Thank you for the…

Thank you for the opportunity to provide comments on ERO posting 026-0300 Proposed
Planning Act, City of Toronto Act, 2006, Building Code Act, 1992 and Municipal Act,
2001 Changes (Schedules 1, 2 and 7 of Bill 98, the Building Homes and Improving
Transportation Infrastructure Act, 2026). Town staff offer the following comments:

Streamlining and Standardizing Official Plans:
Several components of the standardized list require further clarification to enable
meaningful and detailed review. For example, it is unclear whether the category
“Human-Made Hazards” is intended to include climate change. Section 2.9 of the
Provincial Policy Statement (PPS), 2024 explicitly directs planning authorities to plan for
the reduction of greenhouse gas emissions and to prepare for the impacts of a changing
climate. This section includes policies to promote green infrastructure, low-impact
development, and active transportation, as well as consideration of other approaches
that reduce emissions and enhance community resilience. Given the explicit policy
direction within the PPS, it is unclear why climate change-related policies are being
characterized as redundant. Climate change has direct and localized impacts,
including flooding, extreme heat, and public health risks. Removing or consolidating
these policies without clarity may have significant implications for community health
and safety and could increase the burden on municipalities to respond to
climate-related challenges.

Another area that requires clarification is the treatment of Secondary Plans within the
proposed standardized format. Secondary Plans are a critical tool for facilitating
appropriate and well-planned development. These plans play a vital role in translating
the broader goals of the Official Plan into detailed, area-specific policies that guide
growth in new communities or the redevelopment of existing ones. Additional
comments have been provided via ERO 026-0315.

Given that Indigenous consultation continues to be identified as a specific section
through the standardization of Official Plans, the Province must provide guidance to
municipalities on the timing and scope of consultation. This should include clarification on when consultation is required and the appropriate level of engagement with each
Indigenous community that has an interest in the planning area.

With regards to the set of land use designations the uses listed under 5) Major Facilities
and what is permitted under 4) Employment Areas seem to overlap. Clarification on
what specifically differentiates between these two designations should be provided.

Finally, it is staff’s interpretation of the proposed timeline that, once approved, the
standardized Official Plan framework will need to be implemented through the next
municipal Official Plan review following the applicable transition date. For the Town of
Halton Hills, this transition date is identified as January 1, 2029. Given that the Town is
currently undertaking its Official Plan Review process, confirmation from the Province
that this interpretation is correct would be appreciated to ensure alignment with
provincial expectations and appropriate sequencing of work.

Complementary Changes to Support Implementation of Streamlining and
Standardizing Official Plans:

Removing redundant requirement for municipalities to include climate change
policies in their Official Plans

As stated above, given the explicit policy direction within the PPS, it is unclear why
climate change related policies are being characterized as redundant. Climate change
has direct and localized impacts, including flooding, extreme heat, and public health
risks. Removing or consolidating these policies without clarity may have significant
implications for community health and safety and could increase the burden on
municipalities to respond to climate related challenges.

Providing that for an already approved protected major transit station area
(PMTSA), only official plan amendments changing the boundaries of the PMTSA or
the planned population and jobs for the area would require the Minister’s approval,

The Town has no concerns with this proposal.

Providing the Minister with authority to exempt lower-tier municipalities from the
requirement to conform with upper-tier official plan to facilitate implementation of
testing for the proposed Official Plan framework.

As the Region of Halton no longer has planning authority, the Town has no comment on
this proposed change.

Site Plan: Prohibit Mandatory Municipal Enhanced Development Standards and
Green Building Standards

Town staff continue to have concerns with the proposed prohibition on mandatory
enhanced development standards, including Green Development Standards. These
standards have supported municipalities in addressing locally specific environmental
conditions and climate risks—such as stormwater management, urban heat mitigation,
tree canopy protection, and reductions in building-related greenhouse gas emissions—
through the development review process. Removing this authority, without
corresponding enhancements to provincial standards (i.e. OBC), limits municipal
capacity to manage the long-term environmental, infrastructure, and climate impacts
of growth and to implement Council-approved climate and sustainability objectives,
and ultimately has a negative impact on the end user and the community. To support
the broader Provincial objective of standardization, the Ontario Building Code should
be expanded to further standardize green energy construction across the Province.

Town staff are of the opinion that applying Green Development Standards at the lot
level provides many benefits to the developer, future occupants of the home, the
broader community and the environment.

See additional comments sent via ERO #026-0309

Minimum Lot Sizes

In general, the Town continues to advocate for the continued authority of municipalities
to implement development standards that are context specific and support complete
communities, environmental sustainability, and public health and safety.

See additional comments provided via ERO 026-0311.

Minister’s Zoning Orders

It is understood that this proposal would remove the requirement for the Minister to
provide notice when initiating an amendment or revocation of an existing MZO. Town
staff request that any changes to Minister’s Zoning Orders within the Municipality be
clearly communicated to the municipality and public to guarantee transparency and
ensure that any potential local impacts can be assessed and addressed in a timely and
efficient manner to prevent potential project delays.

Encumbered Parkland and Privately Owned Public Spaces (POPS)

The Town supports the intent to clarify requirements related to encumbered parkland
and Privately Owned Public Spaces (POPS); however, care must be taken to ensure that
these spaces continue to provide meaningful public benefit.

Halton Hills relies on public parkland to meet the recreational and open space needs of
our growing and intensifying communities and recognizes the potential for POPS to
complement public parkland.

Any restrictions on municipal ability to assess encumbrances or to secure appropriate
design, access, and long-term maintenance arrangements could reduce the
functionality and community value of these spaces. From the Town’s perspective, the
ability to evaluate parkland quality, usability, and long-term public benefit is essential
to achieving complete communities.

See additional comments via ERO 026-0312.