November 21, 2025 Province…

November 21, 2025

Province of Ontario – Ministry of Municipal Affairs and Housing

Re: Proposed Changes to the Planning Act (Schedule 10 of Bill 60 – the Fighting Delays, Building Faster Act, 2025)

Thank you for the opportunity to review and comment on the Environmental Registry of Ontario (ERO) posting 025-1097 regarding proposed legislative changes to the Planning Act through Bill 60, the proposed Fighting Delays, Building Faster Act, 2025. The intent of the proposed legislative changes is to further support streamlining land use planning processes; building more homes faster; and creating more certainty in the development approvals processes. The proposed changes under Schedule 10 of Bill 60 include additional opportunities for as-of-right variations from performance standards, changes to the applicability of policy statements to Minister’s decisions, changes to the way Minister’s Zoning Orders (MZOs) are made, changes to the process for modifying policies within Protected Major Transit Station Areas (PMTSAs), and changes to the implementation of Community Improvement Plans (CIPs).

The Simcoe County District School Board (SCDSB) is supportive and understands the critical need for additional residential housing forms and is supportive of the intent to streamline land use planning processes and create more certainty in the development approvals process. As a legislated commenting agency as well as an active participant in the development process, the SCDSB has a unique perspective on the proposed changes. The intent of this letter is to outline and provide feedback on amendments of interest to the SCDSB. Comments are provided in the following table:

# Proposed Legislative Amendments SCDSB Comment
1. Minor Variances (As-of-right Variations from Performance Standards)
Provide regulation-making authority by providing for variations to be permitted “as-of-right" for performance standards identified in the regulation (e.g. building height, lot coverage) on specified lands.
- Include parcels of urban residential lands outside of Greenbelt Area
- Exclude hazardous lands and lands near shorelines and railways
The SCDSB respectfully requests clarification of how the future regulation would be applied to urban residential lands and if the as-of-right variations would be restricted to a particular use(s) on such lands. The SCDSB respectfully requests that schools, as public service facilities, that are located on parcels of urban residential land qualify for the as-of-right variation provisions.

The SCDSB respectfully recommends that the province consider additional opportunities to allow as-of-right variations to performance standards like landscaped open space. As urban school sites continue to trend smaller, the board is required to do more with smaller amounts of land. Additional flexibility in performance standards through additional as-of-right variations would enable the board to more efficiently use existing lands and infrastructure in a cost-effective manner.

SCDSB planning staff respectfully request clarification regarding the calculation of the permitted as-of-right variation when a zoning by-law provision states two potential requirements dependent on another criteria. For example, the Town of New Tecumseth Comprehensive Zoning By-law 2021-128 requires a maximum height in the Institutional Zone of 3 storeys or 15 metres, whichever is less (Section 3.2- Neighbourhood Supporting Zones).

The SCDSB respectfully requests that the province consider what would prevent a municipality from enacting stricter performance standards in order to maintain the effective standard currently permitted by the by-law and thus negating the intent of the permitted variation.

3. Minister’s Zoning Orders
Enable MZOs to be made by non-regulatory orders and published on a Government of Ontario website.
Permit delegation of authority to certain officers, employees or agents of municipality where Minister has required an agreement(s) be entered into between an owner of specified land and a municipality. Provide that the Minister may give direction specifying timelines related to the agreement and make certain orders if the agreement is not satisfied. SCDSB planning staff note that there have been numerous times when MZO support requests to the local municipality have not been circulated to the board and the board’s first opportunity for review and analysis is once the MZO has been posted on the Environmental Registry of Ontario (ERO) website for public consultation. Planning staff highlight the importance of public notification and consultation to ensure that board is able to review the potential impact of an MZO development on local school accommodation and provide comments on items that are relevant to the school board. SCDSB planning staff are concerned that if MZOs are no longer issued as regulations, there will be fewer or no opportunities for meaningful consultation, which negatively impacts the board’s ability to plan for potential impacts to school accommodation from new development. Should MZOs no longer be considered regulations and posted through the ERO website and through e-Laws, the province must ensure that there is still a framework for appropriate notification to provide transparency and accountability regarding government decisions. The framework should also include background studies/reports/plans/etc., or at minimum the planning justification report and a concept plan, being posted for public review to ensure that sufficient information is available for comprehensive analysis.

As school boards are an agency of the province, the adequacy of schools needs to be considered when residential development is proposed through an MZO. This could take the form of consulting with the Ministry of Education directly prior to approval, or consulting with individual school boards prior to approval. Regardless of which consultation process is used, schools, as public service facilities, should be included within MZOs as a permitted use and designated as a block in the plan if the plan is at that stage of detail.

With the Province’s stated goal to construct 1.5 million new homes by 2031 comes the need to ensure Public Service Facilities are sufficient to meet the needs of the residents of these new homes. The Simcoe County District School Board is supportive of the government’s proposals to expedite the approvals process for facilities like schools, which will support the board in its efforts to accommodate growth and ensure that every student has access to quality education.

Should you require additional information, please do not hesitate to contact this office.

Sincerely,

Kristen Bartmann, MPLAN
Planner
Simcoe County District School Board

Cc:

Ministry of Education, Government of Ontario
Catherine Roy, Senior Policy Analyst

Simcoe County District School Board
Corry Van Nispen, Superintendent of Business and Facility Services
Andrew Keuken, Senior Manager of Planning, Enrolment, and Community Use
Sandy Clee, Assistant Manager of Accommodation & Planning
Katie Kirton, Assistant Manager of Planning & Property