The Eastern Ontario Wardens’…

The Eastern Ontario Wardens’ Caucus (EOWC) appreciates the opportunity to provide comments on Bill 98 as part of the consultation process. The following comments reflect municipal implementation considerations across eastern Ontario’s rural and small-urban municipalities.

1. Standardized Official Plans

In general, the EOWC has no concerns with the intent to standardize Official Plans.

2. Building Code Reform

The legislation is proposing to shorten the Building Code and establish a third-party advisory body comprised of engineering, construction, and code specialists to identify opportunities to streamline existing requirements.

The EOWC requires municipalities to have a formal and meaningful role in the review process to ensure local implementation realities, including rural and small-urban conditions, are fully considered.
The EOWC notes concern regarding proposed immediate changes that would remove or reduce environmental building and construction standards. Any reform to the Building Code must continue to support climate resilience, energy efficiency, and long-term asset sustainability.

3. Communal Servicing

The legislation is proposing to create regulation-making authority to establish future criteria and conditions under which municipalities would be required to consent to communal water and wastewater systems. Further consultation is expected on these criteria and conditions. Non-municipal systems would be classified as “public utilities,” with no clear provincial backstop in the event of system failure.

The EOWC requires further clarification on this framework and has significant concern regarding the potential for municipalities to assume responsibility for system failure. Current Ministry practice often defaults to municipal assumption of failed systems, including the requirement to take over, upgrade, and operate systems to full municipal standards, creating substantial and unsustainable financial impacts.

Recommendation: A clear provincial liability and funding framework is required with fulsome consultation that accounts for the 2026 municipal elections commitments at the local level.

4. Projection Methodology Guideline (PMG)

The EOWC is concerned that provincially determined forecasts may not reflect local growth conditions, infrastructure planning requirements, or economic development priorities, resulting in regional planning inequities. The provincial government must work closely with municipal staff to ensure alignment and data consistencies.

5. Minimum Lot Sizes

The EOWC supports intensification in fully serviced urban areas where it aligns with infrastructure capacity and municipal planning objectives. Municipal flexibility is required to address local servicing constraints and community context.

6. Encumbered Parkland Dedication

The EOWC has concerns with provisions requiring municipalities to accept encumbered lands, including easement-restricted parcels and privately owned public spaces (POPS), as parkland dedication.

Concerns include:
• Risk of low-functionality or constrained lands being dedicated as parkland
• Ongoing municipal maintenance and liability obligations
• Limited usability of encumbered or restricted spaces
• Lack of clarity regarding POPS governance and maintenance responsibilities
Recommendation: Municipalities should retain discretion to ensure parkland dedication consists of functional, accessible, and usable public space.

7. Site Plan Control Reform

The EOWC is generally neutral on proposed reforms, noting that impacts will vary across municipalities.

Concerns include:
• Reduced ability to manage site design, servicing, and compatibility in some contexts pending capacity
• Disproportionate impacts on rural and small-urban municipalities
Recommendation: Municipalities should retain flexibility to apply site plan control or be provided equivalent tools.

8. Minister’s Zoning Orders (MZOs) – Public Notice

The EOWC has concerns regarding the removal of public notice requirements for amendments or revocations of MZOs.

Concerns include:
• Reduced transparency for municipalities and the public
• Impacts on local planning and infrastructure coordination
• Need for clarity on notification requirements for all MZO changes

Recommendation: Municipalities should continue to receive formal notification of all amendments and revocations.

9. Secondary Plans and Area-Specific Policies

In general, the EOWC supports continued municipal authority over secondary plans and area-specific policies. Secondary Plans are essentially Appendices to Municipal Official Plans, necessary policy to guide neighborhood or community scale planning.

Concerns include:
• Essential tools for community-scale planning
• Support coordination of infrastructure, servicing, and growth management
• More details are needed

Recommendation: Municipal authority to establish and apply these tools should be maintained without restriction.

10. Complete Application Requirements

The EOWC supports standardization of application requirements and expanded recognition of qualified professionals.

Concerns include:
• Municipal ability to assess application completeness must be preserved
• Requirements must reflect local context and site-specific conditions
• Professional qualifications must ensure accountability and oversight

Recommendation: Establish a standardized baseline while preserving municipal discretion for additional studies.

Conclusion

The EOWC supports efforts to improve efficiency and clarity in Ontario’s land use planning framework. However, successful implementation requires flexibility, transparency, and recognition of municipal diversity.

We thank the Ontario government for the opportunity to provide input and look forward to continued collaboration.

Contact the EOWC at info@eowc.org