Re: consultation on…

Re: consultation on simplifying and standardizing official plans
Thank you for the opportunity to participate in this consultation.
I appreciate that you have presented a list of questions to help guide the consultation. I would like to focus on a short list of those questions in this submission. Each question is followed by my response; I’ve tried to keep my responses as brief as possible while maintaining the core of my comment.
What is your perspective on the changes being considered to simplify and standardize the structure and contents of official plans?
Simplified and standardized structure and content are not necessary. The Planning Act and the Provincial Policy Statement provide an adequate and generally understood framework for official plans, provided compliance is enforced by the Province or the upper-tier approval authority. In this context, failure to enforce compliance has the potential to encourage divergent plans and foster confusion in the Provincial system.
What distinctions should be made between the content of upper and lower-tier official plans?
As a general principle, there should be a high degree of alignment between upper and lower-tier plans. Any distinctions, in the sense of differences, should be limited to local considerations which are not shared with other jurisdictions within the upper tier planning area and/or do not conflict with upper tier policy objectives.
To what extent should development standards be set out in official plans vs in zoning by-laws?
Generally speaking, development standards should be located in zoning by-laws (as the regulatory instrument) rather than official plans (as the policy document). However, exceptions can be made for standards which are needed to provide clarity to the intent of official plan policy.
What is your perspective on the changes being considered regarding secondary plans and site-specific policies?
Secondary plans and site-specific policies are necessary to provide clarity at a lesser scale than that of a city-wide official plan. They are particularly useful when the development of the affected area or site is dependent on area- or site-specific infrastructure considerations, and/or considerations related to area character or site characteristics, and/or considerations related to development timing or phasing.
What is your perspective on the number and types of standardized schedules, overlays and data proposed to be required?
As noted above, the number and types of schedules is primarily driven by the Act and the PPS as the guiding framework for local planning. Schedules are a necessary adjunct to policy in that they locate policy ‘on the ground’. Given the diverse ecosystems and urban form of the province, a standardized set of schedules is likely to be unworkable in many instances. Furthermore, additional schedules may be necessary to clarify the intent of locally responsive policy or to support anomalous local considerations.
What is your perspective on the changes being considered to limit the length of official plans?
Any limitations on the length of official plans will be arbitrary and unlikely to fit most circumstances. As above, official plans must in any case contain structured content driven by the Act and the PPS. Inclusion of locally responsive policy must be allowed in each individual circumstance.
What is your perspective on the changes being considered to standardize the number and type of land use designations? Are there implications to making land use designations more streamlined and permissive?
The Ontario planning framework and generally accepted practice have now evolved to the point that land use designations are generally similar across the province. This has resulted, in part, from compliance with the Act and the PPS and, in part, as a result of broad consensus within the planning system. This consensus has been recognized in Hearings of the Ontario Land Tribunal and its predecessors.
Furthermore, the historic principle of separation of land uses (which was the underlier for the historic designations) has, as part of the evolution of general planning practice, been superseded by new concepts such as complete communities which provide for a much more fluid set of designations than was historically the case.
Land use designations have also, in many instances, been tailored to reflect individual circumstances and planning objectives as identified through research and consultation. This flexibility is necessary and desirable for a workable and relevant local planning system.
It should be noted that municipalities already have the flexibility to designate, for example, mixed use areas with highly permissive policy guidance where such an approach would satisfy local planning objectives. This approach can be particularly effective when implemented by way of secondary planning areas.
Conversely, enforced use of standardized designations could result in an unworkable planning framework in those municipalities whose circumstances warrant locally specific policy direction, and could stifle creativity in formulating new designations and policy approaches based on locally determined planning objectives. Necessary evolution of thinking about the clustering of land uses could be stopped in its tracks.
As a concluding note, I would like to point out that local planning policy, and any related local sensitivities, can be easily determined in pre-application meetings with the municipality, and/or by reading the official plan itself. This is the preferred and workable alternative to simplified and standardized official plans.
Thank you for your attention to this submission.
Alan Gummo
1-222 York Street
Kingston ON K7K 1R4
613-650-1561
agummo@hotmail.com
Former Member, Ontario Professional Planners Institute
Former Associate Director, Regional Planning Policy (retired)