As a planning consultant…

As a planning consultant that prepares Official Plans for municipalities across the Province, my main concern with this initiative is the Transition provisions. While I appreciate seeing that smaller communities would not need to update the format of their Official Plans until the next Section 26 review, some municipalities may get caught mid-stream during their reviews when these provisions come into effect.

In some cases, the Official Plan format may have been crafted and developed in consultation with Council, Staff and community members over long periods of time. In addition to the disruption and delays to the process that these new regulations would cause mid-stream, it would also result in additional consulting fees to revise the document.

I would recommend a combination of these measures to help with the transition:

1 - Establishing a long transition period (perhaps 1 year) before the regulations come into effect to provide ample time for drafted Official Plan documents to be approved.

2 - Exempting from the regulations those Official Plans that have already been submitted to the Minister (MMAH) for the 90-day review under S. 17(17.1) of the Planning Act, or the equivalent process for a lower-tier municipality.

3 - Exempting from the regulations those Official Plans that have already been submitted to the Minister (MMAH) for approval.

Thank you for considering my comments.