This proposed regulation is…

This proposed regulation is extremely short sighted and problematic. Not requiring wind or shadow studies at zoning would invalidate any opportunity to mitigate the effects of shadow and wind which will affect enjoyment of parks and public spaces. Strong gusting wind can be an AODA issue not allowing people with disabilities or senior to safely and comfortably walk in public spaces. I do not believe would want important public amenities like children's playgrounds or, for example, the conservatory buildings in Allan Gardens to be in perpetual shadow.

There is a stronger argument to be made that these studies should not be required at the site plan stage as the opportunities to mitigate against the effects of wind and shadow have largely passed.

Lighting studies are a critical component to public safety, ensuring that new public spaces are safe for everyone. Unlike the previous two studies, this should only be asked at site plan, so I could understand, in this instance, not requiring it at zoning and official plan.

Studies should be required at the appropriate scale of development application where they are applied most effectively. Not making these studies a mandatory requirement of a planning application will ensure that these considerations remain largely unmet.

Last, no longer requiring urban design analysis will result in an meaner and, frankly, uglier, public realm. If there is a concern of overreach there are alternative ways to mitigate against these concerns.

The longest and most expensive component of a planning application is the engineering and architecture. The studies singled out here, ironically, are amongst the least expensive and quickest to produce. Not requiring these studies will not significantly mitigate the costs of an application or reduce the time it takes to produce an application but will (materially!) result in poorer built form that will directly impact accessibility for Ontarians and their enjoyment of the public realm.