Please see attached letter…

Please see attached letter from Halton Region.

Key comments provided below:

Elimination of Third-Party Appeals

Bill 185 continues to remove appeal rights for upper-tier municipalities with no planning responsibilities. Although Halton Region does not often exercise appeal rights, there is concern with not having any status at the OLT when there is an appeal directly related to a continued Regional interest (i.e. infrastructure). Halton Region would ask that the Province consider providing options for appeal rights where there is a clear Regional interest.

Bill 185 proposes to eliminate third-party appeals related to Official Plans, Official Plan Amendments, Zoning By-laws and Zoning By-law amendments. While we can appreciate that this may reduce time, cost and the burden on the OLT, Halton Region feels that it is important members of the public and other stakeholders have a voice in planning for their communities. We recommend that the Province reconsider eliminating appeal rights when it comes to comprehensive changes.

Appeal Rights for Privately Initiated Settlement Area Boundary Expansions

Bill 185 proposes to restore appeal rights for privately initiated applications for settlement area boundary expansions. Planning for boundary expansions involve a wide range of considerations, including the availability of infrastructure. There is a concern with allowing boundary expansions sporadically and not as part of a broader comprehensive review as it relates to understanding population projections and planning for roads, water and wastewater. Currently Halton’s municipalities have urban area boundaries that provide enough land to accommodate growth to 2051. Planning for this land in a comprehensive and coordinated manner is the best way to get housing built faster, rather than expending resources on small individual requests. Given these considerations, the permissions for ad-hoc boundary expansions do not aid in delivering housing faster, and may in fact create delays.

New “Use it or Lose it” Tool

Halton is supportive of the changes made as it relates to the “Use it or Lose it” tool. Ensuring that development moves ahead within the specified timeline will provide more certainty in determining servicing allocation needs. Further, Halton supports the changes related to repealing Section 70.3 of the Planning Act related to servicing allocation and including new Section 86.1 to Part III (Specific Municipal Powers) of the Municipal Act, 2001 in its place. Halton also supports the changes that allow for the creation of a servicing management tool to establish how water and wastewater will be approved.

Removal of Mandatory Pre-consultation

Bill 185 proposes to remove the ability for municipalities to require a pre-consultation meeting in advance of a formal application. Although Halton recognizes that we will no longer have planning responsibilities, we will still have a significant role related to the planning and delivery of Regional roads, water and wastewater, waste collection and other key services. Considerations for Regional interests will continue to be necessary in the development review process. Pre-consultation meetings allow for the opportunity to highlight all potential issues early in the process, it allows agencies to communicate expectations on the application and provides a list of what constitutes a complete application. When done properly, it allows for a much faster and efficient application review process. This process has proven to be successful and beneficial for both the applicants and participating agencies. Halton recommends that the Province reconsider the changes to the pre-consultation process.

New MZO Framework

The new MZO Framework does not formally require input from upper-tier municipalities when making submissions. Given the importance of servicing MZO lands and that any growth resulting from these decisions will be above any beyond planned growth and infrastructure (per the Proposed Provincial Planning Statement, 2024), Halton feels it would be important to receive input from upper-tier municipalities that have a role in providing infrastructure. Halton recommends revising the framework to include this as a requirement.