Regarding a complete…

   Regarding a complete application and its description in the regulation, the regulation should require that all studies as required in the PPS, Provincial Plans, the Official Plan, or by municipal policy, have been completed. In an increasing number of cases, including where the proponent is the approval municipality, I have observed that studies are not complete at the time of the so-called "complete application", with the proponent claiming that they will be completed at the detailed design phase. However, by then the higher order approvals have been made, citizen and agency appeal opportunities have been curtailed, and site plans are not subject to appeal. In other cases, placeholder studies are included but do not address all issues, or study protocols, and thus are updated much later in the process, including after a planning decision is made by the municipality and before the appeal is dealt with at the OMB (for example, the Batten-White subdivision proposed for the provincially significant Loggerhead Marsh in the City of Peterborough, heard before the OMB this past fall). Thus, there is a strong need for the complete application description and regulation to ensure that studies are completed, thoroughly, and a declaration be made by the proponent that this is so. If this is not complete, then the proponent should not have access to the new tribunal.

  Thank you for this opportunity. I may provide further comments tomorrow, after a bit more research.

[Original Comment ID: 212119]