Bill 66 Schedule 10 is an…

Bill 66 Schedule 10 is an attempt to reduce government barriers to development by turning back the clock on bureaucracy. The explicit 'open-for-business' rhetoric masks the underlying risks and responsibilities developers will still be faced with even if all the Official Plans, Secondary Plans, regional and environmental plans are ignored.

The Bill operates from a premise that simply by removing these immediate barriers that development can flourish, and in some areas with less competent councils and planners it may, for a time. The trap is that these planning documents are not always the source of the requirements they represent. Instead they consolidate requirements imposed by an array of legislation and introduce new policies where gaps within or between this legislation exists. An Archaeological Management Plan (usually vested in an Official Plan) for example, is not the source of archaeological site protections, that rests in the Ontario Heritage Act. What an Archaeological Management Plan does provide is a more efficient means for developers to assess the potential risks of finding an archaeological site before they undertake an assessment process. The Plan also notifies developers of potential liabilities should they proceed anyways - notifies not imposes, again that originates elsewhere.

If the goal is truly one of reducing barriers to development, then look at harmonizing internal provincial and municipal data management with a goal of reducing the number of development-related applications with redundant information (Ontario has ONe-key, why not ONe-form). This approach would not only save time and cut red-tape, it would do so without exposing developers to needless and, without proper planning documents, unforeseen liabilities.