Builder's association not prepared to support the draft OP because it doesn’t provide the information their members need to do business here.

News 100 blueBy Staff

September 8, 2017



Susan HHHBA 2

Suzanne Mammel Executive Officer Hamilton Halton Home Builders Association

Suzzane Mammel is a pretty direct woman; trained as an engineer, she was dealing in planning matters before a city council committee when she made the point that her association Hamilton Halton Home Builders, “can’t be supportive of this OP, because it doesn’t provide the information our members need to do business here.

“We applaud the efforts to have a new Official Plan that meets the needs of all parties, this isn’t it.
This was basically the theme that came through her presentation to city council – it isn’t complete – far from it and the time line in place to get it complete is far too short.

Mammel, the Executive Officer of the Hamilton-Halton Home Builders’ Association, explained that they spent considerable time reviewing the document, meeting with staff, and providing comments, both on big picture and detailed issues.

Mammel was telling city council and staff that “the OP is important to how the City grows in the future, and it’s very important to get it right.”

“We are very supportive of the City’s initiative to create a new official plan that guides how our City continues to grow in the years to come, and addresses the new realities the City is facing: growth via intensification versus the greenfield type of developments that have dominated in recent decades, and new mandated growth targets and densities imposed by the Province to meet the Growth Plan.

Project - banner -

The city has a lot on the go – many are asking if the Planning department has bitten off more than they can chew.

“We recognize that this is a bit of a daunting task. The policies need to firstly meet these mandated targets, and those from the Regional OP, while at the same time attempting to balance the needs and desires of the City’s businesses and residents, residents like me. In a letter to this committee in June, I noted that “we believe that the title of the document “Growing Bold”, and its correlation to similar themes under the City’s strategic plan are applaudable but must be unapologetic, and guide future applicants to successfully provide economically feasible, quality developments that are in keeping with big picture City goals, and that marry the City’s vision with the growth targets mandated by higher order government.”

Our membership need a strong and solid document that directs how growth should occur.
There are many moving parts, and it is not as easy as an outsider may think. She added that the mandated time frame staff was given to bring this draft forward resulted in an OP that is incomplete.

James Ridge Day 1 - pic 2

Burlington city manager James Ridge

“One of the initial comments and concerns we raised, and the biggest concern with this draft document, was a lack of critical information: information that if absent in the OP, does not provide the level of detail required by any applicant to understand if they are in conformance with an OP. I asked for it formally and in writing of staff. I noted it in a meeting I had with the City Manager and Director of Planning in June, and I noted it in my formal submission to this committee at the end of June.

“ What population growth has been achieved to date (relative to the targets set in the Regional OP and the densities set for urban growth centers and mobility hubs in the original and updated Growth Plan), what remains to achieve these targets and where will that growth occur. We understand this information is being developed but believe the information is absolutely critical before finalizing the mobility hub Area Specific Plans or the Official Plan”
“To date this information has not been provided, nor am I aware that it is available” she said. “There has been an attempt to address it – we’ve been referred to reports done to support specific OMB appeals with respect to downtown, and anecdotally we’ve been told such things like – we’re confident we’ll reach the numbers.


A critical document – are we getting it right?

This just isn’t good enough. It is critical to getting this whole thing right and therefore should be foremost in the approach to the OP and included in it in a clear and obvious way, like it is in the Official Plans of our neighbours like Hamilton and Oakville.

While there is a lot of policy and vision included in the document, what good is it if it fails to achieve the mandated growth? It begs the question: why was it not included?

This is a new and full OP, and should be the document in which this information is contained. It will be the document of reference in the future. It generally indicates that growth is to be directed firstly to the downtown – being the urban growth centre, the three remaining mobility hubs, uptown, and then corridors, and to a lesser extent, modest intensification into existing neighbourhoods. What it fails to answer is those critical questions I noted a couple minutes ago, including what portion of growth should and will be apportioned to each of these areas.

The approach of directing growth to the areas chosen is a good one. We are mandated by the Province to have a minimum level of density in the urban growth centre, and mobility hubs – it is economically appropriate to direct densities to those significant investments. But the big picture numbers to make these areas successful are not available.

How can we move forward with detailed studies, like is happening in the mobility hubs, without knowing if those concepts are achieving the required minimum targets we are expected to achieve?

Tanner and Taylor at June 21-17 workshop

Mary Lou Tanner, educated as a geographer and now the Chief of the Planning department has more on her plate that many in the development business feel can be done within the tie frames in place. She explains a point to Councillor John Taylor

Which refers me back to the daunting task. Some have and will say, the City has put the cart before the horse. The process taken elects to do things concurrently, which in theory may be fine. I acknowledge that we are in a state of flux, but that is not justification for not including any substantiating detail.

But without these big picture numbers, there is no ability for an applicant to understand if they are in conformity with the OP, if decisions made by a proponent on densities proposed are appropriate, too much, or too little, or what the justification is for a decision made by the City when advising an applicant has got it wrong.
When you combine these with the provincial landscape, changes to the Planning Act that prevent an OP amendment to be submitted within two years of the date of this OP being approved, and the likelihood of changes to the OMB which would limit appeals to those decisions which lack conformity to the OP, it is even more critical that this base information be provided.

Mobility hubs

The mobility hub concept was to be the way the Official Plan would be implemented – some developers think the city has put he cart before the horse.

Detailed land use permissions are being envisioned through the Mobility Hub study – which is essentially a secondary planning process. This is appropriate. This is a finer level of detail than an OP. The draft document itself says “the Official Plan provides high level direction on land use, built form and density ranges”, which I note are not provided.

Arial of city with Hamilton Harbour

An aerial look at the west side of the city with Hamilton Harbour in the background.

However, in many instances, the document strays from this intent and as noted numerous times above, is lacking in critical information, at other times it delves into the minutiae of development issues, that are better left for such documents as a site specific zoning bylaw or a site plan guideline.

Sometimes a little dose of sarcasm is needed to make a point.  Mammel pointed out that the level of detail in an OP could render an application out of conformity, and with no recourse to amend or appeal, given the current situation we are in, details such as site lighting, fencing and loading dock locations, are “I hope we can all agree, not Official Plan level issues.

The reality said Mammel is that “we can’t be supportive of this OP, because it doesn’t provide the information our members need to do business here, to understand what will be required of them.

Andrea Smith

Andrew Smith the planner tasked with the writing of the Official Plan that is currently in draft form. The time line they have given Smith is seen as far too tight.

Staff require more time to put together a fulsome document. But there seems to be a systemic problem here – the approach and timelines currently being applied to all significant changes being undertaken by the Planning Dept. It is frankly too rushed.

We have respectfully asked for details, rationale, and justification through many of these processes, including the Official Plan. But time hasn’t allowed, and the formal documents are rushing forward. The concern is this: whether it be the OP, concepts for Mobility Hubs, or any other document introduced to the public, the public perceives it to already have that substantiation and justification complete and available. And it isn’t.

“We are asked to comment and consult, yet the information we require to do a proper job isn’t available to us. It puts us in a very difficult position. And it is making our members feel that their input and comments are irrelevant – because the end product is made public before that background information can be reviewed and vetted.”

In summary, “while we applaud the efforts to have a new Official Plan that meets the needs of all parties, this isn’t it. We are not able to support a document that has the significant gaps and concerns this one currently does.”

Mammel is pleased that there is going to be a second draft – “today is the first time I heard that – we’d previously been told the next step is intended to be the final document”

The only firm date is that the final version is to be approved is November 28th.

Not only is the HHHBA not prepared to support the OP as it stands – she advised council that, her association would appeal the plan unless considerable amendments are made in advance of it being approved by this committee and council.

That would be a line drawn in the sand.

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1 comment to Builder’s association not prepared to support the draft OP because it doesn’t provide the information their members need to do business here.

  • Jeremy Skinner

    It would be helpful if the Hamilton Halton Home Builders Association (HHHBA) would present or publish their list of information requirements and illustrations of potential project impacts so that the citizens of Burlington may better understand their concerns. It would also be useful to understand the composition of this association and typical building project interests.

    The suggestion that above quoted “what population growth has been achieved to date (relative to the targets set in the Regional OP and the densities set for urban growth centers and mobility hubs in the original and updated Growth Plan), what remains to achieve these targets and where will that growth occur” is simply too vague.

    Could this information exchange take the form of a public forum jointly hosted by representatives of the City of Burlington Planning Department and the Hamilton Halton Home Builders Association?

    Noting the “GO Bold” declaration of “only five to six per cent of Burlington will be targeted for growth with a variety of building sizes, types of housing, jobs, transportation, shops, recreation, and services. Established neighbourhoods will see some change, but it will be limited and that growth will not be required to meet the growth requirements of the Province” indicates the lack of land available for the construction new single and duplex housing.

    That being said, I believe that Burlington has an urgent need for affordable family (children-friendly) residence accommodations and appropriately configured empty-nester (with ample sized bedroom/living/dining/kitchen) residence accommodation. Mike Ridge was the City’s subject matter expert assisting the HDSB Burlington Secondary School Program Accommodation Review Committee in their deliberations. In summary, we are closing schools because we lack the sufficient number of households with school aged children to fill them.

    I also believe that we have a significant number of empty nesters living in family friendly homes who wish to continue to live in Burlington but lack suitably priced and configured accommodations with which to transition to.

    Some of these requirements could be satisfied through appropriately priced and configured rental and/or condominiums in mid-rise and/or tall tower developments.

    Identifying Zones of Intensification in City of Burlington Official Plan documents have been mandated by the Province. These, by definition, are designed to promote mixed-use (retail, commercial, residential) development opportunity projects on lands which are deemed as under-developed.

    A total of six new zones of intensification has been identified in the proposed new Official Plan. They include: the lands which surround each of the three GO Train stations (Aldershot, Burlington & Appleby) on the Lakeshore West GO transit corridor; the Downtown Mobility Hub (essentially the east side of Brandt St. from Lakeshore to Fiarview; the Fairview retail corridor; and the Uptown Centre (Appleby and Upper-Middle Road).

    This is in addition to most of the existing large retail plaza properties which have already designated as zones for intensification in the existing Official Plan.

    Unfortunately, land suitable for single/duplex home development has already been spoken for except for some infill developments such as school closures. As such, the development emphasis going forward is to build up and/or combining residences with retail/commercial uses within common mid-rise or tall building structures. However, mixed use developments may pose challenges to some property developers who tend to specialize in one as opposed to multiple building (residential / retail / commercial) uses.

    The HHHBA could seek to negotiate with City Council for the adoption of zoning changes to permit the replacement of single and/or duplex residential properties along specified major and minor arterial roads for townhomes; stacked retail/townhomes; and/or stacked commercial/townhomes development. However, any such zoning changes would require negotiations amongst representatives of the affected residential neighbourhoods.

    Regardless of development type is being proposed, residential neighbourhood transition guidelines including sun/shade angular plane step-backs, building setbacks, etc. must be respected and adhered to. Lest there be significant NIMBY responses.

    P.S. I am a concerned Burlington resident who lacks formal land use planning training and certifications.