May 10, 2024 Project:…

May 10, 2024 Project: KL.AT

Re: ERO number 019-8492 – Bill 185 , the Proposed Cutting Red Tape to Build More Homes Act, 2024 – Proposed legislation to support the expansion of Settlement Areas for housing supply

On behalf of Everett Community Partners Inc.

Introduction

This submission is to provide comments regarding Bill 185 and its potential impact on the ability of the Township of Adjala-Tosorontio (Township) to provide increased housing supply through settlement boundary expansions.

Our client, Everett Community Partners Inc., collectively own approximately 152 Ha of developable land adjacent to the Everett Settlement Boundary in the Township of Adjala-Tosorontio, County of Simcoe. This submission is to respond to proposed changes through Bill 185 that will support future planning processes for the Township to implement the previously adopted Official Plan Amendment (OPA 15) that was thoroughly prepared, considered, and adopted in 2013. We support improved processes and legislation that promote the village of Everett as a complete community of 12,000 people.

The comments outlined below, while specific to our client’s lands, will also facilitate housing supply in the GTA that is already facing significant growth pressures to 2051 and beyond.

Background

The Township of Adjala-Tosorontio (“Township”) is a small rural municipality uniquely positioned in the high-growth region of south Simcoe. With a 2021 population of 11,260, the Township has spent significant time and resources to come up with a local model (OPA 15) that allows for modest growth in support of the Township’s aspirations to gradually evolve its rural settlements into fully serviced communities that offer a better range of services and opportunities for its residents.

This submission seeks to reinforce and comment on aspects of Bill 185 that will assist with the expansion of Everett through an updated version of adopted OPA 15 that implements the most recent housing directions of the Province while providing growth options for the Township of Adjala-Tosorontio.

In support of our submission, please find attached a map showing the Proposed Settlement Boundary for Everett dated November 11, 2022.

Bill 185 Comments:

We provide the following comments on behalf of our client regarding Bill 185:

Comment 1: Ontario Land Tribunal Appeals

The ability for private sector applications to appeal settlement boundary expansions is a welcome tool to help facilitate potentially complex matters as part of settlement expansions. We suggest that appeal rights should be extended to landowners included/considered as part of the settlement boundary expansion process.

Comment 2: The Need for Municipal Comprehensive Reviews

Proposed new policies contained in the draft Provincial Policy Statement remove the need for a Municipal Comprehensive Review. This change does not negate the need for good planning but does provide flexibility in the timing and delivery of lands for development consistent with the Province’s direction to increase housing supply faster.

Increasing the proposed planning horizon to 30 years is progressive given the complexity and timing needed for many approvals. The extended planning horizon is welcome and allows for greater certainty when making decisions for both infrastructure and land use planning decisions.

Comment 3: Development Charge Deferral

The phase-in of Development Charges is a way to reduce the expense of new homes and make them more affordable. Maintaining the 5 year phase-in of Development Charges would be helpful in this regard for the building industry since these charges are passed on to new homeowners.

Comment 4: Voluntary Pre-Consultation

The value of effective pre-consultation cannot be overstated when trying to provide additional housing in a timely manner while meeting the needs of municipal partners. Many municipal responses to previous Planning Act changes effectively ‘weaponize’ the pre-consultation process to avoid the required timelines to make decisions on planning applications until they are deemed complete. Excessively long pre-consultation processes and information requirements are slowing down the submission of planning applications and ultimately housing supply. The ability of the OLT to determine reasonable pre-consultation is a positive change.

Voluntary and reasonable pre-consultation is more equitable and will facilitate complete applications in partnership with decision-makers.

Comment 5: MZO Criteria Framework

Increased clarity for the consideration of MZOs, with the support of the local municipality, is considered helpful. In the absence of normal municipal practices to deliver timely housing supply, the opportunity for a more standardized MZO process will be an effective tool.

Summary

We appreciate the Province’s efforts associated with Bill 185. We support the Province’s continued improvements for good planning outcomes and increased housing supply. The comments above support smaller complete communities like Everett that want to grow responsibly.