Please reconsider the…

Please reconsider the proposed removal of planning responsibility from the specified Regions, particularly in this period of anticipated significant growth. Regional Official Plan amendments were democratically produced by cities, rural municipalities and regional government over the past three years in full compliance of the Province’s directives, using the province’s formula for projecting and accommodating the population growth to 2051. In the case of Waterloo Region, our sustainable Region Official Plan provides for more housing construction than the targets set out in Bill 23. The Province’s recent amendments to Halton, Hamilton and Ottawa’s ROPs will produce more sprawl, compromise our environment, remove needed farmland and require inefficient servicing by local authorities without necessarily producing more housing or more affordable housing.

I appreciate the interest in seeking efficiencies, but recommend seeking other options to eliminating our regional planning structure. Waterloo and Kitchener meet along city streets, with no buffer. A lack of coordination is likely to produce harmful results. Please also note that impediments to change can be introduced by all levels of government. When the Province struck Section 37 from the Planning Act under Bill 108 in 2019 -- with understandable intent -- Kitchener’s plan for its downtown zoning was rendered inoperable. A new plan for our downtown has yet to be considered by Council almost three years later. This has led to heightened tensions between the community and the development industry, more OPA and ZBA applications and more appeals to the OLT. And when the Province re-interpreted the 10-minute walking distance around Major Transit Stations, it stopped progress on implementation of land designations and zoning. Being clearer in goals, more flexible in means and more collaborative may yield quicker and better results.

Please check with local governments whether one year will be sufficient time to implement zoning near MTSAs before passing the legislation.

Please amend the Bill such that the rights to an appeal are not curtailed. What if the third party is right? The requirement to display to the Tribunal the grounds for appeal, and the Tribunal’s power to deny a frivolous application should be sufficient.

Please also review the mandated timelines for consideration of OPAs and ZBAs and find a better way to require Council’s to rule on applications within mandated timelines rather than granting the right to an appeal to the OLT on the basis of a non-decision by Council. All parties deserve fair access to a timely local decision. Requiring the public to deliver their comments to the OLT as opposed to local planning staff and Council is an unfair time and financial burden.

I am also concerned about the removal of site plan control from developments of less than 10 units and the curtailment of site planning jurisdiction. Site plan control permits development with less conflict and greater sustainability. If the Province intends to manage matters currently handled via site plan control via other mechanisms, such as Building Code, and so forth, please work with local governments to identify acceptable transfers of authority and communicate the plan to the public before passing the legislation.