On behalf of our client,…

On behalf of our client, Build Urban, please accept this letter with respect to the Province of Ontario’s proposed Bill 60 - Fighting Delays, Building Faster Act, 2025. Up Consulting Ltd. has been retained by Build Urban to review and provide planning comments and recommendations with respect to the proposed legislation, specifically as it relates to the amendments to the Planning Act. Up Consulting Ltd. is a full service land use planning and urban design consulting firm based in Waterloo.
To provide some additional context of our client’s work and objectives, Build Urban is a collection of urban developers who, through their projects, play a significant role in shaping the future urban landscape of Waterloo Region, as well as its economic prosperity. The group’s members share a commitment to an active and progressive form of city building that includes residential, commercial and institutional land uses that are inclusive, healthy, sustainable and vibrant for the community.
Build Urban’s goal is to be a consistent two-way communication channel between urban development stakeholders and all levels of government. They offer technical expertise to government committees, educate through thought leadership white papers, and constructively provide new and fresh perspectives in order to build partnerships in urban development.

As a general statement, we appreciate the Province’s continued efforts to address Ontario’s housing supply challenges and support the delivery of new homes. In principle, we agree that meaningful steps can be taken to streamline approvals and reduce barriers in the planning process. As such, we welcome the opportunity to provide comments and recommendations with respect to Bill 60, per this correspondence.

While we support the intent of the legislation, we have identified several areas within the proposed amendments, specifically to the Planning Act and the Development Charges Act, that warrant further consideration. Our recommendations below are offered to assist the Province in refining the proposed framework in a way that encourages housing delivery and achieves the Province’s broader housing objectives.

1 Planning Act
The following section provides our comments and recommendations regarding the proposed amendments to the Planning Act under Bill 60.
a) As-of-right Variances
The proposed legislation would allow the Minister to create regulations enabling “as-of-right” variances to certain zoning standards, such as height, within defined percentage limits. Transition rules clarify that the applicable standard is fixed at the time a building permit is issued or, if no permit exists, when the lawful use is established. These provisions would not affect minimum setback requirements, which are already addressed through earlier amendments under Bill 17.
Comments/Recommendations: We recognize that the introduction of “as-of-right” variances could provide a streamlined, more predictable approach to minor adjustments in zoning standards, similar in concept to a Community Planning Permit System. By reducing the need for involved planning processes for limited deviations, this approach may help accelerate development timelines and reduce administrative burden, while providing professional planning discretion to municipal staff in assessing the appropriateness of variations.
We recommend that the Province, through the implementing regulations, clarify on how as-of-right variances interact with other development approvals, including site plan control or urban design guidelines, to avoid unintended conflicts. Likewise, we would recommend including monitoring and reporting mechanisms to assess the impact of as-of-right variances on planning outcomes and community objectives.
Overall, while we support the principle of reducing minor regulatory barriers, careful implementation is required to balance efficiency with good planning outcomes and municipal oversight.
b) Simplifying and Standardizing Official Plans
Bill 60 proposes a more uniform and streamlined approach to municipal official plans by introducing several structural and procedural requirements. These include establishing a mandatory chapter sequence and standardized schedules to ensure greater consistency across municipalities. The reforms would also restrict the extent to which development standards can be embedded within official plans, requiring municipalities to move such standards into zoning by-laws instead. In addition, municipalities may be required to merge their various planning documents into a single, consolidated official plan, which could limit or eliminate the use of secondary plans and site-specific policy areas.
Bill 60 is also considering imposing page or word limits to simplify official plans and encourage clearer, more concise policy direction. A standardized set of land use designations would be introduced, with an emphasis on creating more flexible and permissive categories. To assist with implementation, the Province would provide transition measures, potentially including phased timelines, technical support, and updates to underlying data and mapping. Finally, Bill 60 would allow municipalities to submit official plan materials to the Ministry electronically through an online portal, further modernizing and digitizing the review process.
Comments/Recommendations: While our client supports the Province’s intent to make Official Plans simpler, more concise, and easier to navigate, we believe the proposed approach under Bill 60 could benefit from refinement to account for the diverse contexts and needs of municipalities across Ontario. Please see the breakdown of comments/recommendation below:
i) Mandatory Chapter Order and Standardized Schedules
We are concerned that a prescriptive, mandatory chapter order and standardized schedules could be overly restrictive. Municipalities vary significantly in size, growth pressures, and planning challenges. Urban municipalities face very different planning and development issues than rural or small municipalities, and a rigid structure could limit their ability to address local priorities effectively. We recommend that the Province allow flexibility in chapter sequencing and schedules while providing guidance or best practices, rather than imposing a “one-size-fits-all” model.
ii) Limiting Development Standards in Official Plans
We support the proposed shift to move prescriptive development standards from Official Plans into Zoning By-laws. This change aligns with best practices, as Zoning By-laws are better suited for detailed development standards.
In particular, we recommend that urban design-related standards, such as tower separation, floor plates, and other built-form provisions, be incorporated into Urban Design Guidelines or Manuals, rather than included as mandatory Official Plan policies. This would provide flexibility and allow for site-specific evaluation, while still promoting good urban design.
iii) Consolidation of Planning Documents
We generally support the consolidation of planning documents to reduce duplication and improve clarity. Streamlining content across Official Plans, Secondary Plans, and site-specific plans can improve cohesion, readability and implementation of local official plans.
iv) Page or Word Limits
We do not support imposing page or word limits for Official Plans. Municipalities differ widely in the scope of their planning challenges, growth pressures, and policy requirements. Standardized limits could undermine the comprehensiveness of plans and may create difficulties to achieve word limits when future Official Plan Amendments are required. Instead, we recommend encouraging concise, well-structured documents with actionable policy direction through guidance or templates, without enforcing rigid page limit restrictions.
v) Standardized Land Use Designations
We do not support standardizing the number and type of land use designations across all municipalities. Land use needs differ significantly between urban and rural areas, and a uniform approach could constrain municipal planning flexibility. While encouraging more permissive designations may be appropriate in certain contexts, the Province should allow municipalities to retain discretion in determining land use categories and policies that reflect their unique local context, growth objectives, and community priorities, provided they are consistent with the Provincial Planning Statement, conform to Provincial Plans as applicable and have regard to the Planning Act.

vi) Additional Considerations
The following include a list of additional considerations:
• Flexibility and Local Context: Any standardization should be framed as guidance, not regulation, allowing municipalities to adapt policies to their local context.
• Implementation Support: The Province should provide technical support, templates, and best-practice examples to help municipalities align with standardized frameworks without imposing undue constraints.
• Phased Transition: Where changes are introduced, phased implementation timelines will help municipalities adapt policies and systems effectively, particularly where existing planning frameworks are extensive or complex.
Overall, we support the principle of streamlining and simplifying Official Plans but recommend that Bill 60 allow sufficient flexibility to respect the diversity of municipal contexts, provide practical guidance rather than rigid rules, and maintain mechanisms for tailored, site-specific planning where appropriate.
c) Protected Major Transit Station Areas
The legislation would remove the need for Ministerial approval of official plan amendments that solely adjust land-use permissions within Protected Major Transit Station Areas (“PMTSA”). This applies where the amendment authorizes residential uses across all affected lands within the PMTSA.
Comments/Recommendations: We are generally supportive of this approach. However, with the absence of Ministerial review and approval of PTMSA policies it is noted that additional consultation opportunities currently awarded by the ERO process, will no longer exist, limiting opportunities for community engagement and recourse in the event of disagreement with municipal direction. To that end, should Ministerial approval authority be removed for these areas, it is recommended that appeal rights be provided with regards to policy exercises for PTMSA’s.
d) Community Improvement Plan
Bill 60 would expand flexibility for upper-tier municipalities by reinstating previously cancelled Community Improvement Plans and enabling both tiers of municipalities to exchange grants or loans for CIP purposes. Notably, this authority would apply even if the lending municipality’s official plan does not explicitly permit such financial tools.
Comments/Recommendations: We are supportive of this approach.

2 Development Charges Act
The following section provides our comments on the proposed changes to the Development Charges Act. Similar to the section above, recommendations are provided for each subheading.
a) Minister Oversight
Under Bill 60, the Minister of Municipal Affairs and Housing would have the authority to require municipalities to submit their development charge by-laws, supporting background studies, and local service policies by a specified timeline.
Comments/Recommendations: We support this approach, as it provides a clear mechanism for ensuring timely updates and consistency across municipalities. We recommend that the Province allow some flexibility in deadlines to account for differences in municipal capacity and complexity. Additionally, providing clear guidance on submission requirements and encouraging digital submissions would help streamline the process and reduce administrative burden.
c) Local Service Policies and Ministerial Oversight
To enforce the provision of local services through conditions on plans of subdivision or consents, municipalities would need to establish a formal local service policy under Bill 60. These policies should define the services to be provided in different areas and indicate which costs may be funded through development charges, except where specifically excluded. Municipalities would also be expected to review and update these policies periodically. All required policies must be prepared within 18 months of Bill 60 receiving Royal Assent.
Comments/Recommendations: We support the Province’s intent to provide clarity and transparency regarding the provision of local services and the use of development charges to fund them. Establishing formal local service policies can help ensure that developers, municipalities, and the public understand which services are required in different areas and how associated costs are allocated.
We recommend that the Province allow some flexibility in implementation timelines, recognizing that municipalities vary in size, capacity, and complexity of existing planning and DC frameworks. It is also important to ensure that periodic reviews of these policies are practical and aligned with municipal planning/budgeting cycles, so updates reflect changing infrastructure needs without creating unnecessary duplication of work.
3 Conclusion
We trust that the information and recommendations provided in this correspondence will be considered as the Province continues to advance Bill 60. While we are supportive of the Province’s efforts to address housing supply challenges and reduce barriers within the planning and development approvals process, we maintain that the comments outlined in this letter highlight considerations that warrant further review.
We respectfully recommend that the Province incorporate these recommendations to help ensure that the proposed amendments to the Planning Act and the Development Charges Act can be implemented effectively and, most importantly, in a way that supports delivering new housing across Ontario.
Should you have any questions or to discuss, please do not hesitate to contact the undersigned.
Sincerely,

David Galbraith (Up Consulting Ltd)