I think that these changes…

I think that these changes are good. I would suggest clarification on removing third party appeal rights. Is the intent to prevent third party appeals of comprehensive zoning bylaws initiated by municipalities as well? I think that removing the fee refund for zoning bylaw amendments and site plan control applications is a good thing - it will allow more time for applicants and municipalities to work through issues. I do believe the proposed change to make pre application consultation optional is a dangerous and slippery slope because it will result is a lot of incomplete applications that may result in proposals that are just not good planning simply because the applicant does not want to go through the pre application consultations process. Municipalities should have the discretion to determine if a pre application consultation is required or not. Please consult and consider comments for municipalities and not just developers in the GTA - after all, Ontario is more than just Toronto.