Executive Summary The City…

Executive Summary

The City of Thunder Bay (CTB) Planning Services supports the Province’s goal of increasing housing supply and enabling economic development across Ontario, including in northern communities. Based on review of the proposed changes, CTB offers the following key considerations:

1. Implementation clarity and capacity: Clear guidance, realistic timelines, and transition support are needed to reflect the operational capacity of northern municipalities.
2. Recognition of municipal progress: CTB has made measurable improvements to streamline development approvals, including through the Ontario Streamline Development Fund; changes should build on this work.
3. Northern context matters: Housing supply in northern Ontario is shaped by construction costs, labour availability, and limited market capacity.
4. Administrative burden: Ongoing legislative change places pressure on limited municipal resources.
5. Local flexibility: Municipal tools must remain adaptable to local conditions.
6. Standardized Official Plans: Standardization should be optional and flexible to avoid reworking effective local frameworks.
7. Long-term outcomes: Growth should support complete, sustainable communities with a strong sense of place.

Introduction

The City of Thunder Bay (CTB) Planning Services appreciates the opportunity to comment on Bill 98, the Building Homes and Improving Transportation Infrastructure Act, 2026, and associated changes to Ontario’s planning framework.

CTB shares the Province’s objectives to increase housing supply and support economic development. The City continues to advance these priorities by improving customer service and modernizing planning policies, processes, and regulations to better support timely development.

General Comments

The proposed changes are intended to support housing delivery; however, their scope and complexity present implementation challenges, particularly in northern and mid-sized municipalities. A more phased and clearly defined approach would support effective implementation.

Implementation clarity and municipal capacity
o Additional details on timelines, transition provisions, and expectations are needed.
o Northern municipalities operate with limited staffing and resources; clear and practical implementation direction is critical.
o Aligning new requirements with existing municipal systems will require time and support.

Building on existing municipal improvements
o CTB has made targeted investments to improve development processes, including initiatives supported through the Ontario Streamline Development Fund.
o Proposed changes should build on this work rather than require retooling systems that are already functioning effectively.

Northern housing context
o Housing delivery in northern Ontario differs from larger urban centres. Key constraints include higher construction and transportation costs, labour shortages and limited industry capacity, and smaller and more variable market demand.
o Planning system changes alone will not address these challenges.

Administrative and operational pressures
o Frequent amendments to the Planning Act create cumulative impacts on municipal capacity.
o Smaller municipalities must balance implementation with day-to-day service delivery.
o Clear guidance, transition timelines, and implementation tools would assist.

Maintaining local flexibility
o Municipalities are best positioned to respond to local servicing, market, and community conditions.
o Flexibility should be maintained in key areas, including land use designations, zoning, site plan control, and application requirements.

Supporting complete northern communities
o Development decisions made today will shape northern communities long-term.
o It is important to continue supporting livable and sustainable neighbourhoods, coordination with infrastructure capacity, and design quality and a strong sense of place.
o Growth should align with the realities and strengths of northern communities.

Standardized Official Plans

CTB Planning Services has reviewed the proposed changes in two phases:
1. overall merits of standardized official plans, and
2. review of the proposed framework.

Our position is that a standardized official plan should be available as an optional tool, rather than a mandatory requirement.
• A standardized approach may benefit municipalities with outdated plans.
• Requiring municipalities with modern, effective plans to restructure them would place added pressure on limited capacity.
• In Thunder Bay, resources would be better directed toward advancing housing and growth initiatives already underway.

The City’s current Official Plan is well understood by staff, consultants, and the development community, and has received positive industry feedback. Applying a standardized structure would largely reorganize existing content with limited benefit.

Land Use Designations and Local Application

The proposed designation framework represents a significant shift from CTB’s approach, which uses sub-designations to reflect local context.

Sub-designations currently support:
• land use compatibility
• rural lot creation
• protection of future growth areas

Transitioning to the proposed model would require re-mapping and reconsideration of how these distinctions are maintained.

Examples:

Service Commercial Areas
o Residential uses are only permitted on certain streets.
o Multiple designations may be required to replicate this approach.

Rural and Growth Areas
o “Rural 1,” “Rural 2,” and “Rural 3” apply different lot creation policies.
o “Growth Area” limits severances and protects future expansion.
o It is unclear how these distinctions would be maintained.

Industrial and Employment Areas
o Current designations manage compatibility based on potential impacts.
o Proposed designations may not fully capture these distinctions without added flexibility.

Clarification requested:
• Whether mapping overlays can be used to vary policies within a designation
• Whether sub-designations (or equivalent tools) will be permitted

Permitted Uses and Policy Direction

The proposed framework identifies uses that must be permitted within each designation.
• It is unclear whether municipalities can apply conditions to these permissions, or
• whether uses must be permitted as-of-right across the full designation.
This distinction is important for zoning implementation and land use compatibility.

While fewer designations may reduce amendments, CTB’s current plan already functions efficiently:
• Fewer than three developer-initiated amendments per year since adoption
• Ongoing staff-initiated improvements have further increased flexibility

Additional Considerations

Site-Specific Policy Areas
o Clarification is needed on whether these can be layered onto base designations.
o Additional comments will be provided under ERO 026-315.

Public Engagement
o It is unclear how requirements to inform and obtain public input will be maintained.

Climate Change Policies
o Clarification is needed on their removal from Official Plans.
o Municipalities remain responsible for climate mitigation and adaptation under provincial policy (s. 2.9.1, PPS 2024).
o Official Plans are the most effective and important tool for implementing provincial planning policy
o Local policy remains important given varying regional climate change impacts.

Designation Clarity
o Distinction between “Employment Areas” and “Major Facilities” requires clarification.

Naming Conventions
o Singular terminology (e.g., “Neighbourhood”) will improve clarity.

Conclusion

CTB Planning Services has reviewed the proposed changes to the extent possible. However, the breadth of the proposals and limited implementation detail make it difficult to fully assess local impacts at this time.

The City welcomes continued engagement with the Province and supports a collaborative approach to refining these changes. CTB respectfully provides these comments for consideration as the Province advances this initiative.