I was one of approximately…

I was one of approximately 450 people who participated in an information session yesterday lead by Mr. Fraser and other Ministry staff. My comments relate to some of the proposed changes to the Planning Act.

First, I commend the Government for taking actions in an attempt to alleviate the the housing crisis and streamline development approvals.

1. If my understanding is correct, on the one hand the proposed legislation effectively doubles down on planning act processing timelines by imposing penalties if timelines cannot be met, yet on the other hand, the same legislation 'suspends' timelines for the Minister to approve OP's and OPA's. This seems hypocritical to me.

2. I recognize that detailed regulations will need to be put in place, but as a general statement, I do not feel these timelines will have the desired effect. In fact, it may do the opposite, as evidenced by the many comments during the session, it appears Municipalities have already figured out an 'end around' by front loading the process and essentially delaying the acceptance of a complete application essentially until a site plan and supporting documents are reviewed, agreed to and virtually ready to approve. On this point, Provincial staff have indicated that OP policies will go a long way to inform applicants about what is a complete application. I respectfully disagree and to be blunt, such a thought is naïve. OP's are high level policy documents and my experience with 'complete application policies' is that they are very high level, and simply list the full range of studies that may be required as part of a complete application. I fail to see how OP policies could be detailed enough to have a meaningful impact. This has to be done through pre-consultation. I also feel that these revised procedures to avoid having to give a refund will result in far less collaboration - what if it takes a developers consultant 60 days to revise plans/studies? Is that the CIty's fault?

3. In my community we are happy to utilize recently approved funds for us to hire more people, all in an effort to streamline processes and have more people available to assess and process applications. What about increasing the Provincial staff compliment? This was mentioned at the meeting and Mr. Fraser indicated that Provincial staff are committed to responding in 45 days. Lets take a rezoning for example, 90 day timeline, 20 days for public notice, 20 days for appeal, plus 45 days to wait for Provincial comments if needed, that leave 5 days for everything else to happen!!! Not feasible. I have experiences with MTO staff where months have passed with no comments, and it is not feasible to approve a new lot for example, that might need an entrance permit onto a highway without knowing whether or not that entrance permit would be granted. Yes, as Mr. Fraser suggested, such a permit could be conditional upon approval, but that opens a door that maybe should not have opened in the first place. The solution: Front load things and make MTO comments saying an entrance permit is obtainable as part of a complete application. Again, timelines just get shifted with no real gain. I have another example of an OP that I'm working on. Provincial Core Team meeting was held in early December. MTO staff did not attend. It is April 21 and we still do not have MTO comments after 2 follow ups, and a commitment to have comments by mid Feb! There needs to be an increase to the relevant Provincial staff compliment to make this work. Otherwise, not will Bill 109 fall flat, it will be viewed as very hypocritical and one sided - see comment 1.

4. If the Province is thinking of putting together some form of working group to look at meaningful ways streamlining the development process I am happy to be a part of that.

In my humble opinion, the timeline/refund matters contained in Bill 109 will not achieve the governments goal of 'reducing red tape', in fact, it will increase red tape by front ending the process. In my community, it is often Provincial requirements that have resulted in significant delays. If the Province is serious about removing red tape, it needs to look no further then many of it's regulations. While I commend the government for pumping the breaks on the revised Min. Distance Separation Guidelines that would effectively double the influence area of a noxious/sensitive use, I think there is room to alter the existing guidelines to allow Municipal staff (without a costly consultant study) to make judgement calls. For example, lets say we have a residential development that is 600m from a Class 3 industrial use, but separated by 3 or 4 blocks of existing urban development - The D-Series guidelines requires a costly study whereas the option for a local judgement call could avoid this, thereby reducing timeframes and reducing overall costs - thereby supporting affordable development. Another example would be fish habitat. Every community has numerous watercourses running thought them, with 120m 'buffers' on either side, requiring costly studies prior to any development within these areas, even though there may be 'intervening development' between them. How about some local flexibility related to Natural Heritage Features. Or, funding projects by either the Province or Municipalities to further refine these catch all setbacks - this would apply to Natural Heritage Features and D-series Guidelines, and archaeological potential, among others.

Thank you