1) Not providing the six missing intensification numbers in the official plan results in non compliance to Places to Grow Act 2.2.8.2 a) (See Hemson, “Housing Analysis and Employment Land Needs, Final Report” Table 2).

Places to Grow Act 2.2.8.2 a) “a settlement area boundary expansion may only occur…where it has been demonstrated that – a) sufficient opportunities to accommodate forecasted growth …, are not available.”

2) By removing 70% of apartments from the greenfield lands the Official Plan is in non compliance to Places to Grow Act 2.2.8.2 b) & c) (See Hemson, “Housing Analysis and Employment Land Needs, Final Report” Table 6).

Places to Grow Act 2.2.8.2 b) “the expansion makes available sufficient lands for a time horizon not exceeding 20 yrs.”

And

Places to Grow Act 2.2.8.2 c) “the timing of the expansion and the phasing of development within the designated Greenfield area will not adversely affect the achievement of the intensification target and density targets, and other policies of this Plan”.

3) Removing apartments from the urban boundary expansion lands fails Places to Grow Act Section 2.1.

Places to Grow Act Section 2.1 “This plan is about building complete communities, whether urban or rural. These are communities that are well-designed, offer transportation choices, accommodate people at all stages of life and have the right mix of housing, a good range of jobs, and easy access to stores and services to meet daily needs”.

York Region has identified apartments in the expansion lands, the Vaughan Official Plan removed these and added more housing units then what the Region allocated. (See Hemson, “Housing Analysis and Employment Land Needs, Final Report” Table 8 & Table 5: York Region 2031 Whitebelt Area Unit Requirement by Structure Type and Local Municipality).

4) An urban boundary expansion is being proposed without any analysis of whether or not the proposed lands can accommodate development in an environmentally  sustainable manner at the proposed densities. The expansion is being approved by Vaughan Council with justification to follow at some unknown date. In the spirit of the Places to Grow Act, we believe this process should be reversed. A study must be conducted first as to the feasibility of developing these lands.

Lands identified for residential urban boundary expansion in Vaughan (Blocks 27 & 41) are fragmented by greenbelt lands and other natural heritage features. These lands are headwater areas of the Don and East Humber River. This area is home to the endangered Red Side Dace, in addition to many threatened species of flora and fauna such as Butternut trees. The portion east of Highway 400 is also an important linkage area to the Oak Ridges Moraine from the Don River.

Development on this land at the 70 persons and jobs per hectare (as mandated by Places to Grow Act) must be demonstrated to not threaten the greenbelt and endangered red side dace habitat.

Places to Grow Act Section 2.2.8.2 d) “where applicable, the proposed expansion will meet the requirements of the Greenbelt, Niagara Escarpment and Oak Ridges Moraine Conservation Plans”.

5) In addition, the City has not conducted the necessary studies to show how an expansion will occur on the prime farmland located on these two blocks. Agriculture is an existing use on these lands and a recently completed LEAR show that some of the highest rated agricultural lands in York Region are in the areas designated for urban expansion in Vaughan.

Places to Grow Act 2.2.8.2 f) “in prime agricultural areas: ii. There are no reasonable alternatives that avoid prime agricultural areas. and g) “impacts from expanding settlement areas on agricultural operations which are adjacent or close to the settlement areas are mitigated, nor Section 4.2.2.1 “will identify prime agricultural areas…and where appropriate, develop additional policies for their protection.