Thank you for the…

Thank you for the opportunity to comment on this posting. The County of Brant provides the following commentary and refers the Province to the Council-approved staff report for additional context (RPT-0159-26).

The proposed changes, together with Bill 23, would require municipalities to accept a broader range of lands for parkland dedication. Allowing developer-identified lands, including encumbered lands and POPS, at a 70 percent credit may result in smaller, fragmented, or constrained parcels that are unsuitable for active recreation and limit municipal parkland and climate objectives. In practice, these lands are often not functional for sports fields or courts, and the 70 percent credit may require municipalities to rely on cash-in-lieu for the remaining 30 percent where parcels are too limited in size or function.

The County is also concerned about added administrative, legal, and agreement negotiation requirements that may affect approval timelines. The County recommends a standardized template agreement for these lands to reduce administrative burden and requests clarity on when parkland decisions must be made in the application process.

While the eligibility criteria emphasize accessibility, visibility, and public comfort, key details remain unclear, including standards, long-term maintenance responsibilities, delegated decision-making authority, and appeal risk through the Ontario Land Tribunal. The County requests further clarity on how these matters will be defined. While Privately Owned Public Spaces are typically maintained by condominium corporations, it remains unclear whether the Province intends to assign responsibility to a specific entity.

Should any additional information be required, the County of Brant would be happy to have further discussions on this topic. Do not hesitate to reach out to us for additional input.