The following are responses…

The following are responses to discussion questions included in the posting:
1. What is your perspective on the changes being considered to simplify and standardize the structure and contents of official plans?

Increased Standardization of Official Plans would provide a consistent template in terms of basic plan structure and layout.
We appreciate the notation of ‘inclusionary zoning’ within the standard chapter 6: Residential and Mixed Uses and wonder if the ability to use this tool is to be extended more broadly to municipalities in Ontario.
The province could support standardized plans by maintaining a consolidated list of policies that are required under the Planning Act, Regulations or other legislation in order for Municipalities to undertake specific activities (e.g. enabling community improvement plans, criteria for planning permit systems, complete application requirements for various types of applications, road widenings).

2. 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?

Some municipalities may wish to have plans that cover their entire area, others may prefer plans that focus only on settlement areas. Standardized structures for upper/lower tier plans should be able to accommodate different planning capacities and interests among local municipalities within a County structure.
The Bruce County Official Plan (updated and proposed) provides for local Official Plans to reference policies and criteria that are within the County Official Plan as an alternative to duplicating these policies within the local plan.

3. 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?

Official Plans can provide a succinct policy direction and standard, and in upper-tier plans that cover a broad area can support consistent approaches, for example to address appropriate densities for land division on private services, or to set standards for lot creation along arterial roads in order to maintain their intended function.
We have been working to update the Bruce County Official Plan to reference provincial direction including development criteria, provide more general policy direction wherever possible, and outline criteria to be addressed through planning approvals including land division and zoning by-laws. These updates have significantly reduced the number of requests for site-specific amendments to the plan.

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

Secondary plans and site-specific policies provide a useful opportunity for providing focused direction and flexibility.
Site specific policies also provide an opportunity to permit an emerging use in a specific area without necessarily permitting it broadly across the plan area.
We have used site specific policies to address specific circumstances where year-round road access is not necessary for lot creation, or to permit non-agricultural uses in prime agricultural areas in accordance with the Provincial Planning Statement and Guidelines.
Some local municipalities may consider merging their plan within an upper-tier plan, with provision for area-specific considerations to be addressed within what would appear to be a secondary plan.

5. 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?

Aligning and pointing data back to provincial sources is beneficial for transparency. In respect of natural heritage it is important to recognize the province has not provided datasets for all data points (e.g. significant woodlands), and criteria may be used to identify a subset of provincial data (for example, wetlands larger than a particular size threshold as key or supporting features).
Official Plans often provide interpretation provisions that enable revisions over time to reflect newer information; while Provincially Significant Wetlands have a boundary updating process that requires notification to the Ministry, this is not in place for other provincial datasets, and may result in increased variation over time.
The proposal is for a single water resources schedule including source protection information. We have proposed that the Official Plan would include source water protection area maps exactly as adopted in source protection plans, and provide for their being automatically updated in the plan when source protection plans are approved so as to avoid duplicative processes.
Rural municipalities may have areas for amenity-based development where more flexibility may be provided for development than broader ‘rural’ areas, yet they are not planned or intended to function as complete settlement areas; several of these areas are identified as ‘Escarpment Recreation’ in the Niagara Escarpment Plan. It would be beneficial to be able to have a land use designation for these areas, such as ‘Shoreline and Seasonal Recreation’

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

We have made significant efforts to reduce the length of our new Official Plan, and it would be well within the 65000 word / 250 page limits for text.

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

It would be helpful to know if the page limit, if implemented, is inclusive of schedules. Municipalities with larger geographic areas may want divide schedules into smaller parts.

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

Where the province is providing clear and sufficient direction to address its interests, for example through guidelines for permitted uses in agricultural areas, or, if implemented, a prescribed list of studies that may be required, it could direct that plans reference that there is provincial direction to be followed rather than duplicating that direction within a plan. Such guidance could reduce the length of plans without imposing an arbitrary limit.

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

Rural Municipalities may not have the servicing capacity to support Residential-II and Mixed Use-II designations and may struggle to maintain serviced supply of both Employment Areas and Mixed Use Areas. As a result, Rural Municipalities may be less willing to plan for Employment Uses that could be sensitive to adjacent land uses, with either lost opportunities or pressures to locate these uses in other designations.

10. 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?

The Bruce County Official Plan identifies ‘Settlement Areas’ and then lower-tier official plans provide the policies and schedules for development within these areas. Currently only one of eight local municipalities has a plan that covers the areas outside of settlement areas.

11. 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)?

We have proposed Natural Heritage as an overlay rather than a specific designation, and distinguish between Core Areas and Linkages, Key and Supporting Features, and Hazard land areas.
Parks and Open Space is an important designation, however these uses and natural resource conservation and enhancement should be permitted within nearly all designations.

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

The overall thrust of the provincial planning statement is to direct most growth to settlement areas. Plans are oriented around facilitating infilling and intensification and efficient use of resources and infrastructure. Implications of more broadly permitting low-density residential uses in rural areas may include increased: reliance on busing for education, costs for servicing development, impacts to rural road systems, emergency services response times, transportation-related pollution, and rural land costs.

13. Are there land use designation terminology or descriptions that would be easier to understand?

Replace Residential 1 and 2 and Mixed Use 1 and 2 with ‘Low Density Residential’ and ‘Medium-High Density Residential and same for mixed use, to accommodate contexts where there would be no ‘Residential 2’ or ‘Mixed Use 2’ designations

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

We have nearly completed our new Official Plan, the timing of which has been impacted by various changes in Provincial Direction. We would prefer to conclude the current process without an extensive reorganization of policies.
Before implementing a requirement that the upper tier plan be transitioned to the new framework before a plan for a local lower-tier we recommend considering circumstances such as upper-tier plans that define settlement areas and local plans that focus on lands within those settlement areas.

15. 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.

The standard timelines for review and update (10 years for a new plan, 5 years for an update) should be sufficient and provide for consideration of staffing, council cycles, mapping updates, and public engagement.

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

Slowing the pace of change in the Planning System would give Municipalities a much better chance of understanding and implementing changes.
Providing resources to support First Nations engagement in the Planning system would provide much needed capacity to facilitate review and participation.

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

Support would be conditional on the portal representing significant value relative to the required investment.
For example, if it would result in the Ministry being more responsive in its approvals and was straightforward for staff to use, and if it was connected to the MTO portal for applications that relate to corridor management.

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

The portal could reduce administration time by provincial staff in their intake of files and related materials but increase the administrative burden for municipal staff.
If the portal is used for every official plan matter (including site-specific amendment requests) then staff could be uploading documents to MMAH through its portal and MTO through its portal, and potentially later in the process to the OLT through its portal.
If the MMAH portal is only for major amendments and new plans, it may be used infrequently by local municipalities and require training materials, updates, etc. to reflect changing provincial expectations for submissions.