Regarding the consultation…

Regarding the consultation on simplifying and standardizing official plans, I have the following comments as a municipal planner, regularly involved in the review and implementation of these documents. My views do not represent that of my employer. I take issue with 2 items in particular: A) an imposed size limit of OP documents, and B) the Standardizing of OPs provincially.

A. Proposed Page and Word Limits for Municipal Official Plans
“During recent consultations, the government heard concerns that municipal official plans have become lengthy… We are consulting on a proposal to set clear parameters… including limiting the number of pages that could be in an official plan.”

I do not support legislated length caps for Official Plans (OPs) for the following reasons:

1. Arbitrary Limits Undermine the Purpose of OPs
Official Plans are statutory, policy-rich planning documents intended to guide municipal growth, land use, infrastructure planning, environmental protection, and community development for 20–30 years. Unlike discretionary documents, OPs must:
Conform with or be consistent with multiple provincial plans and policy statements
Integrate extensive technical material (transportation, servicing, watershed management, hazard mitigation, natural heritage, and agricultural systems)
Provide clarity and predictable guidance for zoning, development review, and infrastructure investment
Address unique local conditions, community goals, and geographic realities

A fixed page or word limit treats an OP as a communications product, rather than as a legally binding instrument with real planning and regulatory consequences. Length is a function of complexity, not inefficiency.

2. Municipalities Differ Greatly
A single page or word limit cannot reasonably apply to municipalities with vastly different growth pressures, infrastructure systems, transit investments, natural heritage systems, or agricultural land bases.

3. Reducing Text Removes Clarity, Not Complexity
Mandatory content will simply shift into zoning bylaws, technical appendices, or ad hoc interpretations. This fragments policy, making it harder for the public and development community to navigate.

4. Increased Legal Risk
Over-compressed OPs may lack clarity needed to defend decisions at the OLT or guide zoning and development review, increasing disputes and delays.

5. No Clear Benefit and High Administrative Cost
Neither the public nor the development industry benefits meaningfully from shorter OPs. Implementing caps would consume significant municipal time and resources without solving planning delays.

Conclusion:
Page or word limits are not evidence-based, introduce legal and administrative risks, and undermine municipalities’ ability to plan effectively. Instead of forcing municipalities to shrink their OPs, provincial efforts should focus on the root causes of slow housing delivery— such as the thousands of already approved units not being built. The Province should also consider prioritizing non-market housing especially where private developers choose not to proceed with approved projects.

B. Proposal to Standardize OPs
Standardizing OPs province-wide will have a number of negative effects.

1. Major Costs - Municipalities (all tiers) having to revise entire OPs represents a major cost burden in staff time, consultants, public consultation, mapping, and legal review. We also lose the flexibility to tailor policies to local geography and community needs, (tourism in cities, Northern communities, high-growth suburbs). This undermines local and community-specific protections. If such a changes forces details out of OPs and into zoning bylaws, municipalities may need to massively rewrite zoning bylaws too — doubling the update cost.

2. Generic OPs = less effective land-use planning - OPs are supposed to reflect local conditions, not a province-wide template. Standardization may produce documents that lack: geographic nuance, local natural heritage details, community design priorities and neighbourhood-level intensification strategies.
Residents and communities will come to understand that standardized OPs are more generic, less context-specific, and less reflective of local priorities. Therefore, there becomes less ability to amend neighbourhood-level planning through OP policies. This reduces local autonomy and responsiveness.

3. Prohibiting secondary or site-specific plans removes one of planning’s most important tools for: Intensification areas, Transit station planning, Waterfront development, Employment districts, and Rural settlement areas. This reduces planning precision and the ability to guide growth where it makes sense.

4. Increased Ministerial Control Over Local Planning - A standardized OP structure simplifies Ministerial overrides, because policies are more predictable, easier to amend, and less detailed. Local differentiation or protective language becomes harder to defend.

5. Diminished Planners’ role - Local judgment and expertise of planners, and nuanced community planning are diminished when OPs become “fill-in-the-template” documents. It reduces the planning function to a technical exercise that can be done by any untrained person, rather than those who are experts in the field.

6. Who Benefits Exactly? - Standardization does not appear to provide benefits to anyone in particular, neither the public nor the development industry. Most members of the public have little reason to get involved in the planning process in their lifetime!. (Particularly now that they have no appeal rights). If and when they do, they need to know the policies related to their particular property, if they have questions, municipal planners are available to the public to explain. The planning process is one of the most regulated and transparent, leaving little room for distrust. Never would a member of the public need to review or understand an entire OP. The size of the document or even its complexity in the city of has very little impact on the public.
Even the development industry does not benefit significantly from a standardized or shorter OP. They are required to hire professional planners to interpret those sections of the OP that apply to their sites and justify their development proposals on that basis, regardless of whether it’s in a small to mid-size city or a rural community, again not to review an entire OP. With little to no benefit to the public or builders for this change as compared to the amount of effort, resources, time and cost to implement these, I question who is expressing ‘concerns’ about the length of OP documents and why this is a question that needs entertaining in light of more pressing issues and so little benefit. If however, the province’s objective is to centralize more of its power and allow for greater Ministerial interventions, that alone is troubling and more reason to pause on this proposed change.

7. Economic and planning inefficiencies - Municipalities may spend millions rewriting OPs when those resources could be used much more productively to: Approve housing; Implement infrastructure improvements; Modernize zoning; and Invest in planning staff recruitment and retention. This reform does not directly create housing — it reallocates resources away from housing approvals and into policy rewriting.

Summary: The standardizing of OPs may:
- Create significant administrative and financial burden for municipalities
- Reduce local autonomy and responsiveness
- Provide disproportionate benefits to large developers and the provincial government
- Undermine environmental and community-specific protections
- Lead to rushed, generic planning documents
- Eliminate secondary plans, weakening detailed growth management tools
- Facilitate increased Ministerial control

While marketed as “efficiency,” the reform appears primarily designed to centralize planning authority, reduce municipal influence, and smooth the path for province-priority growth projects, rather than solve the housing crisis directly. Land use planning is an important role that deserves community-specific consideration - not a ‘one size fits all’ municipalities from the largest cities to the smallest townships. For all of the above reasons, it is inappropriate and unsupportable.