Please adopt the following…

Please adopt the following proposed changes in Bill 185:
1. Removal of application fee refund requirements outlined in Schedule 12, Section 5(5) and
2. Time limits on site plan approvals, and draft plan of subdivisions outlined in Schedule 12, Sections 7(3) and 10(3).

Please amend or do not enact the following proposed changes:
1. Removal of Planning Authority for the Region of Waterloo as outlined in Schedule 12, Section 1(5). Integrated regional planning and oversight are necessary as the lower-tier municipalities operate
in tight proximity and the region is dependent on the carrying capacity of our watersheds. Unlike most other Ontario cities and communities, the Region of Waterloo has no freshwater pipelines to the Great Lakes and no Greenbelt protections. If the Province is not amenable to retaining Waterloo Region’s planning authority, please consider a) having the Region retain responsibility for maintaining Regional Official Plans while delegating the approval of OPAs and ZBAs to lower-tier municipalities or b) expanding the provincial Greenbelt to the Waterloo Moraine and Protected Countryside. Proposed Provincial Planning Statement Policy 6.2 encourages coordination across municipal boundaries. The Region of Waterloo may be the most appropriate locus for that coordination.
2. Removal of Third-Party Appeal Rights. Schedule 12, Section 3 proposes to limit appeals of council and approval authority decisions of planning applications to the applicant, Minister, municipality or planning authority and a short list of utilities and safety regulators. We believe that public participation in the creation and amendment of Official Plans and Zoning Bylaws serves the public interest and is a long-standing fundamental democratic right that needs to be upheld. Moreover, we do not see evidence that removing the public’s right of appeal will expedite the construction of homes. According to Lawyer David Donnelly, third party appeals are extremely rare, comprising approximately 0.5% of
all appeals, and only 0.25% of all contested hearings. In fact, removal of OLT appeal rights may result in more court-based litigation, which could produce increased delays and higher costs for all parties.
3. Permitting appeals of OPA/ZBA applications that would alter a settlement area boundary as outlined in Schedule 12, Section 6. We believe questions of urban boundaries are too large to be considered via an OPA/ZBA application and should be reserved to Municipal Comprehensive Reviews at which the public can be duly engaged and the urban boundaries can be considered as a unit.