We are writing to extend our…

We are writing to extend our sincere congratulations to the Government of Ontario on the proposed Provincial Planning Statement 2024 (ERO #019-6813). As builders work to meet the increasing demand for housing, the policies in the planning statement – particularly around land availability for development, and new infrastructure to support development – help industry meet the ambitious goal of building 1.5 million new homes by 2031.

While we support the PPS 2024 overall, we request modifications to remove Sections 22(7.3) and 34(11.0.5) of the Planning Act to allow applicants to make appeals to the Ontario Land Tribunal, as we have concerns around any municipal refusals and non-decisions being sheltered from appeal. While we understand the intent behind this provision, to streamline decision-making and empower municipal councils, we believe that this restriction could have unintended consequences for key development projects.

The ability for builders to appeal municipal council decisions on employment land conversions is essential in ensuring that decisions are made with a balanced view of both local and provincial needs. Without the possibility of appeal, there is a risk that the defined power of municipal councils could potentially hinder the adaptability required for effective land use planning.

We urge the Ministry of Municipal Affairs and Housing to reconsider this aspect of the Planning Act and the PPS 2024 and explore mechanisms that would maintain the role of appeals in the process, while still respecting the authority of municipal councils. This would provide a necessary check and balance to ensure that decisions on employment land conversions are made with comprehensive consideration of both local and broader provincial impacts.

We are eager to discuss these concerns with you and appreciate your consideration in advance.