City of Waterloo Planning…

City of Waterloo Planning Staff Comments on Bill 60 Consultation on simplifying and standardizing Official Plans

City of Waterloo Planning staff have reviewed the proposed legislative and regulatory changes under Bill 60 Fighting Delays, Building Faster Act, 2025, and provide the following response to the consultation on simplifying and standardizing Official Plans.

General Comments:

In general, we support the stated goal of helping ease the administrative burden associated with developing, maintaining and utilizing Official Plans. A common framework can be a helpful tool for municipalities, community members, the development industry and other agencies that look to Official Plans for policy guidance. However, there needs to be a nuanced approach, and requiring that municipalities adhere too rigidly to a standard framework may have the adverse effect of decreasing the usefulness of an Official Plan to guide the growth of the municipality. More specific comments are provided in the sections below.

We also question the need for these changes at this time. While the intent of the changes being considered is to help build more housing, Official Plans are not the primary bottleneck in the current system. The City of Waterloo currently has over 11,000 approved dwelling units that are only waiting on the developers to pull building permits but have been put on hold due to poor market conditions or other external factors. This is over 6 years of growth for the City. Further, almost 20,000 units are in various points of the planning pipeline, which is enough growth to 2040.

Rewriting Official Plans is a significant change to the planning regime in municipalities across the province. These changes will take time to implement, and there is still a lot of uncertainty in exactly how they will be implemented. This uncertainty has an adverse effect on housing development, as well as municipal efforts to update and improve their own plans and policies. Many development firms and municipalities may put projects on hold until the changes to the Planning Act are finalized and in place. This feeling of uncertainty is exacerbated by the number of changes that have occurred through various Bills over the last number of years. When significant changes are made, municipalities and the development industry both need time to work out the nuances of the new regulations.

Part A: Official Plan Structure and Contents

Part of the stated concern is that because every municipality develops their own Official Plan, there ends up being a large amount of variation between the Official Plans across various Ontario municipalities. From this perspective, we can understand the desire to improve consistency. However, this needs to be balanced with the understanding that all municipalities exist within a unique context, with unique needs, visions and goals. An Official Plan framework that meets the needs of a large urban municipality like Toronto may struggle to meet the needs of a small rural municipality.

Establishing clear parameters of what needs to be included within an Official Plan and developing a basic structure that municipalities can follow can certainly help with cross-municipal consistency, but we would caution against making these parameters too prescriptive. We would encourage this framework to be taken as a ‘starting point’ for a municipality to use in the development of their Official Plans, but to allow modification to meet the specific needs, local context, and objectives of the municipality. Some municipalities may not need all of the proposed land use designation or schedules. Conversely, they may need additional designations or schedules due to the unique local context. As the Ministry will ultimately be the approval authority of these plans, it can decide if the ‘spirit’ of the framework was followed, or if the municipality veered to far off course. We strongly encourage meaningful engagement with municipal planners should the Ministry seek to develop a province-wide Official Plan framework.

In principle, we agree that technical standards and requirements should be left to other by-laws to implement (Zoning, CPPS, etc.), but Official Plans still need to play a role in providing policy guidance on these standards. Not having any guidance for height or development scale, for example, would make it difficult for municipalities to determine if a zoning by-law amendment application is consistent with the Official Plan, as an example. This can have the adverse effect of creating additional uncertainty for the development industry and for the community.

We are concerned with the proposal to remove site specific policies from Official Plans. Every municipality is unique, and there will always be extraordinary situations that require a policy approach that differs from the rest of the municipality. For example, a very specific or uncommon use may be appropriate for a specific location, but not appropriate to be applied more broadly to a larger area in the same designation. Municipalities need to be able to maintain a certain level of flexibility for these situations.

Part B: Limiting the Length of Official Plans

We see little value in setting a limit to the length of Official Plans. If an appropriate framework for what is to be included within an Official Plan is established, the document length will be guided by what is required by the specific municipality to adequately cover the topics and sections in that framework. While smaller municipalities with relatively straight forward requirements will very likely come in well under the limit, larger municipalities with more complex geographies, significant natural hazards, extensive natural heritage features, etc. may struggle to adequately cover all aspects necessary to meet the objectives of Official Plan.

Part C: Creating Permissive Land Use Designations

Having standard designations as a starting point for municipalities to develop their Official Plans could be beneficial and lead to greater consistency across the province, but this needs to be balanced with allowing flexibility so that municipalities can still cater the designations to their specific local contexts. Certain designations may not be relevant to a municipality, and certain designation categories may need additional refinement or subcategorization to respond to unique situations. The standard designations should be a starting point from which municipalities have a mechanism to adapt as needed, provided they are still being true to the spirit of the framework for a consistent land use planning approach.

Part D: Transitioning to a New Framework

Regardless of the timing selected, transitioning to a new framework will be a challenge. Establishing a staggered schedule may be beneficial so that not all municipalities are attempting to update their official plans at the same time, which would put a strain on staff resources, the consultants that are normally involved in such projects, and on Ministerial staff who will be required to review and approve the new official plans.

Part E: Submission of Official Plans through Online Portal

We fully support the implementation of an Online Portal to submit materials to the Ministry, and any regulatory changes to the Planning Act required to implement that. Having a clear, easy to use process to submit information will help reduce administrative burden on both Municipal and Provincial staff. The portal design should provide a confirmation notice that the documents have been successfully uploaded and assigned for review.

 
Specific Responses to Discussion Questions

Part A: Official Plan Structure and Contents

--What is your perspective on the changes being considered to simplify and standardize the structure and contents of official plans?--

Pros:

Streamlined Planning and Faster Approvals
• A uniform structure could reduce the time and complexity of preparing, reviewing, and approving official plans, helping municipalities meet housing and infrastructure targets more efficiently.

Improved Clarity and Accessibility
• Shorter, more consistent plans may be easier for residents, developers, and decision-makers to understand and navigate, enhancing transparency and public engagement.

Reduced Costs and Administrative Burden
• Standard templates and schedules could lower the cost of plan preparation and updates, especially for smaller municipalities with limited planning resources.

Enhanced Provincial Oversight and Alignment
• A standardized framework would facilitate better alignment with provincial priorities, such as housing supply, infrastructure development, and environmental protection.

Facilitates Data Integration and Digital Submissions
• The proposal includes online submission portals and standardized mapping, which could improve data sharing and intergovernmental coordination.

Cons:

Loss of Local Flexibility and Context
• Municipalities may lose the ability to tailor plans to local needs, geography, and community values, especially in rural, northern, or rapidly growing urban areas.

Risk of Oversimplification
• Imposing page or word limits and reducing the number of land use designations could lead to vague or overly permissive policies that fail to address complex local issues.

Potential Erosion of Community Planning Tools
• The proposal may prohibit secondary or site-specific plans, which are often used as important tools for managing more unique development scenarios (new growth or high growth areas, re-urbanization areas etc.) and protecting heritage or environmental assets.

Increased Provincial Control
• Requiring Ministerial approval for changes to complete application requirements and other plan elements could centralize decision-making and reduce municipal autonomy. This level of involvement by the Province can also lead to delays in approval.

Implementation Challenges
• Transitioning to a new framework may require significant staff training, public consultation, and technical updates, which could strain municipal resources in the short term.

--What distinctions should be made between the content of upper and lower-tier official plans? What considerations should apply in municipalities where the upper-tier official plan acts as the lower-tier official plan?--

Upper tier plans where they are in place should be limited to regional level concerns and be more of a general direction setting along with population and growth allocation. Local level plans should address more specific community level considerations such as land use designations and site-specific considerations.

-- What is your perspective on limiting development standards in official plans? To what extent should development standards be set out in official plans vs in zoning by-laws?--

Regarding development standards in Official Plans, the Plans should outline high level expectations and standards while implementation tools such as the Zoning bylaw can provide development regulations. For example, the Official Plan should note the absolute height limit for a given designation (for example height in number of storeys) to provide clarity and certainty for the community, but the zoning would outline height in metres.

Some standardization could be beneficial where municipalities face common planning situations, but it is important to recognize that Ontario has many diverse communities and, in many situations, a more custom approach may be necessary. Challenges and market forces faced by mid-sized rapidly growing communities differ from those of smaller and more rural commutes as well as larger urban communities. Municipalities with a high proportion of college and university students face unique planning considerations. Employment uses vary across the price ranging from heavy industrial sites to more suburban research and development-based employment areas. A one size fits all designation may not adequately address various community needs.

While some level of standardization may have advantages, it is important that Ontario does not lose its unique places and different community character.

Some simplification may be warranted, often Official Plans contain too many items that are not land use related. Official Plan are often a “catch-all” of community goals and strategic plans. Detailed implementation is best left to more specific implementation tools such as master plans.

-- What is your perspective on the changes being considered regarding secondary plans and site-specific policies? Are there other ways to address these policies?--

This would limit the ability to add refinement for a specific area. Often needed when developing a new expansion area or to revitalize and redevelop the long-term redevelopment of an existing area.

--What is your perspective on the number and types of standardized schedules, overlays and data proposed to be required? Should any be removed, or are there any other schedules that could help improve official plans?--

This should be used as a starting point but there needs to be room for flexibility and consideration of site-specific considerations. Recognizing that a standard approach will address the majority of situations, there should be flexibility for the minority of situations that require a more specific approach. This is the same consideration that is given to MZOs to address unique situations.

Part B: Limiting the Length of Official Plans

-- What is your perspective on the changes being considered to limit the length of official plans?--

We are not in support of establishing limits (page or word counts) for Official Plans. Given the unique nature of the various municipalities across the province, it is natural that the length of these documents will vary greatly based on the complexity and needs of the community for which the plan has been developed.

There is support for more strict considerations of what is appropriate for an Official Plan, in the examples given, non-land use related planning matters should not be included in an Official Plan. Often Official Plans become a place to note economic development objectives, arts and culture priorities and other community strategic objectives. Thes should not be included in in an Official Plan. However, these elements can be left out of and OP without having strict limits on the length. Limits may affect flexibility as well. If the Province wishes, a better approach would be to have a guideline and target size of the OP as a starting point for all municipalities but allow customization. This allows for flexibility. With this approach it is likely the vast majority of OP will confirm closely to the standard but allows for individual circumstance to apply. Given the Ministry will remain responsible for approving these plans there is still opportunity to remove any unnecessary contents of an Official Plan.

-- Should there be different limits placed on different types of municipalities (e.g., based on population size)?--

If limits were to be placed on the length of Official Plans, different types of municipalities should be held to different limits to reflect their local requirements and context. However, we believe that there are too many variables to consider to make any delineation or categorization of municipalities feasible. Inevitably, certain municipalities will be restricted to a word count that does not adequately allow them to address their needs.

-- Are there other approaches that could be used to limit the length of official plans?--

We believe that establishing a solid framework for what is to be included within an Official Plan as identified in Part A will naturally reduce the length of many OPs.

Part C: Creating Permissive Land Use Designations

--What is your perspective on the changes being considered to standardize the number and type of land use designations?--

It is recommended that specifications concerning the number and type of land use designations be framed as guideline and an overall goal while allowing some flexibility. The rationale behind the intent to standardize is clear, to streamline development and approvals across Ontario. However, while there are many commonalities across Ontario with 444 municipalities, there should be some room for flexibility as there will always be some specific considerations that need to deviate from the standard. It is recommended that a standard set of land use designations should be the baseline but allow municipalities the flexibility to have a variance from this standard as necessary.

For example, not all municipalities have source water protection needs, shoreline areas, historic downtown or academic areas.

This is similar in approach to existing direction regarding density targets. For example, the PPS 2024 outlines that Major Transit Station Areas are to have a planned density of 160 residents and jobs per hectare, while policy 2.4.2 4 outlines that the Minister may approve a lower density target where it is demonstrate that the target may not be achieved. A similar provision should be considered for standard land uses to allow for situations were a modification and deviation from the standard may be required.

--Would standardized land use designations between upper-tier and lower-tier official plan improve clarity? Where are the opportunities to reduce duplication between the upper and lower-tier official plans in land use designations?--

While many of the province upper tier municipalities no longer have panning authority, there is opportunity to reduce duplication by not having standard land use designation shared by upper and lower tier municipalities. Rather there should be a clearer distinction between upper tier and lower tier jurisdiction. For example, where upper ter municipalities have land use authority, Official Plans should focus on regional level considerations such as growth structure and transportation. The lower tier Official Plan should focus on community planning considerations like land use designations (residential commercial etc.) vs distinctions between urban and rural lands.

--Are there additional designations that would be required? Are there opportunities to streamline or further combine some of the proposed designations (e.g. Residential I and II, and Mixed Use I and II)?--

Employment designation in particular could be expanded. There is a wide range of employment types in Ontario. Employment related to heavy manufacturing is different context than light manufacturing and logistics based employment land uses.

-- Are there implications to making land use designations more streamlined and permissive?--

Pros to being more permissive

Accelerated Housing Supply
• Permissive zoning (e.g., allowing multiplexes or higher densities) may enable municipalities to respond to housing demand more effectively.

Support for Intensification and Mixed-Use Development
• The PPS 2024 encourages intensification and a mix of housing types, which can lead to more vibrant, walkable communities and better use of infrastructure.

Alignment with Provincial Priorities
• Municipal decisions must be consistent with the PPS, which now emphasizes housing supply, affordability, and streamlined planning processes.

Cons
Reduced Local Control and Public Input
• Limiting appeal rights and fast-tracking approvals may reduce opportunities for community engagement and oversight, potentially eroding trust in the planning process.
• Greater potential for conflict and lack of certainty for the community and the development industry

Infrastructure and Service Strain
• Rapid development without corresponding infrastructure upgrades (e.g., transit, schools, water) can lead to service gaps and reduced quality of life.

Environmental Risks
• Permissive policies may increase pressure to develop in sensitive areas (e.g., wetlands, floodplains), especially if environmental protections are weakened or bypassed.

Risk of Displacement and Gentrification
• Increased development potential can drive up land values, potentially displacing lower-income residents unless affordability measures are included.

Loss of Strategic Planning Vision
• Overly permissive policies may undermine long-term municipal goals (e.g., heritage preservation, climate resilience) if not carefully balanced with local plans.

--Are there land use designation terminology or descriptions that would be easier to understand?--
No specific comments.

Part D: Transitioning to a New Framework

--What is your perspective on the changes being considered to transition to a standardized official plan framework?--

Standardization can lead to some efficiencies in the approval of housing and could eventually lead to expedite creation and approval of and updates to Official Plans. However, this would also require additional provincial oversight. While the province set the framework for planning in Ontario, it would be difficult to implement throughout Ontario from a centralized position and would eliminate local knowledge and expertise. There could be a lose of local context and flexibility. Overly perspective templates could also stifle creative approach to urban design, sustainability and community development. While short term there may be an influx of housing, it will all the same and eventually there will be a lack of innovation.

Rural, northern and rapidly growing urban municipalities have vastly different planning challenges demographics and histories. A uniform framework may not serve all equally well. There are also risks related to implementation complexity, transitioning to a new framework may require significant staff training updated and public engagement especially for municipalities that are midway though their respective Official Plan reviews.

--What is a realistic implementation timeline for your municipality to update its official plan to comply with a standardized framework (e.g., structure, land use designations, page/word limits), and why? Please consider staffing, council cycles, data/mapping updates, public engagement, and statutory review requirements in your response.--

A two-year timeline does not leave a lot of time for community consultation. Official Plans remain a public document there should be opportunity for meaningful public engagement with the community and industry. Consultation with indigenous communities may also prolong implementation timeline. Technical studies especially related to natural heritage and economic/ population/land use forecasting also take time. The actual writing of the Plan is not what takes time, it is the consultation and study. The City agrees that creating a new Official Plan should not be an indefinite timeline. As such, a three year timeline may be more realistic.

--How can the province best support municipalities in transitioning to a simplified and harmonized official plan framework?--

Staggering implementation requirements for municipalities. Ensuring that the Ministry is appropriately resourced for a timely review and approval.

Part E: Submission of Official Plans through Online Portal

--Do you support the move toward allowing submission of official plan information and documents through an online portal? Why or why not?--

On this matter in particular, there are real opportunities to streamline and improve efficiently in submitting material to the Province for review. The City supports efforts to move toward submitting materials through an online portal. The current system requires too much duplication of documents as well as time consuming printing and mailing of hard copy materials. Most documents are created digitally so it would be more efficient to allow digital submission of these materials. Further, an online portal could theoretically be updated more regularly and efficiently. Currently some of the online submission requirements to the Ministry still references provincial documents (e.g. the Growth Plan) which are not longer in effect.

--What benefits and/or risks do you foresee from transitioning to submission through an online portal?--

Benefits include a more efficient and streamlined process. Having the ability to determine what the submission requirements and methods are before starting the process would help in expediting the submission. It will likely be quicker to gather all the required materials and provide quicker confirmation of receipt of the submission package vs physically mailing a large document. Risks include having the portal being to complicated and cumbersome to use and there should be compatibility with file formats and sizes. These risks can be mitigated by ensuring there is a well design and simple portal. Common file formats will also help mitigate the risks. To ensure ease of use, formats, and submission requirements should be clearly noted ahead of any submission so that the user is not learning what is required at the time of submission.