In considering the proposed…

In considering the proposed legislative changes from a Perth County context, we respectfully provide the following comments for consideration:

1. County Planning Staff are concerned with the permissions being granted to the Minister to forgo compliance with the Provincial Planning Statement. Such exemption further removes municipal decision making power and the public process from planning and development in the Province. The modification builds upon Minister Zoning Orders, Special Economic Zones, and Bill 30 exemptions, which all make the Provincial Planning Statement and the provincial planning process, obsolete. This also undermines the many checks and balances that are in place to ensure good planning occurs across Ontario.

2. County Planning Staff require clarity on how Minister decisions should be applied at a local level given that Perth County Council, and staff, would still be required to make decisions affecting planning matters that are consistent with the Provincial Planning Statement, as per Section 3(5.a) of the Planning Act. An example being where the Minister has approved an Official Plan and made modifications that are not consistent with the Provincial Planning Statement: How can the County make decisions that are consistent with the PPS if the guiding Official Plan document is not consistent with the PPS?

3. The ERO posting indicates that, where Minister’s decisions are exempt from PPS consistency, “a transparent and accountable oversight framework would be developed to support implementation”. However, no draft framework has been released. Staff are unable to provide meaningful comments regarding the implementation of this amendment without fully understanding the situations where Minister exemption would apply. Staff request that the Province release a draft framework for review and commenting period before enacting the exemption clause for the Minister.

The following general comment is provided regarding commenting timelines for Bill 60:

4. Over the past year alone, there have been at least 12 bills and regulations released by the Province that have significantly changed the planning policy and development framework within Ontario. The frequency in which policy changes have been released by the Province and the short commenting periods associated with each change are not conducive for meaningful feedback, as municipal staff are not provided an appropriate amount of time to understand the implications of Provincial directions before the next round of changes are released. The rapid-fire release of legislation changes, combined with limited staffing capacity and statutory review timeline requirements, negatively impacts County planning staff’s ability to provide meaningful comments on such policy changes. Meaningful comments are not possible where staff are only given a matter of days to review, digest, understand, and comment on legislative changes being made to dozens of Acts. Further, frequent release of omnibus bills at the Provincial-level takes away staff’s focus from local policy initiatives. A month spent on reviewing, understanding, and commenting on provincial policy changes is a month taken away from updating policies and regulations that are already outdated at the local level.

The above-noted comments have been discussed by County Council and endorsed for submission to the Ministry for consideration regarding the important amendments proposed through ERO Number 025-1097