Thank you for the…

Thank you for the opportunity to comment on the proposed regulations related to complete development application requirements. Please see the attached staff report and comments for details. A summary of the comments is provided below:

The primary comments from the County of Brant focus on the proposed changes to the Planning Act under Schedule 7, which shifts the authority to define a "complete application" to the Minister. This gives the Minister power to approve municipal requirements and to prohibit municipalities from requesting certain studies (such as urban design, sun and shadow, and lighting studies) as part of a complete application.

Summary of County of Brant Comments:

Agreement on Principle, Disagreement on Approach: Staff agree in principle that there should be standardization and streamlining for complete application requirements. However, the proposed approach of removing reports that support good planning practice, such as urban design, lighting, and sun and shadow studies should be re-examined.

Instead of removing these studies entirely, staff suggest two alternatives:
The Province could enable standardized versions of each study type with standard terms of reference.
The Province could provide clarity on how these studies can continue to be enforced through strong alignment with policies in a municipality's Official Plan and appropriately addressed with other implementation tools (CPPS, zoning, site plan etc.).

Concerns about Shifting Workload: If municipalities can no longer require these studies from applicants, the responsibility and workload for this analysis would shift to the municipality. If this is the Province's expectation, staff recommend that provincial support, such as funding standardized 3D data, should be provided to assist municipalities. Many municipalities are undertaking "digital twin" work and would benefit from additional investment.

Clarification on Securing Studies: Staff also expressed a need for further clarification on whether necessary health and safety studies (e.g., for noise, vibration, or hydrogeology) could still be required and implemented through development agreements, even if they are not part of the initial complete application requirements.

Should there be any further questions, the County of Brant would be happy to have further discussions on the subject.