Thank you for the…

Thank you for the opportunity to provide comments on the proposal to simplify and standardize official plans. Below are the Town’s comments in response to the discussion questions identified in the ERO posting.

A. Standardized Schedules, Overlays and Data

1. What is your perspective on the changes being considered to simplify and standardize the structure and contents of official plans?

The Town of Halton Hills is currently in the process of preparing a new Official Plan. A key objective of this undertaking is to simplify and standardize the structure and content of the document to enhance its usability and accessibility for all users. It is important to recognize that while standardization may offer some benefits, it must allow for flexibility to reflect local conditions, priorities, and community character. Halton Hills is a diverse municipality with unique geographic, economic, and social attributes that must be appropriately addressed in its Official Plan.

One area of concern is the treatment of Secondary Plans within the proposed standardized format. Additional comments have been provided on this topic under question #4. In addition, considering that through the standardization of Official Plans, Indigenous Consultation continues to be identified, the Province should provide guidance to municipalities regarding when consultation with these communities is to take place and the level of consultation with each indigenous community that has an interest in the area.

2. What distinctions should be made between the content of upper and lower-tier official plans? What considerations should apply in municipalities where the upper-tier official plan acts as the lower-tier official plan?

This question does not apply in the case of the Town of Halton Hills. As of July 1, 2024, when the Region of Halton ceased its planning responsibilities, the Town of Halton Hills assumed implementation of the Regional Official Plan. As part of the ongoing Town’s Official Plan Review, applicable Regional policies will be integrated into a single, comprehensive Official Plan. This approach eliminates the need to distinguish between upper- and lower-tier content within the Official Plan, as the Town will be implementing the Region’s policies directly.

3. What is your perspective on limiting development standards in official plans? To what extent should development standards be set out in official plans vs in zoning by-laws?

The Town of Halton Hills views the Official Plan as a high-level policy document that guides long-term land use planning and growth. It establishes the overarching vision and strategic direction for the community, which is then implemented through more detailed regulations in the Zoning By-law. Land use policies in the Official Plan, such as permitted uses, densities, and building heights, are essential to ensuring that future development aligns with the Town’s goals and objectives. These policies help balance growth with social, economic, and environmental priorities, and provide clarity and predictability for both the public and development community.

While the Zoning By-law is the appropriate tool for setting out detailed development standards, such as setbacks, lot coverage, parking requirements, and other site-specific provisions, the inclusion of density and height standards in the Official Plan is critical. These standards serve as a framework for evaluating development proposals and ensuring that future growth supports the Town’s vision for complete, sustainable, and well-designed communities.

In summary, the Town supports a clear distinction between the role of the Official Plan and the Zoning By-law. The Official Plan should continue to provide high-level guidance, including key development parameters like density and height, while the Zoning By-law should contain the detailed standards necessary to implement those policies effectively.

4. What is your perspective on the changes being considered regarding secondary plans and site-specific policies? Are there other ways to address these policies?

Secondary Plans are a critical tool for facilitating appropriate and well-planned development. These plans play a vital role in translating the broader goals of the Official Plan into detailed, area-specific policies that guide growth in new communities or the redevelopment of existing ones. The Town has invested significant effort in developing a number of Secondary Plans that provide detailed, area-specific policies to guide development primarily in new employment and residential areas. These plans are tailored to the unique needs and opportunities of each area and play a critical role in facilitating growth and investment. Secondary Plans provide a framework for the phased development of subdivisions, block plans, and related components, which is a process well understood by and coordinated with the development industry.

The absence of Secondary Plans is expected to create significant challenges, including difficulty in ensuring that growth aligns with community needs for essential infrastructure such as roads and water/wastewater services. It will also make evaluating development proposals more complex without a clear policy framework, potentially leading to delays in the approval process. As such, the Town believes that Secondary Plans should remain as standalone documents to preserve their specificity and effectiveness. Alternative approaches should not compromise the function that Secondary Plans offer to facilitate development.

5. What is your perspective on the number and types of standardized schedules, overlays and data proposed to be required? Should any be removed, or are there any other schedules that could help improve official plans?

In general, the Town of Halton Hills finds the proposed list of standardized schedules/overlays, and data requirements to be appropriate and relatively in alignment with the Town’s current Official Plan, except for a few schedules identified below. However, the Province should provide further clarification on which items are considered schedules versus overlays, as this distinction is important for understanding how the information will be presented, interpreted, and implemented within the Official Plan framework.

It also appears that the preparation of some of these schedules may require additional technical studies or data analysis that could be considered outside the typical scope of an Official Plan project. This raises concerns about the resource implications for municipalities, particularly smaller ones, and the need for provincial support.

Further clarification is needed on the following proposed schedules:

A1 – Estimate of Market Need: More information is required on the methodology and data sources to be used. It is important to understand how this schedule will identify market need as defined and measured.

A2 – Serviced Land Requirement: Additional guidance is needed on how to assess and present serviced land requirements, particularly in relation to infrastructure capacity, phasing, and financial feasibility.

F1 – Wildland Fire Susceptibility: Further detail is needed on how susceptibility will be mapped and what implications it may have for land use planning. Clear direction on data sources, mapping standards, and their role in decision-making would be helpful. Confirmation is needed as to whether this would be applicable to GTA municipalities.

B. Limiting the Length of Official Plans

1. What is your perspective on the changes being considered to limit the length of official plans? Should there be different limits placed on different types of municipalities (e.g., based on population size)? Are there other approaches that could be used to limit the length of official plans?

The Town of Halton Hills believes that the length of an Official Plan should be reasonable and proportionate to the complexity of local planning issues and the planning context. It is appropriate for Official Plans from larger municipalities, or those subject to multiple provincial plans and policy frameworks, to be longer in order to adequately address the range of issues and requirements. For Instance, the Town of Halton Hills is subject to the Niagara Escarpment Plan, the Greenbelt Plan and includes two distinct urban areas (Acton and Georgetown) and a large agricultural area. Therefore, if limits are to be considered, they should be flexible and account for factors such as population size, geographic diversity, and the presence of complex planning areas.

Rather than focusing solely on the number of pages, the emphasis should be on ensuring that Official Plans are clear, well-organized, and easy for the public to understand. A well-structured and accessible document will do more to support the Province’s goal of streamlining development than simply imposing page limits.

C. Creating Permissive Land Use Designations

1. What is your perspective on the changes being considered to standardize the number and type of land use designations?

Through the development of the new Official Plan, the Town of Halton Hills will assess the best approach to standardizing the number and type of land use designations as appropriate. While consistency across municipalities can support clarity and alignment with provincial objectives, it is important that this process remains flexible.

Land use designations and permissions should ultimately be defined by each municipality based on its unique context, planning priorities, and community vision. A one-size-fits-all approach will not be suitable, especially for municipalities with diverse geographic areas, growth pressures, or specific local planning goals.

Standardization can be beneficial where it improves understanding and reduces confusion, but it should not come at the expense of local autonomy or the ability to respond to site-specific conditions. The Town supports a balanced approach that allows for alignment with provincial frameworks while preserving the ability to tailor land use designations to local needs.

2. Would standardized land use designations between upper-tier and lower-tier official plan improve clarity? Where are the opportunities to reduce duplication between the upper and lower-tier official plans in land use designations?

The Region of Halton’s Official Plan is now being implemented directly by the Town and applicable Regional policies will be integrated into a single document as part of the preparation of the new Official Plan. This approach eliminates duplication and improves clarity for users of the document, while ensuring that both regional objectives and local priorities are addressed effectively.

3. Are there additional designations that would be required? Are there opportunities to streamline or further combine some of the proposed designations (e.g. Residential I and II, and Mixed Use I and II)?

The Town of Halton Hills believes that decisions regarding the number and type of land use designations should be made by local municipalities through their Official Plan reviews. Each municipality has its own unique context, planning priorities, and community vision, which should guide the structure and content of its land use designations.

While there may be opportunities to streamline certain designations, these decisions are best made locally, based on how land use patterns function within the community and how policies are intended to be implemented. The Town will assess the most appropriate approach to land use designations as part of the development of its new Official Plan. Any changes will be guided by the need to balance clarity, flexibility, and alignment with local planning goals.

4. Are there implications to making land use designations more streamlined and permissive?

The Town of Halton Hills believes that while streamlining and making land use designations more permissive may offer benefits in terms of clarity and efficiency, doing so at the provincial level could lead to unintended consequences. Specifically, it may result in permissions that are not appropriate for certain areas, potentially creating land use compatibility issues that can only be properly assessed at the local level.

Each municipality has unique geographic, environmental, and community characteristics that must be considered when establishing land use designations. A more permissive or generalized approach may overlook these local nuances, leading to development that conflicts with existing uses and infrastructure capacity. Therefore, any effort to streamline land use designations should be guided by comprehensive local Official Plan reviews. Municipalities are best positioned to determine the appropriate level of flexibility and detail in their land use policies, ensuring that development aligns with both provincial objectives and local priorities.

D. Transitioning to a New Framework

1. What is your perspective on the changes being considered to transition to a standardized official plan framework?

2. What is a realistic implementation timeline for your municipality to update its official plan to comply with a standardized framework (e.g., structure, land use designations, page/word limits), and why? Please consider staffing, council cycles, data/mapping updates, public engagement, and statutory review requirements in your response.

3. How can the province best support municipalities in transitioning to a simplified and harmonized official plan framework?

Support from the Province should include clear guidance, technical assistance, and flexibility to accommodate local contexts and timelines. This will ensure that municipalities can adopt the standardized framework effectively without compromising their planning processes.

To best support municipalities, the Province should ensure that any transition to a simplified and harmonized Official Plan framework aligns with the current stages of Official Plan reviews. In the case of Halton Hills, the Town is entering the policy development phase of its Official Plan Review and therefore implementation of a new framework would have to take place during the next 5-10 year review.

It is important for the Province to recognize that municipalities have already invested significant resources into updating their Official Plans to conform with existing provincial direction. Introducing further changes at this stage could result in inefficiencies, duplication of effort, and delays in implementation impeding the expeditious delivery of housing. The Town supports a thoughtful and coordinated approach to standardization, but it must be flexible enough to respect the timing and progress of local planning processes.

E. Submission of Official Plans through Online Portal

1. Do you support the move toward allowing submission of official plan information and documents through an online portal? Why or why not?

2. What benefits and/or risks do you foresee from transitioning to submission through an online portal?

The Town of Halton Hills would support the move toward allowing submission of Official Plan information and documents through an online portal, provided that the system simplifies the process and facilitates clear coordination and communication with provincial staff. An online portal could improve efficiency, reduce administrative burden, and enhance transparency if designed effectively. However, it is important that the platform is user-friendly, secure, and adaptable to the needs of municipalities. The Town encourages the Province to engage with municipalities during the development of such a system to ensure it meets practical requirements and supports the broader goals of streamlining planning processes.