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TO: |
Mayor and Members of Council |
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FROM: |
Jim Baird, Commissioner of
Development Services Valerie Shuttleworth, Director of
Planning & Urban Design |
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PREPARED BY: |
Biju Karumanchery, Co-ordinator,
South District, ext. 2970 T.J. Lambe, Manager, Policy and
Research Division, ext. 2910 |
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DATE OF MEETING: |
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SUBJECT: |
RECOMMENDATION REPORT |
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Miller Paving Limited Applications for Official Plan
and Zoning By-law Amendments to permit a major shopping centre at the northeast
corner of FILES: OP.04-017217 & ZA.04-017225 |
___________________________________________________________________________________________
RECOMMENDATION:
THAT the record of the Public
Meeting held on October 19, 2004 with respect to the applications by Miller
Paving Limited for Official Plan (OP.04-017217) and Zoning By-law
(ZA.04-017225) amendments, to permit a major shopping centre at the northeast
corner of Woodbine Avenue and 14th Avenue, be received;
AND THAT the applications by Miller
Paving Limited for Official Plan and Zoning By-law amendments be refused.
EXECUTIVE SUMMARY
Refusal of the Applications is Recommended
This report outlines the fundamental policy issues related
to this proposal. Given the factors
noted, the report recommends that the
applications by Miller Paving Limited for Official Plan and Zoning By-law
amendments, to permit a major shopping centre at the northeast corner of
·
The supply of
land for industrial use in
·
The Industrial
designation of the Miller property, as adopted by Council in 2003, is
consistent with the need to ensure an adequate supply of industrial land;
·
the Industrial
designation of the property is consistent with the provisions of the Official
Plan, the Provincial Policy Statement and is now demonstrated to be consistent
with the strategy for the preservation and protection of industrial lands
identified by the Province;
·
The proposed
change in designation of the property is not consistent with the Town’s
Economic Development Strategy to establish, promote and support
·
There is
sufficient land designated in the Official Plan to accommodate retail
development and there is no compelling reason to designate additional land for
more large scale, retail development at this time;
·
·
The proposal is
not consistent with discouraging auto-oriented big-box retail development in
favour of other forms of retail development, to support a Strategic Priority of
Council to create a better quality of community.
Report Summary
The
lands subject to the current applications consist of approximately 20.47
hectares (50.5 acre) adjoining
The
Town has been actively engaged in a program to identify and designate
additional industrial land since 2000. Staff’s
analysis indicates that with, at best, a 5 to 6 year potential
land supply that might become available for industrial use, most of
which cannot be guaranteed to become market-ready, Markham cannot rely on there
being sufficient designated, marketable land to competitively address near term
need. Concurrently therefore, the potential land supply is also not sufficient to
meet a requirement of up to 20 years, as identified in the Provincial Policy
Statement. As part of the Town’s commitment to designate and preserve lands for
industrial use, Council adopted Official Plan Amendment No.112 in 2003,
identifying lands in the Highway 407/Rodick Road area, including the Miller
property, for industrial use.
Emerging Provincial policy confirms the
need to secure viable industrial lands and to assure that opportunities for
infill, and the redevelopment of underutilized lands, are actively pursued in
managing new growth. In February 2005,
the Province released the final version of the Provincial Policy Statement
(PPS), which came into effect on
There is a high demand for
industrial space in
Based on Council
requests over the last two years, staff undertook a review of
Finally,
in 2004, Council identified a Strategic Priority for 2004 to 2006 of “creating
a better quality of community”. In
support of this priority, identified by Council, an action to shift planning policies
to discourage auto oriented big box retail development and encourage pedestrian
friendly retail activity. The proposed
development incorporating significant big box components is not consistent with
supporting this Council priority.
This report outlines the fundamental policy issues related
to this proposal. Given the factors
noted in this report it is concluded that the preferred designation and
continued use of the property is industrial, and that the applications to change
the land use designation to permit large scale retail development should be
refused.
The report also notes that any
future redevelopment of the Miller property will require servicing and traffic
studies as well as a Phase II environmental site assessment since the property
has been identified as having some potential for contamination.
PURPOSE:
The purpose of this report is to provide a detailed review of the
Official Plan and Zoning By-law amendment applications submitted by Miller
Paving Limited to permit a major shopping centre at the northeast corner of
BACKGROUND:
The
lands subject to the current applications consist of approximately 20.47
hectares (50.5 acre) adjoining
The
subject property is bounded to the north by a Hydro Corridor and lands being
protected by the Province for a proposed future Highway 407 transitway, and
further north by lands owned by Magna International and Highway 407. The Hydro lands are currently being used for
storage and maintenance of York Region Transit vehicles and Miller trucks
(Figure 3). The subject property is
bounded to the south by an existing gas station located at the northeast corner
of Woodbine and 14th Avenues and further south across
Proposal is to Develop the Lands for a Major
Shopping Centre
The
applicant is proposing to develop the subject lands (20.47 hectares) with a
major shopping centre. To this end the
applicant has requested a redesignation of the subject lands to Commercial and
specifically the Retail Warehouse Area and the Major Commercial Area sub
categories. The remainder of the
applicant’s lands (15.11 hectares) do not form part of these applications and are
identified for future development with industrial uses as well as a new
Regional waste transfer station. No application for approval of the industrial
uses has been submitted. The waste transfer facility serving southern York
Region is to be constructed and operated by the owner on a 4.4 ha. (11 ac.)
portion of the property and a site
plan application for the facility is currently under review.
The
applicant has submitted a conceptual site plan for the commercial proposal that
includes retail stores having a total retail floor space of approximately
47,473 m² (511,000 ft²) to be anchored by three major tenants, which are not
confirmed at this time. The concept plan
indicates that the major tenants will occupy “big box” buildings of 13,810 m2 (148,663 sq. ft.), 10,215 m2 (109,955
sq. ft.) with room for future expansion, and 8,225 m2 (88,539 sq. ft.).
The concept plan also
demonstrates how the future industrial lands to the east of the subject lands
might be developed (Figure 4).
A Public Meeting with Regard to these Applications
was held in 2004
A Public Meeting was held on
An Official Plan Amendment prepared as part of
Highway 407/Rodick Road Land Use Study Redesignated the subject lands from
Parkway Belt West to Industrial
The Official Plan
currently designates the property as Parkway Belt West, with a Former Waste
Disposal Site symbol at the southwest corner of the property. It should be noted that in 1995, the lands
were deleted from the Parkway Belt West Plan.
However, no change in the Parkway Belt West designation in the Town’s
Official Plan was subsequently requested by the owner and this designation,
although outdated, remained until amended by the Town in 2003.
In July 2003,
Council adopted Official Plan Amendment No. 112 to designate the lands in the
Highway 407/Rodick Road area, including the subject property, as Industrial,
and submitted the Amendment to the Region of York for approval. In January 2004 the Development Services
Committee directed staff to initiate a Secondary Plan for the lands subject to
the designations established by OPA No. 112.
In June 2004, staff proposed a land use concept for the OPA No. 112 area
to the Committee, and received authorization to continue with preparation of
the Secondary Plan to implement the Industrial designation of OPA No. 112 based
on the concept. The concept showed the majority of the lands being designated
General Industrial Area, with the balance of the lands adjoining
For the purpose of
consideration of the subject applications the Industrial designation of the
lands, adopted in 2003, represents the established intent of Council. The
Industrial designation of the subject lands replaced the outdated Parkway Belt
West designation. The lands currently have an industrial zoning and have been
used in accordance with this zoning for many years. By virtue of use, zoning
and adopted designation, the lands can be regarded as industrial.
Zoning By-law Amendment Required
With
respect to zoning, the property is currently zoned Rural Industrial (M4) under
By-law 2284-68, as amended (Figure 2).
A rezoning application is required to permit the proposed commercial
uses. Revision to the current zoning would also be required to implement new
industrial development in accordance with the required Secondary Plan.
OPTIONS/DISCUSSION:
Central to consideration of the application is the request to change
the land use designation of the property. Council adopted an industrial
designation for the property in 2003. The Official Plan requires that the
consideration of applications that seek to change a land use designation shall
have regard for:
“the availability of other
designated lands to accommodate the uses proposed and the effect of a change in
designation on the supply of land in the categories affected.”
The applications
propose to change the Industrial designation adopted in OPA No. 112 to
Commercial on a 20.47 ha portion of the property. It is understood that the
application contemplates the construction of a waste transfer station on a
further 4.4 ha of the property and possible industrial use of the balance (10.7
ha). It must be determined if the requested change in designation of 20.47 ha
is warranted, to achieve an increase in the supply of land for commercial uses
while concurrently reducing the supply of industrial land.
The
Supply of Land for Industrial Use in Markham is Limited
There is a continuing need
to bring additional industrial lands to the market, especially if these
additional lands are suitably located, can be readily serviced, and offer the
potential to provide for larger development parcels. Based on forecast
employment, staff has estimated a near term, 10 year requirement for industrial
land only, of between 600 and 875 hectares. Based on the minimum requirement of
600 ha, the current supply of designated land that is market-ready would
satisfy the industrial land need for only one year (+/-53ha). If additional
designated lands could be made market-ready by the owners these could satisfy
up to an additional two to three years of industrial land need (+/-148 to194
ha). The lands currently awaiting
approval could contribute up to a further two year supply of industrial land
(+/-121 ha). However given the uncertainty of outstanding planning approvals,
installation of services and landowner priorities, it is not clear when, or how
much of the designated and approved lands (+/-269-315 ha) could be relied upon
to become market-ready within the near term.
The policies of the Official
Plan and monitoring of the industrial land supply are intended to ensure that
the Town remains in compliance with the Provincial Policy Statement (PPS),
1997 which requires the provision of sufficient land for employment uses
“…to accommodate growth projected for a time horizon of up to 20 years” and maintains
a land supply consistent with the growth projections established for the Town
through the Regional Official Plan. Staff’s analysis indicates that with, at best, a 5 to 6 year potential
land supply that might become available for industrial use, most of
which cannot be guaranteed to become market-ready, Markham cannot rely on there
being sufficient designated, marketable land to competitively address near term
need. Concurrently therefore, the potential land supply is also not sufficient
to meet a requirement of up to 20 years, as identified in the PPS. Given the
challenges to ensuring an adequate supply of industrial land, the Town must
pursue every opportunity to preserve and enhance the industrial land supply,
particularly within the existing urban area.
UDI Analysis Confirms
In 2004 the Urban
Development Institute retained Malone Given Parsons to assess the demand and
supply of urban land to meet forecast growth in the GTAH to 2031. The resulting
Analysis of Land Supply in the GTA-Hamilton Area
concluded that the supply of employment land in the GTA, within 40 km of
Pearson Airport (includes Markham), is only 45% of the total required, and that
high growth locations such as Markham have limited designated and developable
lands available for residential and employment growth. The analysis identified
the
Council has Designated the Miller Property for Industrial Use
As part of the Town’s commitment to designate and preserve lands for
industrial use, Council adopted Official Plan Amendment No.112 in 2003,
identifying additional lands in the Highway 407/Rodick Road area for industrial
use; Regional approval of that Amendment is pending. This Amendment includes
the Miller property which has an industrial zoning and has been used for
extractive and low intensity industrial uses for many years. Prior to the
adoption of OPA 112, the owner had expressed an interest in relocating some of
the current uses on the property and developing new, more intensive uses. In
discussions with the owner’s agent at that time, staff was provided with a
concept plan for the property proposing an industrial development pattern with
lots averaging 2 hectares (+/-5 acres) in area. The potential for a Business Corridor
Area designation, on lots of appropriate depth adjoining
Following the adoption of OPA No.112 Council directed staff to prepare
an implementing Secondary Plan to provide specific policies to guide the
approval of development for industrial use. This work is in progress. Council
also approved a site plan application for the Parkway Transformer Station,
currently under construction, on a substantial portion (+/-40 ha) of the vacant
and underutilized lands originally included in OPA No.112.
The decision by Hydro One to construct the Transformer Station significantly
reduced the potential additional industrial land contemplated in the approval
of OPA No.112 and focuses more importance on the remaining lands as the final
major opportunity to extend the industrial park development, already existing
on surrounding lands. The Miller property comprises 35.6 ha (+/-88 acres), a
significant area of underutilized land within this existing industrial park
context. Historically, the property has been used for low intensity
industrial uses and is located to form a
logical extension of the industrial development to the east (Rodick Road), west
and south (South Don Mills) and north (Brown’s Corners). In combination with other properties in the
Highway 407/Rodick Road area, these lands also represent the best remaining
opportunity to substantially improve the industrial land supply within the Town’s
current urban boundary, in keeping with the direction of Council.
The Industrial designation assigned to the property through OPA No.112
reflects the historical industrial zoning and use of the property, while
permitting its evolution to more intensive industrial development. The industrial
development contemplated would be in keeping with the character of the existing
industrial development on surrounding lands. In recent discussions, the owner
has identified the option of continuing, and potentially expanding the existing
uses, in the event that the retail development proposed in the applications is
not approved. The continuation, or
expansion, of existing uses would not be consistent with the intent of OPA No. 112
to bring underutilized industrial lands to the market and to accommodate new
industrial development. The owner should
be encouraged to work with the Town to implement the intent of OPA No. 112 and
the Town’s position in regard to the continuation or expansion of existing
uses, should be addressed in the context of the required Secondary Plan and
implementing zoning.
Several
recent documents released by the Province point to the importance of ensuring a
viable supply of land to accommodate industrial employment. Forecasts in The
Growth Outlook for the Greater Golden Horseshoe, published in January 2005,
confirm that York Region will continue to be a significant location for new
office and industrial employment through 2031, and that industrial employment will
continue to comprise the most significant component of the employment mix.
These forecasts underscore the importance of key Regional employment centres
like
Emerging
Provincial policy confirms the need to secure viable industrial lands and to
assure that opportunities for infill, and the redevelopment of underutilized
lands, are actively pursued in managing new growth. In February 2005, the
Province released the final version of the Provincial Policy Statement (PPS),
which came into effect on
“Sufficient land shall be made available through
intensification and redevelopment and , if necessary, designated growth areas,
to accommodate an appropriate range and mix of employment opportunities… to
meet projected needs for a time horizon of up to 20 years.”
Section
1.3, Employment Areas (full extract in Appendix A) establishes a policy that:
Planning authorities shall promote economic
development and competitiveness by…planning for, protecting and preserving employment areas for current and future
uses…”
Also,
in February 2005, the Province released the Draft Growth Plan for the
Greater Golden Horseshoe (GGH). Section 2.5 of the Plan (Employment Areas)
confirms that employment areas within the GGH are among the largest centres for
manufacturing and distribution in
“Demand
for industrial space including knowledge-based industries traditionally found
in employment areas is expected to be
an important element of economic growth in southern
One of the
challenges facing municipalities…is ensuring employment areas are retained for
industrial uses. The conversion of employment
areas to other uses…can result in a shortage of employment lands. The Growth Plan’s policies elaborate on the
policies of the PPS by discouraging
major retail uses in employment areas, and by requiring that a
conversion to non-employment or major retail uses will not result in an
expansion of the designated growth area.” (full extract in Appendix B)
Policies
in the Draft Growth Plan clearly address the conversion of land within
employment areas to major retail use. Section 2.5.2 provides that:
“1. Municipalities may permit
the conversion of lands within employment
areas to non-employment or major retail uses only through a comprehensive
review and only where it has been demonstrated that the conversion or
designation is necessary to address other provincial priorities…or -
a) the land is not required over
the long term for employment purposes for which it has previously been
designated, and
b) the conversion does not result
in an expansion of the settlement area to meet future employment needs.
2. Municipalities are
encouraged to designate and preserve lands in the immediate vicinity
of existing major highways… for
manufacturing, warehousing and associated retail, office
and ancillary facilities.”
Note: An “employment area” as defined in the PPS is an area, “designated in
an official plan for clusters of business and economic activities including but
not limited to, manufacturing, warehousing, office, and associated retail and
ancillary activities”. The Draft Growth Plan makes it clear that major
retail uses are not contemplated as part of an “employment area”.
It is recognized that the provisions of
the new Provincial Policy Statement and the Draft Growth Plan may
not bind Council in regard to a decision on the subject applications, which
were submitted in 2004. The provisions of the previous PPS regarding land
supply were operative at the time the applications were filed. It is important however, for Council to
understand that the new Provincial policies
enunciate a strategy to provide and
protect a supply of industrial land that the Province is directing
municipalities to pursue, and that the strategy specifically discourages major
retail uses in defined employment areas. This strategy is consistent with, and
reinforces, the provisions of
The Proposal is Not Consistent with
There is a high level of
demand for industrial space in
With construction of the
Rodick Road overpass underway and new listings of medium to large sized pieces
of industrial land, the industrial block bounded by Hwy 404, Rodick Road,
Highway 407 and 14th Avenue (including the Miller lands) has been
experiencing increased interest and broker activity for industrial
development. Currently there are no
significant vacancies in this block.
There have been numerous inquiries from industrial users, site selectors
and developers that have come through the Economic Development Office looking
for information. In addition, members
from the following organizations have gone on record to identify increased
industrial interest for available development opportunities in this block:
·
Colliers International – numerous purchase
offers on land listed at
·
Ontario Realty Corporation – numerous inquiries
and eventual sale of 16 acre piece of land at Highway 407 and
·
Connell Real Estate and Royal Lepage Commercial
both state they have represented many industrial clients interested in locating
in this area.
The proposed change in designation of the property is not consistent
with the Town’s Economic Development Strategy to establish, promote and support
· Office
and administrative employment alone cannot sustain continued growth in
·
Ancillary functions such as warehousing,
distribution, component manufacturing and light consumer goods manufacturing
are also necessary to achieve economic growth.
These uses, together with certain high-technology companies which seek flexible
building forms other than offices, will require designated industrial land and purpose-specific
buildings.
· The
Town’s economic strategy also calls for a continued diverse economic base to
achieve a more balanced economy that
can still achieve overall growth when one particular industry sector is
suffering.
· In 2004,
Council approved a budget for the Economic Development Department to commission
a Competitiveness Study that will critically review the current economic
development strategy. It is premature to
allow the conversion of any industrial lands prior to receipt and adoption of
the study recommendations.
In
2003 Council requested a review of the Town’s commercial policies and in 2004
an inventory of commercial development in
The
Review also identified that the supply of designated land with the potential to
accommodate big-box retail is diminishing. However, there is still sufficient
land to accommodate an additional 1.6 million square feet of floorspace in the
form of very large scale retail buildings, if the Town confirms that this type
of retail development is still appropriate. In the event that this type of
development is not what Council determines is appropriate, this available
land could be considered for other forms of retail and mixed use
development.
The Inventory
of Markham Commercial Space, January 2004, identifies that there is
currently 14 million square feet of retail and service floorspace in
“The consistency of the results indicates a
self-regulating stability or “equilibrium”, in the overall commercial land
market in
The
Inventory demonstrates that there is sufficient opportunity to continue to meet
retail and service needs until at least 2011. The Inventory also reveals that
Markham’s
Retail Employment is at an Appropriate Level
At
the Public Meeting on October 19 2004, a consultant for the applicant advised
the Development Services Committee that
Staff
has investigated this assertion, including a review of the report entitled Employment
and Industry 2003 prepared by the Region,
and referred to by the consultant. The Region’s report acknowledges (page A-3)
that its primary focus is employment areas (business parks) and that it
therefore significantly under-reports employment in certain parts of Markham,
most notably locations such as Shoppes on Steeles, Markville Mall and Pacific
Mall, that accommodate significant retail employment. This circumstance is
clearly illustrated on Figure 40 of the Report. The report is therefore not an
accurate data source for the conclusion regarding retail employment presented
to the Development Services Committee.
Staff
also examined 2001 Census data that demonstrates that the share of retail jobs
in
In
2004, Council identified a Strategic Priority for 2004 to 2006 of “creating a
better quality of community”. As one
action in support of this priority, Council identified:
“Shifting
planning policies to discourage auto-oriented big-box retail development and
encourage pedestrian friendly retail activity and mixed land uses at community
focal points.”
It is
understood that identified actions supporting the strategic priorities are to
be considered in regard to policy recommendations and decisions by staff and
Council. Approval of the proposed development which includes large scale retail
buildings and large surface parking areas to accommodate auto access would not
be consistent with supporting Council’s Strategic Priority.
Servicing and Traffic Studies are required for the
Property
Although
some servicing is available in the vicinity of the subject lands, a servicing
study is required to determine if the existing municipal sanitary sewers and
watermain can accommodate any future development with no adverse impacts on the
existing system. With respect to stormwater management, there are no Town storm sewers available in
the vicinity and a drainage study is required for the subject property to
accommodate any future development.
As part
of the Highway 407/Rodick Road study, a transportation report was prepared
which reviewed current traffic conditions and identified a number of
transportation improvements which are being investigated within the Highway
407/Rodick Road area. However, any
significant redevelopment of the subject lands will require a site specific
traffic study. The applicant has
submitted a traffic study to support the proposal and it has been forwarded for
peer review. However, in light of the
issues raised in this staff report, the peer review has been put on hold,
pending a policy decision by Council on the issues raised herein.
Potential Contamination Issues will be Addressed prior
to any future Development Approvals on these Lands
The existing Official Plan identifies a Former Waste
Disposal site on the subject lands. This
identification, and the related policies, were incorporated into the Town’s
Official Plan by a modification required by the Ontario Ministry of the
Environment. The policies require that
prior to any development of these lands, environmental studies and any
necessary mitigative measures be undertaken to the satisfaction of the Town and
the Ministry of the Environment.
As part of the Highway 407/Rodick Road study, a
preliminary environmental site screening report was prepared by the Town’s
consultants to identify areas of potential contamination, and to provide
recommendations for additional studies/action plans. According to the
study, the majority of the subject property has a moderate potential for
contamination. The consultant identified adjacent lands, as well as a
small portion of the subject lands as having a high potential for
contamination. Phase I and Phase II Environment Site Assessments will be
required prior to any future development approvals on the subject lands. In addition, prior to the granting of any
approval for development a Record of Site Condition should also be completed
for the subject lands by a qualified person, in accordance with current
environmental legislation and standards.
To confirm that the site is suitable for the proposed use and, if
necessary, remediated in accordance with
the Ministry of Environment standards, the Town should require that the Record
of Site Condition be filed with the Environmental Site Registry office of the
Ministry of the Environment and be acknowledged by the Ministry of the
Environment. The Town will also require
an environmental clearance letter for any lands conveyed to the Town.
CONCLUSION:
This report outlines the
fundamental policy issues relating to the consideration of the applications to
redesignate the subject lands. Based on
consideration of these issues, as outlined in the report, staff concludes that a
change in the Industrial land use designation, adopted by Council in 2003, to a
Commercial designation, to permit large scale retail development is not
warranted, and that the applications should be refused for the following
reasons:
·
The supply of
land for industrial use in
·
Council’s 2003
designation of the Miller property as Industrial is consistent with the need to
ensure an adequate supply of industrial land and followed an extensive
consultation process;
·
Retaining the
Industrial designation of the property is consistent with the provisions of the
Official Plan and is now demonstrated to be consistent with the strategy for
the reservation and protection of industrial lands identified by the Province;
·
The proposed
change in property designation is not consistent with the Town’s Economic
Development Strategy to establish, promote and support
·
There is
sufficient land designated in the Official Plan to accommodate retail
development and there is no compelling reason to designate additional land for
more large scale, retail development at this time;
·
·
The proposal is
not consistent with discouraging auto-oriented big-box retail development in
favour of other forms of retail development, to support a Strategic Priority of
Council to create a better quality of community.
FINANCIAL CONSIDERATIONS:
ENVIRONMENTAL CONSIDERATIONS:
As discussed above, potential for contamination exists on the subject
lands and will have to be addressed to the Town’s satisfaction, in consultation
with the Ministry of the Environment where appropriate, prior to any future
development approvals.
ENGAGE 21ST CENTURY
The retention of the Industrial designation of the property and
continued effort to encourage the development of the property for industrial use
responds to corporate goals relating to managed growth and economic development
established in Engage 21st Century Markham, and particularly to the
strategic choice that, “The Town will continue to focus on and actively support
its position as the high tech/knowledge based capital of Canada”.
BUSINESS UNITS CONSULTED AND AFFECTED:
The applications were circulated to internal
departments (Fire, Building, Engineering, Design, Waste Management), and
external agencies for comments. The Economic Development Department was
consulted, and assisted in the preparation of this report.
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Valerie Shuttleworth, M.C.I.P., R.P.P. Director of |
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Jim Baird, M.C.I.P., R.P.P. Commissioner of Development Services |
Q:\Development\Planning\APPL\ZONING\04
017225_MillerLands\DSC_March 22_05 -
Miller Final Report.doc
ATTACHMENTS:
Appendix A
Extract from The Provincial
Policy Statement,
Appendix B Extract from Places to Grow, the Draft
Growth Plan, February, 2005
Figure 1: Location Map
Figure 2: Area
Context/Zoning
Figure 3: Aerial Map
Figure 4: Conceptual Site
Plan (Option 1)
AGENT/ Malone Given
Parsons Ltd. Tel:
(905) 513-0170
c/o Jim
Kirk Fax:
(905) 513-0177
L3R 6B3