Comment
I would like to commend the Province for advancing reforms aimed at simplifying, standardizing, and improving the efficiency of Ontario’s planning system. The recognition that the current framework is fragmented, complex, and often inconsistent is both accurate and important.
However, I respectfully submit that the proposal does not fully address a critical gap affecting existing residential properties, particularly legacy urban lots in established neighbourhoods such as Etobicoke in the City of Toronto.
In these contexts, homeowners frequently encounter overlapping and conflicting regulatory frameworks, including:
- Zoning By-laws
- Municipal Code provisions
- Planning Act requirements
- Public right-of-way controls
In addition, there is often a lack of coordination between municipal divisions, including Planning, Zoning, Building, Transportation Services, and Municipal Enforcement. These systems operate in parallel rather than in alignment, which can result in contradictory requirements and practical deadlock situations.
As a result, homeowners are often required to pursue disproportionate and costly planning pathways, such as repeated Committee of Adjustment applications or full Zoning By-law Amendments, despite the absence of new development, increased density, or land use change. In many cases, these processes can exceed $60,000 in costs and involve prolonged timelines, even for minor, site-specific residential matters such as parking configuration, driveway access, or landscaping adjustments.
This creates a planning environment that is not only inefficient but also misaligned with the Province’s stated objectives of reducing red tape, improving consistency, and accelerating approvals.
In light of this, I strongly encourage the Province to consider the introduction of a new planning tool, which I refer to as a Minor Residential Zoning Order (MRZO), or an equivalent mechanism.
Such a tool would:
- Enable low-impact, site-specific residential adjustments without requiring full rezoning
- Provide a streamlined alternative to repeated Committee of Adjustment applications
- Address conflicts between overlapping regulatory frameworks
- Support practical and lawful use of existing residential properties
- Align directly with the Province’s goals of efficiency, predictability, and reduced administrative burden
Additionally, I encourage consideration of policy direction that would extend “substantial renovation” or grandfathering principles, currently applied to dwellings, to exterior residential elements such as walkways, parking pads, driveways, side yards, rear yards, fences, and accessory structures where long-standing or improved conditions exist.
These measures would help ensure that planning policy reflects real-world conditions in established neighbourhoods, rather than creating barriers for homeowners attempting to maintain or modestly improve their properties.
Thank you for the opportunity to provide input on this important initiative. I would be pleased to provide additional information or examples if helpful.
Supporting links
Submitted April 16, 2026 12:19 AM
Comment on
Proposed Planning Act, City of Toronto Act, 2006, Building Code Act, 1992 and Municipal Act, 2001 Changes (Schedules 1, 2 and 7 of Bill 98, the Building Homes and Improving Transportation Infrastructure Act, 2026)
ERO number
026-0300
Comment ID
184559
Commenting on behalf of
Comment status