Letter to Mayor & Councillors re: Town Report

From: Jim Goodfellow <jlgoodfellow@mac.com>Date: January 26, 2026 at 11:25:05 AM ESTTo: Rob Burton Mayor <Mayor@oakville.ca>, council@oakville.caCc: stephen.crawford@pc.ola.org, tod.mccarthy@pc.ola.org, rob.flack@pc.ola.org, Clerks Town <TownClerk@oakville.ca>Subject: ERO 025-1368 - Provincial priority request for four (4) Minister’s Zoning Orders for the Transit-Oriented Community in the Town of Oakville

Dear Mayor Burton and Councillors,

We are writing to express our strong support for, and sincere appreciation of, the Town’s planning staff and the thorough, professional report they prepared on the revised Midtown Transit-Oriented Community (TOC) proposal. 

This is the second staff report addressing what is, in substance, the same proposal. Unfortunately, once again, staff have had to devote their time and resources to analyze and restate the same serious and fundamental concerns, because their original report has not been meaningfully responded to. That repetition is both costly and telling. It confirms that the professional advice of Town staff, and the concerns of the community are not considered important and have been ignored. 

We Love Oakville submitted detailed written comments to Minister McCarthy by the January 17 deadline, which Council has received. This letter does not attempt to address every issue raised in the planning staff report, or in our submission. Please take it as read that we fully support the staff’s findings and conclusions. In this letter we focus on a few overarching issues where we can offer some additional perspectives and suggestions. 

Unacceptable Mega-Density 

The staff report concludes that the revised TOC represents an excessive and disproportionate share of Midtown’s planned population. The report states that “approximately 68% of northwest Midtown’s projected 2051 units are concentrated on just 13% of the land area. This distorts the residential market, undermines the development of other Midtown sites, and jeopardizes Midtown’s evolution into a complete community. It also risks exceeding planned infrastructure capacity, underscoring the need to scale the TOC back to align with OPA 70.”  We concur. 

Staff also concluded that tower separation standards are deficient across all sites. In particular, Sites 1 and 3 lack the physical space required to safely accommodate the number and height of towers proposed. These are fundamental failures in urban design, livability, and public safety.  The staff report highlights the critical importance of clear and enforceable planning guardrails: limits on height and density, adequate tower separation, access to light and air, wind mitigation, safe streets, emergency access, and functional public realm design. When these guardrails do not exist, as in the revised TOC, this will likely result in an environment that is unsafe, uncomfortable, and fundamentally unlivable.

Town planners have now reached the same conclusion twice: density beyond OPA 70 is not justified. Yet the revised TOC proposes essentially the same mega-density, without explanation, justification, and without addressing well-founded staff and resident concerns.

This is unacceptable. 

This level of density undermines the complete-community outcomes the Province claims to support. Complete communities require integrated planning for parkland, schools and childcare, transportation, mobility, stormwater and climate resilience, urban design, and servicing capacity. The revised TOC ignores the careful, interlocking framework designed to achieve these outcomes, such as:

• Council-endorsed Midtown Transportation Plan

• Council-endorsed Midtown Stormwater Management Plan

• Council-endorsed Designing Midtown – Urban Design Direction

• Council-approved Town-wide Transportation Master Plan

• The Midtown Area Servicing Plan

• Halton Region Water, Wastewater and Transportation Integrated Master Plan

• Draft Town of Oakville Community Planning Permit By-law

The Revised TOC Fails Proper Planning, Fairness, and the Public Interest

The staff makes it clear that the proposed TOC would override the Town’s Official Plan and ignore OPA 70 on height, density, and community benefits. The staff report states this would undermine responsible planning for Midtown and confer an unfair and unprecedented advantage on a single developer at the expense of every other landowner and builder.

Let us expand on this important point: proceeding with MZOs that grant this proposed zoning would substantially increase the value of land owned by the selected developer. Doing so under confidentiality agreements, without transparency, meaningful public engagement, or independent oversight, would be indefensible on planning, governance, and public-interest grounds.

Staff also conclude that the proposal fails to meet the Minister’s stated TOC objectives and that the proposed community benefits are not aligned with existing or draft policy. The Town further finds that the use of MZOs is directed at prioritizing speed over public consultation, municipal autonomy, and long-term planning.

However, we have been informed that Phase One would not begin until after 2030, with full build-out stretching over roughly the next 20 years, which means that IO’s explanation of prioritizing speed is not valid and this TOC does nothing to meet the Province’s current housing needs or targets.  So why are they proposing to issue these MZOs? 

We fully support staff’s damning conclusion that this proposal is fundamentally a private development proposal with little to no community benefit for either the Town or the Province. It delivers no near-term housing, does not advance the Province’s housing targets, fails to meet the TOC program objectives, and is not in the public interest. This raises a basic and fundamental question: why should this project proceed?

Completing the Due Diligence

The staff report concluded that “If the Province is intent on proceeding with zoning certainty, it should complete all of its due diligence by seeking vital input from the public and all levels of government, including other Ministries and federal regulations regarding land use clearances”.  The staff report notes that NAV Canada has raised concerns related to impacts of Navigation Canada’s Minimum Vectoring Altitude (MVA) for the TOC sites, and clearly this is one of the open due diligence items that needs to be resolved. We however, would add three other areas where due diligence appears incomplete:

• The collapse and structural transformation of the condominium market, and its implications for the revised TOC and all stakeholders

• The absence of any comprehensive risk-reward analysis identifying who bears financial, operational, and delivery risks over a multi-decade timeframe

• The lack of independent, objective assessment of whether the proponent has the financial capacity, operating expertise, and long-term resilience required to deliver and sustain a project of this size and scale

Given current condominium market realities, locking in excessive height and density without this analysis could expose both the Town and the Province to significant financial, planning, and reputational risk. Proceeding without full due diligence would be inconsistent with responsible governance and sound planning practice.

The Need for Transparency and a Public Hearing

Mayor Burton, many if not most residents have lost confidence in this process. The professional judgment of Town planning staff and the voices of the community are aligned, yet they have been dismissed without serious consideration.  Why will this round be any different?

Staff have now concluded, twice, that density beyond OPA 70 is not justified and that this proposal delivers little to no community benefit. We urge you to actively and decisively champion these findings and ensure they are clearly understood and taken seriously in your discussions with provincial Ministers and officials. Simply put, the Province must be convinced that implementing OPA 70 consistently across all of Midtown, without exception, is the best outcome for both the Town and the Province. 

If, for some reason, Ministers are unwilling to implement OPA 70 consistently across Midtown and instead advance another non OPA compliant “compromise,” we urge you to object as strongly as possible and to insist on a full public meeting or hearing before any agreement is finalized or imposed through an MZO; so that the areas of non-compliance, and the reasons for non-compliance, can be publicly tested, assessed, and responded to.

If this proposal were proceeding through the Town’s normal planning process, a statutory public meeting would be mandatory. Even the OLT hearings are conducted in public. There is no defensible reason why MZOs of this magnitude should be negotiated in secret.

Mandate OPA 70 for all of Midtown ASAP

In closing, we focus on staff’s request that the Province preserve the role of local decision-making through the Town’s OPA 70. We fully support staff’s request, and point out that OPA 70 aligns with provincial growth targets, supports transit-oriented development, streamlines approvals, reduces red tape, and allows flexibility to respond to changing market conditions.

As stated in our submission, approving OPA 70 and applying it uniformly across Midtown is the most practical and responsible path forward, which provides zoning certainty within a holistic planning framework and positive conditions for growth. Council and the community support this framework. Provincial approval is now needed to work together, collaboratively and transparently, to deliver housing and build a livable Midtown.

The only Minister’s Zoning Order that should be issued is one that approves and implements OPA 70.

Sincerely,

George Niblock and Jim Goodfellow 

On behalf of We Love Oakville, a non-partisan grassroots organization representing 12 residents’ associations and over 8,500 Oakville residents.

Sent from my iPhone

(905) 301-5994