The following comments are…

The following comments are submitted on behalf of the City of Greater Sudbury in response to this Environmental Registry of Ontario (ERO) proposal. As a northern municipality with a diverse geography, significant natural resources, and unique environmental and economic considerations, we appreciate the opportunity to provide input and respectfully submit the following observations and recommendations for consideration:

Ministerial Oversight on New Requirements: While we support greater consistency in development approvals, requiring provincial approval before adding new local requirements risks delaying site-specific responses. A streamlined process should be created for municipalities to seek expedited approvals in cases with environmental, infrastructure, or safety considerations.

Professional Certification Deemed Complete: We urge the Province to retain municipal discretion to request clarifications or supplemental documentation. Not all certified reports are created equal—especially in high-risk or technically complex projects.

As-of-Right Setback Variations: Municipalities should be permitted to apply limitations or performance criteria in specific neighbourhoods where cumulative effects (on drainage, privacy, heritage integrity) are a concern.

Schools on Urban Residential Lands / Portable Classrooms: These changes are not expected to impact Greater Sudbury directly at this time. We support the general intent but recommend that municipalities retain tools (e.g., site plan control) to manage land use compatibility where appropriate.