Subject: Feedback on Removal…

Subject: Feedback on Removal of Shadow Studies from Complete Application Requirements

To whom it may concern,

I am writing on behalf of AgileForm Inc., a Canadian technology company that builds tools specifically designed to accelerate and streamline the shadow study process in planning applications. Our solutions are used by leading architecture firms across Canada and internationally to support faster, higher-quality submissions and more efficient municipal reviews.

We recognize and support the Province’s goal of increasing housing supply and improving the predictability of development approvals — this is a mission we share. However, we are concerned by the proposed regulation under Bill 17 that would prohibit municipalities from requiring sun/shadow studies as part of complete applications.

This change would remove a planning tool that plays a critical role in supporting informed, livable, and sustainable urban development, particularly in dense and growing municipalities such as Toronto, Ottawa, and Mississauga.

Shadow studies are not a barrier to housing. On the contrary, they are a practical, evidence-based tool used to assess how developments will impact adjacent properties, parks, streets, and public spaces. Many of our clients — architects, planners, and urban designers — rely on these studies to refine proposals early in the process and minimize delays or opposition. Thanks to digital tools and automation, the process is now significantly faster, more consistent, and more cost-effective than ever before — with up to 92% time savings reported by our clients.

We respectfully ask that the Province reconsider the approach of eliminating sun/shadow studies from the list of studies permitted in a complete application — particularly in urban, mixed-use, or intensifying areas. A more balanced approach would be to standardize how and when such studies are applied, rather than prohibit them entirely. This would meet the Province’s goal of streamlining approvals while preserving urban livability and providing clear, evidence-based information to support planning decisions.

Thank you for the opportunity to provide input and for considering our perspective.

Sincerely,
Ido Biran
AgileForm Inc.