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PL141318 ONTARIO MUNICIPAL BOARD Bronte Green Corporation has appealed to the Ontario Municipal Board under subsection 51(34) of the Planning Act, R.S.O. 1990, c. P.13, from the failure of the Town of Oakville to make a decision to permit the development of an integrated mixed-use, mixed-density community, 1401 Bronte Road, Town of Oakville Municipal File No.24T-14004/1530 OMB File No. PL141320 Bronte Green Corporation has appealed to the Ontario Municipal Board under subsection 51(34) of the Planning Act, R.S.O. 1990, c. P.13, from the failure of the Town of Oakville to make a decision to permit the development of an integrated mixed-use, mixed-density community, 1401 Bronte Road, Town of Oakville Municipal File No. 24CDM-14003/1530 OMB File No. PL141319 Bronte Green Corporation has appealed to the Ontario Municipal Board under subsection 22(7) of the Planning Act, R.S.O. 1990, c. P.13, from the failure of the Town of Oakville to adopt the requested amendment to permit the development of an integrated mixed-use, mixed-density community, 1401 Bronte Road, Town of Oakville Approval Authority File no. OPA 1530.07 OMB File No. PL141318 Bronte Green Corporation has appealed to the Ontario Municipal Board under subsection 34(11) of the Planning Act, R.S.O. 1990, c. P.13,from the neglect or refusal of the Town of Oakville to amend Zoning By-law No. 1984-63 to permit the development of an integrated mixed-use, mixed-density community, 1401 Bronte Road, Town of Oakville Municipal File No.Z.1530.07 OMB File No. PL141318 WITNESS STATEMENT OF ALICIA JAKAITIS August 27, 2015

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PL141318

ONTARIO MUNICIPAL BOARD

Bronte Green Corporation has appealed to the Ontario Municipal Board under subsection51(34) of the Planning Act, R.S.O. 1990, c. P.13, from the failure of the Town ofOakville to make a decision to permit the development of an integrated mixed-use,mixed-density community, 1401 Bronte Road, Town of OakvilleMunicipal File No.24T-14004/1530OMB File No. PL141320

Bronte Green Corporation has appealed to the Ontario Municipal Board under subsection51(34) of the Planning Act, R.S.O. 1990, c. P.13, from the failure of the Town ofOakville to make a decision to permit the development of an integrated mixed-use,mixed-density community, 1401 Bronte Road, Town of OakvilleMunicipal File No. 24CDM-14003/1530OMB File No. PL141319

Bronte Green Corporation has appealed to the Ontario Municipal Board under subsection22(7) of the Planning Act, R.S.O. 1990, c. P.13, from the failure of the Town of Oakvilleto adopt the requested amendment to permit the development of an integrated mixed-use,mixed-density community, 1401 Bronte Road, Town of OakvilleApproval Authority File no. OPA 1530.07OMB File No. PL141318

Bronte Green Corporation has appealed to the Ontario Municipal Board under subsection34(11) of the Planning Act, R.S.O. 1990, c. P.13,from the neglect or refusal of the Townof Oakville to amend Zoning By-law No. 1984-63 to permit the development of anintegrated mixed-use, mixed-density community, 1401 Bronte Road, Town of OakvilleMunicipal File No.Z.1530.07OMB File No. PL141318

WITNESS STATEMENT OF ALICIA JAKAITIS

August 27, 2015

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WITNESS STATEMENT OF ALICIA JAKAITIS

INTRODUCTION

1. The following witness statement is submitted by Alicia Jakaitis, SeniorTransportation Planner, Infrastructure Planning and Policy at the RegionalMunicipality of Halton (the “Region”).

2. The purpose of this witness statement is to provide my evidence andtransportation planning opinion in response to Issues 56, 57, 59 and 60 on theConsolidated Issues List of the Public Agencies. In doing so, I will in someinstances be relying upon the opinions and conclusions of other consultantsretained by the applicant or by the Region.

3. I attended on the Bronte Green property on June 26, 2015 for a site visit.

QUALIFICATIONS.

4. I have over 15 years of experience in the preparation and review of a wide rangeof transportation planning, long range planning and traffic engineering studies,including functional design of Regional Roads. I am a member of the Institute ofTransportation Engineers.

5. I am currently employed by the Region as the Senior Transportation Planner inthe Infrastructure Planning and Policy division. In this role I provide strategicreview of Provincial transportation projects and transportation direction intoofficial plan updates. I am also responsible for the management and delivery ofEnvironmental Study Reports for Regional Roads and review and assessdevelopment applications as they relate to access and impact to the Regional Roadnetwork.

6. I have provided expert transportation related testimony before the OntarioMunicipal Board on several occasions.

7. My qualifications and experience are further detailed in my curriculum vitae,attached to this Witness Statement as Appendix A. My Acknowledgment ofExpert’s Duty is attached as Appendix B.

RETAINER

8. I was requested by Regional legal counsel to provide evidence to the OntarioMunicipal Board for matters pertaining to the potential impact of the proposedsubdivision on the Regional Road network and on other Regional interests relatedto transportation matters.

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MATERIALS RELIED UPON

9. I have reviewed and rely on the following documents in preparing this WitnessStatement:

a) Sustainable Halton Transportation Master Plan, the "Road to Change" (2011)b) Guidelines for the Preparation of Traffic Impact Studies, Regional

Municipality of Halton, January 2015c) Highway Dedication Guidelines, Regional Official Plan Guidelinesd) Bronte Green Subdivision, Merton Tertiary Plan, Oakville Traffic Impact

Study prepared by Read, Voorhees & Associates, February 2014e) Bronte Green Subdivision, Merton Tertiary Plan, Oakville Traffic Impact

Study prepared by Read, Voorhees & Associates, April 2015 (“April 2015TIS”)

f) Draft Plan of Subdivision, Bronte Green, Prepared by SGL Planning &Design Inc., dated April 14, 2015

g) Consolidated Issues List of the Public Agencies

ISSUES TO BE ADDRESSED

10. I will be addressing the following four issues in my evidence:

Issue 56: Does the Traffic Impact Study adequately address the following:

a) Impacts to Bronte Road at the North Service Road;b) Impacts to Bronte Road at the QEW off-ramp;c) Queuing issues with westbound left-turns on the North Service

Road at Bronte Road in relation to the access and operations to theHalton Regional Centre?

Issue 57: Is there sufficient road access to the parcel at the southeast corner ofUpper Middle Road and Bronte Road?

Issue 59: Should an updated Traffic Impact Study be provided to address how theproposed development, including the increase of traffic resulting fromthe proposed development, will impact the access, operations, queuing,sight lines, and other traffic-related issues with respect to:

a) the Woodlands Operation Centre;b) the proposed Halton Regional Police Headquarters;c) the Halton Regional Centre; andd) the internal ring road surrounding the Halton Regional Centre?

Issue 60: Has the applicant obtained the necessary approvals from MTO, giventhe significant impacts to the QEW ramps at Bronte Road and at ThirdLine?

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SUMMARY OF EVIDENCE AND OPINION

11. Issue 56: Does the Traffic Impact Study adequately address the following:

a) Impacts to Bronte Road at the North Service Road;b) Impacts to Bronte Road at the QEW off-ramp;c) Queuing issues with westbound left-turns on the North Service

Road at Bronte Road in relation to the access and operations tothe Halton Regional Centre?

12. On July 15, 2015, I attended a meeting with the traffic experts. An AgreedStatement of Facts (“ASF”), attached to this Witness Statement as Attachment 1,was produced following this meeting that sets out the areas of agreement andagreed outstanding technical issues. The ASF does not capture all of the areas ofdisagreement between the parties relating to transportation matters.

13. As noted in Agreed Statement #2 in the ASF, I agree that the impacts to BronteRoad at North Service Road have been addressed through the April 2015 TIS. Asa result, Issue 56a) is no longer being pursued by the Region.

14. As noted in Agreed Statement #5 in the ASF, I agree that clarification regardingthe Ministry of Transportation’s (MTO) jurisdiction for approval of the April2015 TIS with respect to impact to the QEW interchange at Bronte Road isrequired. Issue 56b) remains an issue until such time that MTO issues finalcomments on the April 2015 TIS.

15. As noted in Agreed Statement #2 in the ASF, I agree that queuing issues with thewestbound left turns at the North Service Road and Bronte Road intersection havebeen addressed through the April 2015 TIS.

16. Issue 57: Is there sufficient road access to the parcel at the southeast cornerof Upper Middle Road and Bronte Road?

17. This issue is primarily a Town issue, as it addresses the internal road networkproposed by Bronte Green. However, given the agreed outstanding technicalissues identified in the ASF, I agree that there is insufficient road access to theparcels located at the southeast corner of Upper Middle Road and Bronte Road.

18. The draft plan submitted by the applicant only identifies a single, internal accessto these lots (Street ‘V’). In the event that the only access to the parcel at thesoutheast corner of Upper Middle Road and Bronte Road is unavailable orblocked, there is no means for emergency services to access these lots, therebycompromising emergency service response time. In my opinion this is an issuethat must be addressed before the draft plan can be approved.

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19. Issue 59: Should an updated Traffic Impact Study be provided to addresshow the proposed development, including the increase of traffic resultingfrom the proposed development, will impact the access, operations, queuing,sight lines, and other traffic-related issues with respect to:

a) the Woodlands Operation Centre;b) the proposed Halton Regional Police Headquarters;c) the Halton Regional Centre; andd) the internal ring road surrounding the Halton Regional

Centre?

20. The applicant’s draft plan proposes a connection from the subdivision to BronteRoad via Street ‘C’’. The extension of Street ‘C’ is proposed on lands owned bythe Region and that are currently being used as part of the Region’s WoodlandsOperations Centre (“WOC”). A map showing the proposed Street ‘C’ extensionin relation to the existing WOC and road network is found at Attachment 2.

21. As noted in Agreed Statement #6 in the ASF, all of the traffic experts agree thatIssue 59 is applicable if the extension of Street ‘C’ through the WOC is includedas part of the application.

22. The experts also agree as part of the “outstanding technical issues” that

a) there is a need for clarification regarding either the inclusion or provision forthe extension of Street ‘C’ through the WOC;

b) there is a need for additional transportation information regarding either theinclusion or provision for the extension of Street ‘C’ through the WOC;

c) the impacts to the road network design as a result of either the inclusion orprovision for the extension of Street ‘C’ through the WOC have yet to bedetermined; and

d) a Revised TIS will be required in the event that the proposal changes or ifStreet ‘C’ is to extend through the WOC.

23. It is unclear whether the applicant still seeks this extension of Street ‘C’ as part ofthe application. To date, information has not been provided to clarify theoutstanding technical issues identified above, nor has information been providedto outline the impacts to the road network design as a result of either the inclusionor provision for the extension of Street ‘C’ through the WOC.

24. As noted in Agreed Statement #6 the impacts of the Street ‘C’ extension to theproposed internal road network of the subdivision and to the Halton RegionalCentre (“HRC”) ring road and WOC access were not addressed in the April 2015TIS. There is insufficient information available to determine the appropriateness

CURRICULUM VITAE OF ALICIA JAKAITIS

ACADEMIC BACKGROUND University of Toronto, 2000: Bachelor of EnvironmentalManagement (Honours, Geography & GeographicInformation Systems)

PROFESSIONAL EXPERIENCEFebruary 2015 – Present

January 2009 – February 2015

September 2001 – January 2009

Acting Senior Transportation PlannerInfrastructure Planning and Policy (department realignment)Public WorksRegional Municipality of Halton

Provide strategic review of Provincial transportationprojects) and provide transportation direction into OfficialPlan updates. Responsible for management and delivery ofEnvironmental Study Reports for Regional Roads andmentor 2 junior staff.

Review and assess development applications as they relateto access and impact to the Regional Road network utilizingestablished Halton Region and MTO standards andguidelines. Provide and review screenline transportationanalysis for all Secondary Plan and review and assessNoise Impact Studies and assist in Noise Retrofit projects.

Transportation CoordinatorTransportation ServicesPublic WorksRegional Municipality of Halton

Duties as noted above.

Technical AnalystTraffic DevelopmentPublic WorksRegion of Peel

Review and assess development applications andengineering submissions as they relate to developmentrelated infrastructure improvements. Review and assesssecondary plans, traffic impact and planning studies.Work with Capital group to review modelling workingcompleted as part of Environmental Assessment Studies.Review engineering submissions for proposed road works.Draft site plan and access agreements, manage letters ofcredit, collect fees and coordinate financing of road projects.Provide expert testimony at the Ontario Municipal Board.

Appendix A

Appendix B

Attachment 1

Attachm

ent2

Attachment 3