As noted in our January 2021…

As noted in our January 2021 submission, MZOs should be used in extremely limited circumstances for projects under urgent timelines, that have high-level strategic importance and address key matters of Provincial interest (e.g. affordable housing projects where funding is contingent upon a construction start deadline or accommodating major employers with tight deadlines). The PPS is the most complete articulation of provincial interests in land use planning. It includes important policy direction regarding the protection of resources, public health and safety, and the quality of the natural and built environment. Examples include protecting significant wetlands from development and ensuring a comprehensive consideration of alternatives prior to expanding urban boundaries.

Statements of provincial policy in land use planning, starting with the the 1992 Wetlands Policy Statement have been crucial to preserving what remains of these crucial natural heritage features and advancing other important planning principles. The proposal could put these planning principles at risk.

The Province should hold itself accountable to its own policies when making land use planning decisions. It is unclear how provincial decisions contrary to its own stated interest could represent good planning and the public interest. The increased propensity for MZOs combined with removal of policies that govern their use could compromise conservation of resources; public health and safety; and the natural and built environment.

It is concerning that legislative changes may be proposed to address a site-specific circumstance, but that this could have broader negative implications over time. Allowing complete ministerial discretion on planning decisions, without the requirement that these decisions be guided by the Provincial Policy Statement introduces unnecessary risk of arbitrary planning decisions.

The Planning Act amendments included in Bill 257 should not be approved as they may undermine good planning in the Province of Ontario. The City of Kitchener recommends against changes to the legislation regarding MZOs.