May 14, 2026 Ministry of…

May 14, 2026

Ministry of Municipal Affairs and Housing 

Provincial Planning Branch 
13th Floor, 777 Bay Street 

Toronto, ON, M7A 2J3 

Subject: Proposed Changes to Support Standardizing of Parkland Requirements Under the Planning Act

We support the Province’s proposal to standardize parkland dedication requirements and provide greater clarity regarding developer-identified parkland, encumbered lands and privately owned public spaces (POPS). The current system is highly inconsistent across municipalities and often results in lengthy negotiations and uncertainty.

Mattamy Homes has a long and proud history in the homebuilding sector. Founded in 1978, we are Canada’s largest residential real estate developer, building master-planned communities and homes of every type, including single-detached, townhomes, mid-rise, and high-rise. In Canada, our communities stretch across the Greater Golden Horseshoe Area, as well as Ottawa, Calgary, and Edmonton.

To ensure these reforms meaningfully support housing delivery while maintaining quality public spaces, we recommend:

Establishing clear, province-wide criteria for acceptable parkland dedication lands, including encumbered lands and POPS arrangements, to reduce subjectivity and inconsistent municipal interpretation.

Require municipalities to accept developer-identified parkland where prescribed criteria are met, with limited discretion to reject lands that are functional, accessible and safe for public use.

Recognize that high-density urban development often cannot deliver traditional unencumbered park blocks, and that POPS, linear parks, stormwater-integrated open spaces, mid-block connections and publicly accessible landscaped areas can provide meaningful recreational and community benefit.

Permit encumbered lands to receive proportional parkland credit where the lands remain functional and publicly accessible, rather than applying blanket exclusions or heavily discounted valuation approaches. The proposed credit of 70% is reasonable for such lands.

Standardize how municipalities evaluate and credit POPS and encumbered lands to eliminate project-by-project negotiation and improve predictability at the outset of development applications. It is important that this land valuation process needs to also be the same for other development fees such as Community Benefits Charges, whereas right now the dispute process is different and can lead to unintended outcomes or subjectivity. One has a 3rd party binding arbitration dispute process and the other doesn’t.

Implement firm municipal response timelines for acceptance or rejection of developer-identified parkland, with deemed acceptance where timelines are not met.

Provide applicants with access to a fast and binding dispute-resolution or OLT appeal mechanism where municipalities reject lands that satisfy prescribed provincial criteria.

Standardize municipal agreement requirements for POPS, including maintenance, public access, liability and operational obligations, to avoid lengthy and costly legal negotiations.

Ensure parkland dedication policies reflect modern urban intensification objectives, particularly around transit-oriented communities, mixed-use developments and attainable housing projects where land availability is constrained.

Avoid policies that unintentionally reduce housing supply through excessive parkland requirements or by limiting the ability to use functional alternative open space solutions in urban environments.

Lastly, an area that could use additional clarification relates to what the province considers the appropriate "lot" to calculate parkland against. Will it include lands that are not being developed, and should it account for phasing?

We appreciate the opportunity to provide feedback and look forward to continued collaboration on measures that enhance transparency, efficiency, and timely housing delivery across Ontario. 

For additional information:

Adria Minsky, Director, Public Affairs

Mattamy Homes Canada

Adria.minsky@mattamycorp.com