Stop Sprawl: Critique of Envisioning Brantford

Comments due February 8, 2019

Submit to: Alan Waterfield and Joshua Schram

Background: The Public Information Centre for the City of Brantford Official Plan Review was held January 17, 2019. The presentation, easel boards, and table discussion sheets can be found

Over the past decade, Brantford has failed to meet the Growth Plan density requirements. This has made it even harder for the City to meet the new, higher density requirements of the 2017 Growth Plan. To solve this problem, the City is proposing to use what is called an alternative density target, which would be lower than the 80 residents and jobs per hectare (ha) required by the new Growth Plan. This is allowed by the 2017 Growth Plan, provided the City demonstrates it can’t meet the 80 residents and jobs per ha density target, and the alternative target is equal to or higher than the current density requirements in the City Official Plan. The alternative target proposed by the City is 52 residents and jobs per ha and the city uses this density in justifying a proposed 460 ha expansion of the urban area. Current policies in the City Official Plan require a density of approximately 70 residents and jobs per ha on the residential lands, to which the proposed alternative density of 52 residents and jobs per ha would apply. This does not meet the requirements of the Growth Plan, calling into question the amount of land that could be included in any future expansion.

The Province has recently proposed an amendment (Amendment No. 1) to the Growth Plan that would directly affect how this issue is resolved.

We recommend that the Envisioning Brantford plan not proceed until Amendment No. 1 has been approved by the Province.

In addition, population growth in Brantford for the period from 2011 to 2016 has been 43% lower than anticipated by the study on which the Growth Plan forecasts were based. More recently, another population projection by the Ministry of Finance indicated growth to 2041 for Brantford would take place at a considerably slower rate than the Growth Plan forecasts. The less the growth that occurs, the smaller the expansion that would be necessary to accommodate such growth.

We recommend that the Province review the population forecasts for Brantford to ensure they are appropriately up to date.

Delaying the Envisioning Brantford plan as proposed above could also have the added benefit of allowing the review of the Growth Plan population forecasts to occur before decisions are made about any future expansion onto the annexed land.

This summary is based on an analysis undertaken by Kevin Eby, a Registered Professional Planner working with Eby Growth Management Planning Services.