This is in response to the…

Numéro du REO

025-1097

Identifiant (ID) du commentaire

173155

Commentaire fait au nom

Individual

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Commentaire

This is in response to the recent ERO posting of Bill 60. As a municipal planner, I have a particular interest in this Bill. I do wish to stress that the opinions expressed below are personal, and do not represent those of my employer. Had the usual time been provided for responding, I’d suggest more input may have been received, and do question the reduced response time.

Proposed Changes to the Planning Act (Schedule 10 of Bill 60) 
“Changes are proposed to the Planning Act to make provincial policy statements inapplicable with respect to all Minister’s decisions, including past decisions, under the Planning Act outside the Greenbelt Area. A transparent and accountable oversight framework would be developed to support implementation.”

It is my view that the potential negative impacts of this proposal are significant and that the proposed change warrants serious reconsideration, as follows:

1. Erosion of Planning System Integrity and Predictability
This proposal undermines the purpose of the Provincial Planning Statement (PPS). The PPS exists to create a consistent, province-wide framework for land-use planning. Allowing Ministers to bypass it—even retroactively—removes the coordinating backbone of the system.
It further creates uncertainty for municipalities, developers, conservation authorities, and the public. If the PPS no longer applies to Ministerial decisions, planning rules become unpredictable, based on political discretion rather than policy guidance.

2. Concentration of Power and Reduced Accountability
This proposal centralizes discretion in the hands of a single Minister. This reduces checks and balances meant to protect long-term planning outcomes and public interest. The planning process is built on public accessibility and input. Such input is important and may impact planning reports and final decisions as determined by a hierarchy of staff (in the case of planning reports) and elected council officials (decisions of Council). Centralized discretion circumvents and negates all of this.
Furthermore, retroactive exemption weakens accountability for past decisions.
Making the policy apply to previous decisions risks being seen as an attempt to shield earlier uses of Ministerial powers from scrutiny or legal challenge, and is troubling to say the least.
“Transparent and accountable framework” is undefined. Without concrete, legislated oversight mechanisms, the promise of transparency may not offset the increased discretion.

3. Increased Risk of Politicized Decisions
Priority projects could be selected based on short-term political considerations.
When decisions are no longer constrained by an objective policy framework, pressures from donors, lobbyists, or political timelines may influence land-use outcomes. Developers may perceive that political access, rather than good planning, is the key to project approval.
This can lead to loss of public trust in the planning process, and ultimately government in general, if residents perceive development approvals as politically motivated rather than evidence-based.

4. Undermining Municipal Planning Capacity
Municipal councils and planning departments could be sidelined. A key purpose of the PPS is to guide local planning decisions. If Ministers can override it, municipal planning frameworks lose relevance.
Further, long-term planning coherence suffers. Municipalities may struggle to align infrastructure, water/wastewater servicing, transportation, and community amenities if projects leapfrog normal planning processes.

5. Reduced Transparency
Ministerial orders and expedited interventions limit opportunities for public, Indigenous, and stakeholder consultation. Decision-making becomes less transparent and less defensible.

6. Economic and Environmental Risks
Fast-tracked projects may proceed without full servicing plans, leading to higher long-term costs for municipalities or taxpayers. Planned infrastructure needs and costs may be misaligned.
Further, there is risk of approving developments in unsuitable locations (e.g., provincially significant features, poor soil, inadequate transit) simply because PPS guidance was bypassed.

7. Precedent for Further Erosion of Standards
Once exemptions to the PPS become normalized for “priority” projects, the definition of “priority” may expand—weakening the overall planning system over time. This could create pressure to extend similar Ministerial powers in other regions.

In summary, the Proposed policy change to allow Ministerial decision-making regardless of its own PPS policies, may accelerate approvals, but this comes at the cost of: long-term planning integrity, consistency, and predictability; reduced municipal authority; concentrated power at a provincial level with limited oversight; economic and environmental risks, and eroded trust in land-use decision making. The benefits of such a change are far outweighed by these potential negative consequences, and in my view are not prudent or supportable.