Thank you for the…

Thank you for the opportunity to comment on the proposed legislation. This correspondence only deals with Schedule 10 of Bill 66. I’m reviewing this from a perspective of a recently retired practising municipal planner who before his retirement actively participated in planning and development matters in Ontario since 1980.

I am uncertain as to the intent of Schedule 10. There is already a process in place for a Minister’s zoning order process (section 47 of the Planning Act) to deal with urgent business opportunities that may not quite align with all government rules and requirements. From past examples in Ontario, the process of implementation involves local municipal decision-makers. If there is something within this process that the provincial government finds problematic, I would urge modification to this existing legislation.

I find the proposal being put forward quite problematic for several reasons:
1) Developers need assurances on what is permissible to build in certain locales; uncertainties in the ‘development game’ such as revising development scenarios as being suggested here do not assist the situation.
2) Planning by its nature is a multi-jurisdictional and multi-stakeholder endeavour working in both local and regional conditions. This contemplated process puts various players potentially at odds with one another which can undermine trust – local municipalities striving for increased assessment within their own borders; local government agencies that will have differing planning/operating objectives at upper/lower tier circumstances as well as regional Public Health, Conservation Authority, Transportation entities; the public who want to be a part of the process to develop their communities.
3) Definitions on terms such as population thresholds, employees generated, etc. appear to be quite arbitrary. Also mechanisms to implement employment jobs in a given area through planning rules is quite problematic, e.g., full/part time definitions, on- versus off-site jobs.

At its core, I’m unsure what the purpose of the proposed legislation is – it duplicates the existing minister’s order process and gives an impression to repudiate the purpose of other standing gov’t legislation in place, i.e., what is the purpose of other government air, water and land stewardship legislation if the proposal’s intent is to circumvent the protection of community living standards and environmental protections. Overall, this proposal leaves you with the impression that the government is governing in needless circles and simply adding to taxpayers’ expense.

To supplement my perspective, and without adding needless word duplication here, I would urge you to consider the positions of the following municipalities (reports under separate cover): Waterloo Region, January 8, 2019; City of Guelph, January 14, 2019.