The following comments apply…

The following comments apply to the proposed new regulation, and regulation changes, made under the Planning Act related to Schedule 12 of Bill 108.

The reduction of timelines for decisions for both the approval authority (Official Plan/Amendments) and for lower tier municipalities (Official Plan Amendments/Zoning By-law Amendments/Plans of Subdivision) are extremely challenging as it is. For the regulations to set the "start" date for these timelines to be as of proclamation for the approval authority, and for any application received after June 6th is unreasonable. Applying the start of decision timelines retroactively would potentially create situations where the deadline would have elapsed at the time of approval of Schedule 12 and regulation. That would in-turn provide unnecessary opportunities for appeals to the LPAT and be detrimental to the Municipality that is diligently processing applications. A more fair and reasonable transition would be to apply the new decision timelines to new applications deemed complete after the regulations (and Schedule 12) come into force and effect, or where the approval authority has not yet received the application.

Secondly, with respect to the regulation establishing requirements and standards for the establishment of additional residential units, it would be helpful to have clarified whether this requirement takes precedence over other Provincial Plans like the Oak Ridges Moraine Conservation Plan which prohibits multiple units.

Thank you for the opportunity to comment and I trust that the above concerns will be reviewed and considered in some detail PRIOR to a decision being made with respect to the proposed regulation.