November 11, 2025 Ministry…

November 11, 2025

Ministry of Municipal Affairs and Housing

Provincial Planning Branch

13th Floor, 777 Bay Street

Toronto, ON

M7A 2J3

PlanningConsultation@ontario.ca

RE: Bill 60, Fighting Delays, Building Faster Act, 2025 – Public consultation

To whom it may concern:

We are opposed to providing the legislative authority to eliminate municipal authority over site plan controls.

The technical briefing for the Fighting Delays, Building Faster Act, 2025 states that:

“Municipalities currently use land use planning tools (often through site plan control) to require enhanced development standards at the lot level. These requirements can vary across different municipalities and add costs to projects. MMAH will identify future changes with the intent of removing so-called “green development standards” at the lot level outside the building to cut red tape and lower home and building costs. This will ensure enhanced site plan controls are eliminated by the spring building season.”

The proposal provides no analysis that supports the proposed changes other than mentioning that a site plan control requirement may increase costs for a builder. In our view, the proposal to eliminate municipal authority over site plan control is a continuation of the erosion of the checks and balances needed in a building permit system to keep it fair and honest. With this proposed change, the building permit system will continue to become more susceptible to occurrences of conflicts of interest, local biases, poor decisions and the negative outcomes that result.

If the Ford government decides to proceed, we hope that it will at least consider that site plan controls will be more valuable on some lands/projects than others.

Consideration should be given to maintaining site plan control authority when issuing building permits for:

• waterfront lots in general.

Particular attention should be given to:

• waterfront lots that include variances in their permit (especially multiple variances),

• undersized waterfront lots,

• undersized waterfront lots that include variances (especially multiple variances) in their permit,

• seasonal homes.

Waterfront Lots

One of the features that makes Ontario beautiful and enjoyable is its natural landscapes, particularly the many lakes and rivers and their natural shorelines.

For this reason, site plan controls may be more appropriate for building permits on waterfront lots in Ontario’s cottage areas compared to lands within an urban core.

Waterfront Lots with Variances / Multiple Variances in Their Permit

In some cases, municipalities are issuing building permits on waterfront lots that allow multiple "minor" variances which cumulatively may not be minor. Municipalities may also grant permits for residential structures that are actually prohibited in their zoning bylaw.

Yet, as a result of the previous More Homes Built Faster Act, 2022, such permits cannot be contested by neighbours.

In such cases, a municipality’s use of site plan controls is an appropriate tool to help mitigate at least some of the negative effects of densification that may be associated with the variances.

Undersized Waterfront Lots

Another important consideration is the size of the lot and the extent to which it is undersized or oversized. In our view, undersized waterfront lots (with grandfathered density) should be handled differently as the densification and impacts on neighbours are exponentially greater due to the lack of buffer that a full sized lot would provide. A municipality should take lot size into account when deciding whether to grant variances in conjunction with the need for site plan controls. Site plan controls can help mitigate at least some of the negative effects of densification that may be associated with undersized lots.

Undersized Waterfront Lots with Variances / Multiple Variances in their Permit

When numerous land use pressures are at play, such as waterfront lots that are undersized and also include multiple variances in their building permits, the negative aspects of over development are maximized. In these cases, having site plan controls available becomes even more important.

Seasonal Homes

Seasonal homes do not contribute to the policy goal of more homes for Ontarians.

Nontheless, changes to the building permit system through the previous More Homes Built Faster Act, 2022 and the proposed Bill 60, Fighting Delays, Building Faster Act, 2025 are green-lighting the construction of seasonal homes. In some cases, such seasonal homes are also associated with all of the concerns mentioned above. They may be on waterfront lots, lots that are undersized and they may have variances or multiple variances in their permits.

In these cases, having numerous mechanisms for oversight becomes even more important. This includes site plan controls.

Thank you for your consideration.

Yours sincerely,

Ontario Resident