• We request further…

• We request further information justifying the extreme increase in the MSDs and AOIs around major facilities, or that these distances be reduced to reflect empirical data.

• We recommend that the requirement for compatibility studies for all development of sensitive land uses within a major facility’s AOI be reconsidered. The proposed AOIs are, in many cases, so large that a compatibility study would be unnecessary.

• We recommend that, should Demonstration of Need Studies be required, they be imposed only on proposals for new sensitive land uses that are adjacent to major facilities, where compatibility studies have concluded there will be some impact. This will reflect the intent of PPS Policy 1.2.6.2.

• We request that additional guidance be provided to assist proponents in the preparation of Demonstration of Need Studies, and that the requirements for said Studies be reduced. In their current form, they include several requirements that do not involve justifying proposals on their own merits.

• We recommend that more consideration be given to balancing land use compatibility with the efficient development of complete communities, as the Draft Guideline, in its current form, will frustrate development, increasing costs and barriers, and ultimately dissuade proponents from developing lands within built-up areas.

• We recommend that in-process development applications be “grandfathered” and that, once it is finalized, the Draft Guideline apply only to new development proposals.

• We request that the Province not rush to implement the Draft Guideline. More time should be provided for consultation with impacted parties, including industry professionals, landowners, and members of the public, to refine the Draft Guideline and ensure it does not become a hindrance to achieving other provincial planning and growth priorities.