We appreciate the intent to…

We appreciate the intent to standardize Official Plan (OP) terms and definitions in principle as a means of achieving a greater level of consistency within Ontario's established planning framework; however, the proposed changes run the risk of treating common terminology as a proxy for uniform policy outcomes and spatial approaches, rather than allow for locally responsive land-use planning. Standardized language alone does not ensure consistent planning outcomes, nor should it replace context sensitive policy expression that responds to local economic, geographic, and community conditions. Given the significant diversity of communities and municipal structures in Ontario, we believe that there must be some allowance for community specific differentiation and autonomy within our planning framework.
The Town is in the process of drafting a new Official Plan, which proposes a mapping and policy framework that is unique and specific to our urban context and is intended to support compatible development in an identified shoulder “Downtown Fringe” designation. While the legislative changes are presented in fairly general terms, we strongly suggest that the final wording and implementation context continue to allow for meaningful flexibility to respond to specific community needs.
We would also request, should this policy be approved, that clarity be provided in terms of how “hazard lands”, including floodplains, unstable slopes and other constrained areas such as intake protection zones need to be addressed. While these may be intended to be incorporated within the “Natural Environment and Water Resources Area” designation, these necessary considerations will need to be included. For the sake of organizational expediency, it would also be helpful if the mandatory contents be framed as an “upset limit” that allows municipalities to include less. For example, it is unlikely that “Resource Areas” or “Specialty Crop Areas” would be designations that are applicable within the Town’s municipal boundary that almost exclusively consists of urban area.