City Of Burlington MZO

Recommendation Report
Background
Millcroft Golf Course Development Application History
The Millcroft Greens Corporation submitted applications for approval of Official Plan and
Zoning By-law amendments, as well as a draft plan of subdivision, on December 18, 2020, to
redevelop portions of the Millcroft Golf Course lands into residential uses. The proposal
consisted of five redevelopment areas (A–E) totaling about 12.4 hectares and included plans
for 90 detached homes and a six-storey apartment building with 130 units.
The applications were appealed by the applicant to the Ontario Land Tribunal (OLT) in June
2022 due to a lack of municipal decision through Case File number OLT-22-004149. After a
17-day hearing in March 2024, the OLT approved the proposal in June 2024. This approval is
final and binding. The City’s role, as it relates to the existing OLT approved development, is
now limited to overseeing implementation of the OLT’s conditions.
MZO Application
A Minister’s Zoning Order, made pursuant to clause 47(1)(a) of the Planning Act, regulates the
use of land and the erection, location and use of any building or structure on the land, and
prevails over the existing municipal zoning by-law to the extent there is any conflict.
The Minister is considering a request from Millcroft Greens Corporation to make a Minister’s
Zoning Order for lands at 2155 Country Club Drive and 4274 Dundas Street, in the City of
Burlington (City). See Appendix A for a location map of these lands. This request has written
support from the Minister of Seniors and Accessibility and the Minister of Environment,
Conservation and Parks.
The comment period for the MZO opened on June 5, 2026 and closes on July 5, 2026 (30
days).
Pursuant to subsection 47(4.0.1) of the Planning Act, the requested zoning order would
exempt the proposal from the requirement to comply with the Provincial Planning Statement,
provincial plans and municipal official plans.
According to the ERO posting, this request is being made to expedite approvals for the
proposed residential development.
Page 3 of Report Number: CAF-07-26
To help ensure decisions are made in a transparent manner and support government priorities,
the Ministry is seeking feedback on whether this request should be considered and any
additional information that may help inform a decision. In particular, the Ministry is requesting
identification of any potential environmental risks, financial impacts on the municipality or
implications for other approved developments and how these can be mitigated.
2155 Country Club Drive
The subject lands at 2155 Country Club Drive are comprised of six (6) areas with a combined
size of approximately 11.6 hectares. These lands are bound by Dundas Street to the north,
Upper Middle Road to the south, Appleby Line to the east, and Walker’s Line to the west.
Most of the subject lands at 2155 Country Club Drive are currently designated Major Parks and
Open Space, with small portions designated Natural Heritage System and Key Natural
Features in the City of Burlington Official Plan, 2020. The lands are zoned Open Space in
the City of Burlington Zoning By-law, 2020, as amended.
The requested Zoning Order seeks to facilitate approximately 138 new housing units to be
accessed by private (condominium) roads, in the six (6) areas at 2155 Country Club Drive.
Specifically, the requested Zoning Order seeks to override the current Open Space zoning
regulations of the City of Burlington Zoning By-law 2020, as amended, that apply to these
areas, by permitting the following uses:
 Single detached dwellings on private roadways owned collectively by homeowners.
 A range of townhouse styles.
 Accessory uses, buildings and structures.
 Additional Residential Units in any permitted detached dwelling or townhouse building
or accessory building or structure.
 Office use in combination with a dwelling unit.
 Home Occupation
 Private open space including outdoor community and recreation facilities.
 Uses permitted in all zones, which will include a stormwater management tank as well
as storm water management and erosion control facilities, non-intensive outdoor
recreation uses, public utilities and services, archaeological restoration, and forest,
wildlife and fisheries management in accordance with regulations set out in the
Residential Zoning By-law 09-2026, as amended.
The requested Zoning Order would also establish zoning requirements for the proposed single
detached dwellings and townhouses, such as lot area and coverage, setbacks, building
heights, encroachment into yards, and off-street parking.
4274 Dundas Street
Page 4 of Report Number: CAF-07-26
The subject lands at 4274 Dundas Street are approximately 0.66 hectares in size comprised of
one (1) area fronting onto Dundas Street, between Millcroft Park Drive to the east and Weslock
Common to the west. These subject lands are currently occupied by a maintenance shed for
the golf course.
The subject lands at 4274 Dundas Street were included among the parcels approved for
development by the OLT as described above. As a result of the OLT allowing Millcroft Green’s
appeal, they are currently designated High-Density Residential in the City of Burlington Official
Plan, 2020, and zoned Medium-Density Residential with a site-specific exemption and Holding
provision (H-RM3-558) in the Burlington Zoning By-law 2020.
The requested Zoning Order seeks to broaden land use permissions on the subject lands at
4274 Dundas Street to add long-term care facility and retirement home as permitted uses, in
addition to apartment building, townhouse buildings, and back-to-back townhouses, already
permitted on the subject lands through the H-RM3-588 zone in the Burlington Zoning By-law,
2020, as amended by the Ontario Land Tribunal.
Additionally, the requested Zoning Order seeks to apply the current apartment building
regulations set out in the H-RM3-588 zone to the proposed long-term care facility and
retirement home uses; and to add a new minimum off-street parking requirement of 0.6 spaces
per unit or bed for the proposed long-term care facility and retirement home uses.
Municipal Advocacy History
On June 17, 2025, Councillor Bentivegna brought forward a motion, seconded by Mayor Meed
Ward, to request that the Minister of Municipal Affairs and Housing issue a Minister’s Zoning
Order (MZO) to restrict the uses permitted on the remainder of the Millcroft Golf Course lands
to those currently permitted by the City’s Zoning By-law. This motion was approved by Council.
On June 17, 2025, the Minister of Municipal Affairs and Housing wrote to Mayor Meed Ward to
advise that:
 it was premature for the Minister to consider an MZO request for the remainder of the
Millcroft Golf Course lands; and,
 he has asked that the Provincial Land and Development Facilitator engage the City and
Millcroft Greens and strongly encourages the City and Millcroft Greens work with the
facilitator to explore how housing and an integrated parks and open space system can
be achieved on the remainder of the Millcroft Golf Course lands.
On June 18, 2025, Mayor Meed Ward and Councillor Bentivegna responded to the Minister of
Municipal Affairs and Housing to acknowledge the Minister’s response and recommendation to
engage with the Provincial Land and Development Facilitator.
Page 5 of Report Number: CAF-07-26
In addition to the correspondence from the Minister of Municipal Affairs, Mayor Meed Ward
also received correspondence, with copy to others including members of Council, the Premier,
the Minister and the MPP, from Argo Development Corp on June 17, 2025 in which Argo
expressed its displeasure with the City’s MZO request. Further, Argo indicated that it was
interested in discussing a sale of up to 70 acres of the remaining golf course land for nominal
consideration if an agreeable development scenario on the balance of the lands could be
achieved.
On June 18, Mayor Meed Ward and Councillor Bentivenga wrote to Argo, confirming Council’s
support for an MZO on the remaining golf course lands, and advising that City staff will be
reporting on this matter to Council to seek instructions on participating in the facilitated
discussion.
Provincial Land and Development Facilitator
At the July 7, 2025 Committee of the Whole meeting, staff presented confidential legal report
LLS-41-25. Subsequently, on July 15, 2025, City Council approved the following public
recommendation:
Direct the Commissioner of Development Growth Management, or his designate, to
attend the facilitation led by the Provincial Land and Development Facilitator regarding
the Millcroft Golf Course and report back to Committee and Council to provide updates
on the facilitation process and obtain instructions as required.
As such, the City has engaged in a provincially-led facilitation process with the applicants
(Millcroft Greens), at the request of the Minister of Municipal Affairs and Housing. It was a non
binding process involving solely the City of Burlington, the applicants (Millcroft Greens/Argo),
and the provincial facilitator, but did not include public or neighbourhood associations.
The facilitation was guided by the Office of the Provincial Land and Development Facilitator
(PLDF). There were several meetings as well as individual phone calls that staff had with both
the PLDF and Millcroft Greens / Argo. The discussions were intended to explore land-use
options for the balance of the lands not subject to the aforementioned planning applications
approved by the OLT. The facilitation process concluded on December 12, 2025, without
consensus on land-use options for the remaining lands on the Millcroft Golf Course.
Current Applications
City request for MZO on remaining lands
Page 6 of Report Number: CAF-07-26
On April 13, 2026, a Ministerial Zoning Order Framework Request was submitted by the City to
the Minister of Municipal Affairs and Housing. The requested MZO would apply to all
remaining lands in the Millcroft Golf Course outside of the previously mentioned OLT decision.
It would prohibit every use of land and every erection, location or use of any building or
structure except those specifically permitted by the current O1 Open Space Zone in Zoning By-
law 2020.
To date, the Minister has not issued a decision on the City’s 2026 MZO request.
Planning Act Applications
On June 5, 2026, the City received an application from the Millcroft Greens Corporation for an
Official Plan Amendment (OPA) and Draft Plan of Subdivision (DPS) for the lands included in
Millcroft Greens’ MZO request. This constitutes a new phase of development on the Golf
Course lands outside of the previous OLT decision.
These applications are intended to support and implement the applicant’s requested MZO, as
described in the MZO Application section earlier in this report, and as such were submitted
without the benefit of a Zoning By-law Amendment (ZBA). The applicant is relying on their
MZO request for land use planning approval and replace the need to submit a ZBA to the City.
In doing so, the applicant’s MZO request would reduce the submitted OPA and DPS to an
administrative process rather than a holistic land use planning review with the inclusion of a
ZBA. To meet the legislated development processing timelines, staff are targeting a Statutory
Public Meeting for these applications in the September Council meeting cycle.
Analysis
Based on the information available within the Environmental Registry of Ontario Posting #026-
0551, municipal staff have the following general comments that form the basis of this
submission on behalf of the City of Burlington.
As stated above, the City has yet to receive a decision on its MZO application submitted on
April 13, 2026. This application seeks to maintain the open space uses on the lands and is
fundamentally incompatible with the applicant’s current applications, which are premature until
a decision has been made on the City’s MZO application.
At the same time, the City must make a decision on the new applications within its legislated
development processing timelines and are targeting the September Council meeting cycle. It
is staff's view that separately processing the Planning Act applications and the applicant’s
Page 7 of Report Number: CAF-07-26
MZO, especially while the City’s MZO request remains open, creates confusion and
contradictions in the land use planning process for these lands.
The City’s vision for these lands as articulated in the Official Plan is for open space. It is the
City’s position that the MZO should be refused, the OPA and draft plan applications withdrawn,
and the City’s MZO application approved.
In the absence of clarity regarding the City’s MZO application, staff offer the following
supplementary comments on the Millcroft Greens Corporation request for MZO.
2155 Country Club Drive: recommend refusal of the Millcroft Greens’ MZO application
 The majority of the proposed development is within or adjacent to Conservation Halton
Regulated Areas. Other than a location map, the MZO has no supporting materials to
understand the developable area or demonstrate that the proposed residential
development will not be located in a hazard area in accordance with the Provincial
Planning Statement (PPS).
 It is understood that an MZO is exempt from compliance with provincial policy including
the PPS. However, given the potential health, safety, financial, and environmental risk
for residential development within flood hazard areas, along with any downstream
flooding impacts, it would not be in the public interest to ignore provincial policy
including the PPS.
 The City received applications for an Official Plan Amendment (OPA) and Draft Plan of
Subdivision (DPS) on June 5, 2026 and has 120 days to meet its legislated timelines
and issue a decision.
 As the closing date for the Millcroft MZO is July 5, 2026, a minimum of 30 of the 120
days to process the OPA and DPS will have passed without zoning clarity for staff to
process the OPA and DPS.
It should be understood that the City’s primary position is that its 2026 MZO application should
be approved and the applicant’s MZO application refused. The following comments apply only
in the event of the refusal of the City's 2026 MZO application.
 To ensure the orderly processing of the development applications, a Zoning By-law
Amendment (ZBA), including all technical supporting materials, should also be
submitted to the City for review.
 The ZBA will ensure a complete, transparent, and public development review process at
the local level and can be considered in an integrated manner with the OPA and DPS.
Page 8 of Report Number: CAF-07-26
 There is already a Provincial appeal mechanism via the OLT for municipal decisions on
development applications. An MZO is not required for the Province to have oversight
on the decision-making process for this development.
 The legislative processing timelines for the OPA and DPS should restart so that the
OPA, ZBA and DPS are reviewed holistically and within the same legislated processing
timelines.
4724 Dundas Drive: recommend refusal of the Millcroft Greens' MZO application
The City does not object to the merits of the proposed changes for 4724 Dundas Drive; it does
object to the process to implement through an MZO and recommends refusal.
 The request to add long term care and retirement home as a permitted use while
applying the OLT approved regulations for an apartment building is appropriate as the
built form and intensity of use would not increase.
 The MZO request does not provide a parking utilization study or technical materials to
support the requested parking rate for the proposed land uses.
 There are no nearby on-street parking options available for this property so it is critical
to ensure that an appropriate parking rate is applied to the development.
 The proposed parking rate would be best considered as part of the suggested ZBA
application identified above.
Recommendation Details
Consistent with previous direction on advocacy concerning the future development of the
Millcroft Golf Course, this staff recommendation report identifies another opportunity to share
the City of Burlington’s perspective on the future uses of the subject lands.
It is recommended that this report be submitted to Environmental Registry of Ontario (ERO) to
convey the City of Burlington’s opposition to the Environmental Registry of Ontario (ERO)
Posting #026-0551, Millcroft Greens Corporation Request for a Ministerial Zoning Order (MZO)
for Residential Uses in the City of Burlington.
Key Dates & Milestones
 June 5, 2026: Environmental Registry of Ontario Posting #026-0551 Open for Comment
 June 23, 2026: Special Meeting of City Council
 July 5, 2026: Environmental Registry of Ontario Posting #026-0551 Closed for
Comment
Page 9 of Report Number: CAF-07-26
References
Environmental Registry of Ontario Posting #026-0551, Request for a Minister’s Zoning Order
for Residential Uses in the City of Burlington. June 5, 2026. https://ero.ontario.ca/notice/026-
0551
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