Comment
Comments re: Planning Act Changes to Site Plan control:
• Bruce County and its local municipalities have not previously applied broader enhanced development standards through zoning or site plan control.
• Rural municipalities often encounter proposals for development in or adjacent to natural heritage features as defined in the Provincial Planning Statement (PPS), where proponents must ‘evaluate and demonstrate no negative impact to a feature or its ecological function’ per the PPS.
• Environmental Impact Studies often provide recommendations for implementation through site plan approvals, such as tree preservation / retention or replanting of native species post-development, as a requirement to demonstrate that development meets the PPS test. The ability to have such provisions is important to facilitating development in these areas that is consistent with the full scope of the Provincial Planning Statement; absent these tools to facilitate mitigation of impacts, development may not be able to proceed or may require a reduced scale in order to demonstrate no negative impact.
• It is unclear whether mitigative measures (such as landscaped buffers) to address compatibility between sensitive uses would remain within the scope of site plan control
• We request the province continue to provide municipalities with the necessary tools to implement the full scope of provincial direction.
Comments regarding legislative authority for Minimum Lot Sizes for Urban Residential Land
• Establishing a province-wide minimum standard may reduce the need for zoning amendment applications to permit smaller lots to be created and facilitate more innovation in housing forms.
• The size proposed appears to be most consistent with townhouse housing forms in rural areas where onsite parking is a typical requirement, however some zoning by-laws have separate zones for single/semi-detached/duplex dwellings and associated ARUs and townhouses.
• While provisions may be self-limiting, there may be challenges with snow storage on smaller lots with one or more dwellings and onsite parking.
• Planning considerations may lead to lot sizes that are multiples of the proposed minimum; zoning by-laws (including site-specific provisions) can offer a way to make area-specific requirements visible; absent zoning as a tool, these considerations may need to be addressed through other, less visible instruments like subdivision agreements.
Submitted April 29, 2026 10:25 PM
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
185097
Commenting on behalf of
Comment status