We are supportive of the…

We are supportive of the proposed regulation to facilitate the standardization and acceptance of encumbered parkland contributions pursuant to the requirements of the Planning Act.

In general, the criteria should be balanced as proposed: not so overly detailed as to frustrate the policy objective, while still ensuring that the parkland contributions made are high quality and will meet public needs for park space. In particular, it is hoped that the new regulation and statutory provisions will make possible more creative and innovative approaches to adding to the stock of available and needed park space, especially in highly urbanized and dense locations, where such space is most needed and at a premium. In many cases, establishing actual park space is far preferable to a cash contribution being made to the municipality.

One procedural gap that could be addressed is to establish a trigger by which landowners could prompt a "decision" from a municipality on the acceptability of the proposed encumbered parkland. This would allow the question of the acceptability of a park to be determined by the Tribunal, if there is disagreement, at an earlier stage in the process - which is important as the design of the related development will likely depend, in part, on the parkland decision. This will allow for greater and earlier certainty in the process for all stakeholders.