We appreciate the…

We appreciate the opportunity to provide comments on Bill 98 and support the Province’s objective to streamline land use planning, reduce approval timelines, and accelerate the delivery of housing and supporting infrastructure.

From a development perspective, we wish to highlight an important gap in Bill 98 related to Official Plan expansions adjacent to Ministry of Transportation of Ontario (MTO) corridors and the implications for housing delivery, transportation planning, and infrastructure responsibility.

Official Plan Expansions and Provincial Highway Corridors
Bill 98 advances important changes to streamline and standardise Official Plans and support growth management. However, the proposed framework does not address how provincial highway corridors are to be reviewed, upgraded, or assumed when Official Plan boundary expansions or density increases occur adjacent to MTO corridors.

In many cases, settlement expansions rely on existing provincial highways to function as urban or near urban arterials. These growth decisions materially change traffic volumes, access needs, safety considerations, and the role of these corridors within the transportation network. Without a required, early stage provincial corridor review tied to Official Plan decisions, these impacts are deferred to later stages of the approvals process.

Site Specific MTO Review and Developer Led Improvements
In the absence of system level corridor planning, transportation impacts are typically addressed through site specific development applications and project by project MTO review. This approach frequently results in developers being required to design and drive highway or intersection improvements that serve broader, cumulative growth rather than individual developments.

These site specific, developer led requirements often emerge late in the approvals process and can lead to:
• Delays associated with additional studies, redesign, and iterative agency review;
• Increased highway improvement costs as development specific sections done independently instead of larger components undertaken simultaneously. These increased costs lead to significant impact to homebuyers with both delays to homes & increased costs;
• Increased upfront costs and uncertainty at the land planning stage; and
• Prolonged timelines for draft plan and zoning approvals.

Leaving growth driven highway improvements to site specific review works against the Province’s stated objectives of Building Homes Faster and Cutting Red Tape. It introduces uncertainty, duplication, and inefficiency into the approvals process rather than providing the predictability and streamlining Bill 98 seeks to achieve.

Based on our own project experience along a provincial highway corridor, the current approach to corridor review can result in significant duplication and delay. In this case, technical designs for stormwater and servicing were reviewed through Municipal and Conservation Authority processes, and then subject to further MTO review requiring additional analysis and education to satisfy their review requirements. Similarly, despite prior Environmental Assessment work having been completed for the broader area by the Municipality, additional developer led studies were required to support highway improvements, with limited ability to rely on existing work. These layered, consecutive reviews introduced over two years of delay and uncertainty, illustrating how deferring provincial corridor requirements to site specific development approvals can create duplication and inefficiencies that are inconsistent with the Province’s objectives of streamlining approvals and accelerating housing delivery.

Need for Corridor Review Triggered by Growth Decisions
We recommend that Bill 98, or its accompanying regulations or guidance, provide that Official Plan expansions, growth area designations, or significant density increases adjacent to MTO corridors automatically trigger coordinated provincial municipal transportation reviews. This would allow corridor needs to be identified and addressed earlier, concurrently with growth planning decisions.
Early corridor review would:
• Reduce reliance on ad hoc, site specific MTO conditions;
• Improve certainty for municipalities and the development industry;
• Support coordinated infrastructure planning and investment; and
• Enable more timely housing delivery.

Responsibility for Highway Improvements
In many growth areas, provincial highways effectively function as part of the local urban road network following settlement expansion. However, responsibility for upgrading these corridors is often unclear. We encourage the Province to provide clearer direction on when provincial highway segments should be evaluated for Connecting Link designation or municipally or provincially led improvements, rather than relying primarily on developer driven solutions.

Conclusion
Bill 98 presents an opportunity to better align growth planning with transportation infrastructure delivery. Clarifying how MTO corridors are addressed as part of Official Plan expansions would reduce delays, improve certainty, and directly support the Province’s housing supply and red tape reduction objectives.

We appreciate the opportunity to provide these comments and would welcome further engagement on improving coordination between provincial, municipal, and development stakeholders in growth areas adjacent to MTO corridors.