I am a Candidate Member of…

I am a Candidate Member of OPPI working as a land use planner in the private consulting sector; my current projects include assisting municipal clients with reviewing and updating their Official Plans. In working with the new official plan framework that would be introduced through Bill 98 (which, I note, has just passed Third Reading in the House), I have noticed a few important omissions in the proposed Schedule 1 to the Planning Act that could have unintended consequences:

- As prescribed by paragraph 1 in s. 1 of Schedule 1, Chapter 1 is to be entitled "Introduction and How to Read this Plan." However, subparagraphs i and ii do not provide for a section entitled "How to Read this Plan," nor do they provide for any content that provides such information. Subparagraphs 10 i–iv do not provide for such content, either.

- Paragraph 8 does not provide for official plans to include policies related to stormwater management or drainage. Presumably this should be included either as part of Section 8.4 or as its own section.

- The land use designations prescribed in section 2 of Schedule 1 do not provide for any site-specific policies that would permit additional uses beyond those listed. As a result, municipalities will have no way of approving mineral aggregate extraction or other resource extraction in prime agricultural areas, as those uses are not contemplated in paragraph 10, and as the lands must remain part of the prime agricultural area in order to maintain consistency with the Provincial Planning Statement, 2024.

- The use of "shall" in the phrase "within which the following land uses shall be authorized" indicates that all of the uses listed must be permitted everywhere in the designation. This could create compatibility issues, for instance where a residential use must be permitted under subparagraph 9 i next to an agricultural use that must be permitted under subparagraph 9 iv or next to a resource management use that must be permitted under subparagraph 9 vii.

- Subparagraph 5 iii identifies "Infrastructure uses" as permitted in the "Major Facilities" designation. Because infrastructure uses are not listed as permitted in any other designation, this could be interpreted as requiring that all infrastructure uses be designated as "Major Facilities."

Thank you for taking the time to consider these comments.