While we note that Bill 17…

While we note that Bill 17 has received Royal Assent prior to the closing of the comment period, the County of Brant appreciates the opportunity to provide comments on this legislation, including future directions mentioned in the technical briefing. In addition to the attached information, a summary of the comments related to the changes to the Planning Act are provided as follows:

Comments on Bill 17 Amendments to the Planning Act
1. Regulating Requirements for a Complete Application

Proposed Change: The Minister will gain authority to regulate the requirements for complete development applications. This includes creating a list of studies that municipalities cannot ask for (such as sun/shadow, urban design, and lighting studies) and requiring municipalities to accept studies from certified professionals.

County of Brant Comments:
The County agrees with the goal of standardizing and streamlining application requirements.
However, staff do not support removing studies that are considered part of good planning practice, such as urban design, sun and shadow, and lighting studies.
It is suggested that the Province should either create standardized versions and terms of reference for these studies or clarify how they can continue to be enforced through policies in the Official Plan.
Staff note that if the expectation is for municipalities to conduct their own analysis (e.g., 3D modeling) instead of relying on applicant-submitted studies, this would shift the workload and responsibility to the municipality, and provincial support (like funding) should be provided.

2. Conditional Approvals for Minister's Zoning Orders (MZOs)

Proposed Change: The Minister will have the authority to impose conditions on an MZO that must be met before permitted uses can take effect.

County of Brant Comments:
Staff have no comments at this time, as there are currently no MZOs within the County of Brant.

3. "Schools As-of-Right"

Proposed Change: This provision will permit elementary and secondary schools "as-of-right" on urban lands zoned for residential use. It also removes timing restrictions related to the placement of portable classrooms.

County of Brant Comments:
The County supports policies that streamline school development to meet the needs of growing communities. Staff advise that it should be clarified that Minimum Separation Distance setbacks from industrial and employment uses will still take precedence to ensure student safety.

The County cautions that not all residential areas, particularly those on higher-order roads like arterials, may be suitable for safe active transportation to schools. The Province should consider adopting design guidelines for schools in various settings.

4. Minor Variance and "As-of-Right" Variations

Proposed Change: The Minister will have the power to create regulations that allow certain variations to zoning by-laws "as-of-right," reducing the need for minor variance applications. An example is allowing setbacks to be varied by up to 10% without an application.

County of Brant Comments:
The County supports this streamlined approach to reduce the workload associated with minor variance applications. This direction aligns with the County's transition toward a Community Planning Permit System (CPPS) by the end of 2026, which also aims to provide more flexible standards.

5. Streamlining Official Plans (Mentioned in Technical Briefing)

Proposed Change: The Province proposes to work with municipalities to establish simplified and standardized land use designations in Official Plans.

County of Brant Comments:
This item is considered not applicable for comment at this time as the proposed goals are not yet actionable. However, the County supports standardization of Official Plan designations with consideration for localized factors. The County of Brant's new Official Plan has taken a simplified approach to land use designations in an effort to streamline the development process.

6. Official Plan Population Updates (Mentioned in Technical Briefing)

Proposed Change: Municipalities whose populations are anticipated to surpass their Official Plan estimates will be required to update their plans to align with the Ministry of Finance's forecast.

County of Brant Comments:

The County's most recent population projections are aligned with current growth rates and have considered both the previous Growth Plan numbers and the Ministry of Finance's forecast as part of the municpal comprehensive review completed in 2023.

Please see attached County of Brant staff report RPT-0223-25 and Appendix 1 for additional details. Please do not hesitate to contact the County of Brant with additional questions.