The City of Kawartha Lakes’…

The City of Kawartha Lakes’ full comments are attached. These are the key points:

The City supports the Province’s objective to improve the clarity, usability, and consistency of official plans. However, the standardized framework must retain sufficient flexibility to respond to local context. A rigid structure risks shifting complexity to secondary plans or site-specific policies, undermining the intended efficiencies.
The City requests detailed provincial guidance on how the standardized chapters and land use designations are intended to function in practice, similar to other provincial guidance documents (e.g., population methodology guidelines).
Several proposed land use designations require clarification to ensure internal consistency and usability, including:
- The distinction between “Mixed-Use Areas” and “Mixed-Use Commercial Areas”
- The purpose and scope of the “Major Facilities” designation
- The alignment of “Employment Areas” with actual employment patterns
- Potential duplication between “Rural Lands” and “Shoreline Areas”
- Treatment of residential uses in agricultural designations
It is unclear how municipalities are expected to apply designations in relation to prescribed schedules. Clarification is needed on:
- Where detailed land use differentiation should occur (designation, schedules, or policy)
- How to represent density, intensification areas, and park classifications
- How to identify hamlets and smaller settlement areas within the framework
The proposed structure does not clearly accommodate provincially mandated frameworks such as the Oak Ridges Moraine Conservation Plan. Guidance is required on how such frameworks are to be implemented, including whether secondary plans or area-specific policies are intended to play this role.
Clarification is also requested on where affordable housing policies and implementation tools would be incorporated within the standardized framework.
With respect to sustainable design, the City supports the objectives of energy efficiency and environmental performance but requests clarification on what would be prohibited. There is limited evidence that such requirements are a significant source of delay, and a more targeted approach distinguishing functional measures from aesthetic design is recommended.