Key Areas of Concern &…

Key Areas of Concern & Implications

Limits to CA Appeals
• The current proposal to limit CA appeals to natural hazard policies of the PPS means CAs
cannot appeal on regulatory issues outside of the PPS natural hazard framework (e.g.,
wetlands, regulatory allowances, permitting standards). This may result in second appeals to
resolve CA permitting issues, if these matters cannot be addressed at the same time, which
will result in costly delays in approvals.

Changes to Additional Residential Units Framework
• I support the implementation of an updated additional residential unit framework for the
creation of additional residential units on existing lots; however, to ensure there is no increased
risk to life or property, there should be limits on new units within natural hazards.
• Official Plans and Zoning By-Laws may not be based on the most up-to-date hazard mapping,
which may result in additional residential units being permitted by municipalities in hazard
lands without input from CAs.
• Increased lot coverage throughout a watershed may cumulatively result in increased run-off that
cannot reasonably be mitigated by stormwater management measures. Downstream flood hazards may increase and be reflected in future flood hazard mapping studies once increased lot coverage is incorporated into modeling.

Key Recommendations

Limits to CA Appeals - Reframe proposed Planning Act clauses to ensure CA regulatory and PPS natural hazard matters can be dealt with together to avoid additional appeals or costly delays. Include specific language in Planning Act to clarify that CAs may request party status (but limited to natural hazard and regulatory matters).

Changes to Additional Residential Units Framework - Include qualifying language in the amendment to Ontario Regulation 299/19: Additional Residential Units to limit new units within hazard lands.