We understand the province…

We understand the province is concerned about the breadth and scope of information requirements to support developments, the time that can be tied up in peer reviews, and the appeal of system-wide changes to support swift implementation.

In respect of complete applications regulations, we offer the following comments:

• We encourage the Minister to provide a list of studies that can be readily incorporated into Official Plan ‘complete application’ requirements, potentially reducing the timeline required for approvals. This is particularly important for communities advancing new Official Plans to completion, as the proposed approach would require the Minister’s approval of application requirements before the plan is adopted, and then the Minister’s approval of the plan.

• We encourage the province to consider whether it intends for the Minister to approve complete application requirements for all plans, including local Official Plans for which approval is otherwise delegated to upper tier municipalities.

• It is important that Municipalities be able to request the information that they need to make good decisions for their communities.

• The built form in Bruce County and its local communities is such that shadow and wind impacts arising from development have rarely been a factor; however, these could become more important as we work to support density and intensification; shadow studies could also be important for municipalities considering whether to support new wind energy systems to meet Ontario’s growing electricity requirements.

• Urban design is important to creating vibrant and attractive communities.

• Lighting plans are important to address offsite impacts from development, and to support energy conservation by lighting what needs to be illuminated, and nothing else.

• As an alternative to ruling out entire categories of information, we suggest the province engage with Municipalities and Industry professionals to produce standard terms of reference. These could:
o Define the scope of information requirements relative to project scale
o Allow for impacts and potential for mitigation to be understood
o Allow reviews to focus on the outcomes of information, rather than whether its all there.

In respect of studies by prescribed professions, we offer the following comments:

• While the scope and duration of peer review can be a problem, issues with studies can relate to a range of factors. These can include disagreements with respect to the scope or terms of reference, alignment of recommendations with municipal standards, ability of a municipality to implement recommendations, and errors in assumptions, data, or differences in professional opinion with respect to conclusions.

• We suggest that addressing the root causes of issues through improved standards for terms of reference, pre-submission consultation to confirm the applicable municipal standards and implementation capacity, and provision for review, questions, and revisions to studies would be preferable to municipalities being compelled to accept first submissions as ‘complete,’ the effects of which could be:
o More applications refused and advanced to the Ontario Land Tribunal;
o Harm to communities associated with errors that are not addressed;
o Lawsuits to recover damages

• Increased standardization of terms of reference and study frameworks could provide more opportunities for technical professions such as Certified Engineering Technicians to enhance their scope of practice.
We encourage the province to consult further with municipalities and with professional organizations that could be prescribed if it moves forward to implement regulations related to complete applications and prescribed professions.