Thank you for the…

Thank you for the opportunity to comment on this posting. The County of Brant provides the following commentary and refers the Province to the Council-approved staff report for additional context (RPT-0159-26). Where a related ERO posting exists, the County will comment through that posting. Remaining comments are as follows:

Streamlining and Standardizing Official Plans: The County supports efforts to standardize Official Plans and recognizes variation across municipalities. However, flexibility must remain to reflect local social, environmental, and economic conditions. Allowing some community-specific policies will help municipalities address local needs. The County also requests clarification on the following:

• Whether designation criteria will be implemented and how terms such as “small-scale uses” will be consistently defined; and,
• How does the proposed framework align with the Provincial Planning Statement (PPS) requirement for municipalities to plan for and map a natural heritage system, given that it references Natural Environment and Water Resource areas without recognizing their systemic function?

The County is also concerned with the proposed removal of climate change policies. As climate change is addressed in the PPS and remains a matter of Provincial interest under section 2 of the Planning Act, the County is seeking clarification on how municipalities are expected to proceed. Official plans must be consistent with the PPS and implement matters of provincial interest; if climate change is no longer expressly referenced in Official Plans, how are municipalities to ensure alignment with these requirements?

Broader Focus on Public Health and Safety Over Sustainability: With respect to the related ERO postings, the direction of this ERO posting and the recent Provincial directions (like those in Bill 17), provides municipal uncertainty on how to implement sustainability at a local level consistent with the Provincial Planning Statement. How and at what stage of the planning process are sustainable development goals intended to be pursued?

Further, the County recognizes that there is overlap between public health and safety and sustainability, as climate-related impacts have a direct impact on human well-being such as intensified precipitation patterns resulting in flooding, exacerbated temperatures, etc. The County is seeking clarification on the Provincial understanding of “health and safety” given that many of the ERO postings shift municipal focus towards health and safety, removing references to sustainability and undermining the County’s long-term understanding of health and safety protections.

Should any additional information be required, the County of Brant would be happy to have further discussions on this topic. Do not hesitate to reach out to us for additional input.