Proposed Changes to Support…

Proposed Changes to Support Standardizing of Parkland Requirements

City of Cambridge supports the Province’s objective of increasing housing supply and providing greater certainty in the planning system. High‑quality, accessible parkland is essential to complete communities and to supporting intensification. Achieving these outcomes requires municipalities to retain flexibility to respond to local conditions and long‑term community needs.

1. Preserving Local Decision‑Making
The proposed regulation significantly limits municipal discretion by requiring acceptance of developer‑identified lands that meet prescribed criteria and enabling OLT appeals where lands are refused or where a municipality does not make a decision. Municipalities are best positioned to evaluate whether lands contribute meaningfully to an integrated park system and should retain authority over parkland outcomes in their communities.

2. Risk to Parkland Quality and Strategic Planning
A compliance‑driven approach may result in parkland that meets minimum standards but does not align with municipal parks strategies, particularly in built‑up areas. Reduced flexibility to rely on cash‑in‑lieu contributions may undermine the ability to deliver larger, well‑located, functional parks that serve broader community needs.

3. Financial and Capacity Impacts
The City is concerned about increased administrative, legal, and long‑term operating costs associated with reviewing and managing developer‑identified lands, including encumbered lands and POPS. These costs are not accompanied by additional funding tools, creating pressure on municipal budgets and capacity.

4. Appeal Risk and Timelines
The proposed appeal framework and short statutory timelines increase procedural risk and workload for municipalities and may shift parkland decisions from local councils to the OLT. Greater flexibility is needed to allow municipalities to undertake thorough and defensible reviews. This will also increase OLT appeals and associate legal costs for the municipalities.

5. Encumbered Lands and POPS
The City of Cambridge remains concerned about long‑term access, liability, enforcement, and public confidence issues associated with encumbered lands and POPS. Municipal discretion to refuse such lands, based on long‑term public interest considerations, should be preserved without automatic appeal exposure.

6. Recognizing Municipal Diversity
A standardized provincial framework does not reflect the diversity of municipal contexts across Ontario. The City requests flexibility to align parkland dedication practices with local growth patterns, urban form, and community needs.

7. Transition and Ongoing Review
If the regulation proceeds, the City of Cambridge requests clear transition provisions, practical implementation guidance, reasonable timelines, and ongoing monitoring of impacts on parkland quality, municipal costs, and appeal volumes, with a commitment to make adjustments if unintended consequences arise.