly notable in light of the Applicant's testimony at the OLT hearing that there was no intention to develop beyond Phase 1 — testimony to the contrary of which MABD was formally reprimanded for raising, as referenced in the Tribunal's decision. Phase 2 is situated upstream of Phase 1; accordingly, any flooding associated with Phase 1 would be materially exacerbated by the proposed upstream development. Had the full scope of the development been known at the time of the hearing, it is reasonable to expect the Tribunal would have required significantly greater due diligence with respect to flooding impacts on the community, south Burlington, and Oakville.

It is further noted that Millcroft Greens Corporation testified at the OLT hearing that an 18-hole golf course would be retained. The submission of an application for Phase 2 renders this representation impossible, as the proposed development would occupy the remaining land on which such a course could exist.

While MABD wished to appeal the OLT's decision, no legal basis for appeal existed within the legislated timeframe. However, given the recent Phase 2 application and the request for an MZO, we respectfully request that the OLT's decision be revisited.

Enclosed with this letter are flood photographs of the precise lands Millcroft Greens Corporation proposes to develop. As characterized by Ron Foxcroft, this constitutes "tragic" development. MABD supports responsible and well-considered development — as evidenced by our position regarding the Dundas Street parcel — but cannot support development that will demonstrably increase flood risk and adversely affect tens of thousands of residents across Burlington and Oakville.

We respectfully submit that the OLT was presented with incomplete and, in certain respects, misleading information, and that the Tribunal's decision would not stand as rendered had all relevant facts pertaining to both Phase 1 and Phase 2 been before it.

In addition, we formally request that the MZO sought by Millcroft Greens Corporation not be approved, in order to allow the proper planning process to proceed. A thorough planning process — one that identifies and addresses deficiencies, incorporates responsible stewardship of the land, and reflects genuine community engagement — will command public confidence and uphold the integrity of democratic planning principles.

We would welcome the opportunity to meet with you to discuss these matters further, alongside representatives of MABD and/or Mr. Ron Foxcroft.