Submitted by Rosalie Evans,…

Submitted by Rosalie Evans, Solicitor-Clerk, Municipality of Neebing. (Note that these are the Solicitor-Clerk's comments from a Northern, Rural, Small municipality perspective. These comments do not necessarily reflect the Municipal Council's concerns - which cannot be determined until the next Council meeting (August 7th) which is past the commenting period.)

Regarding the 5th (main) bullet point under "Transition":
The timing is within a number of days after submission of a "complete" application. Who determines whether or not an application is "complete"?

Under "Additional Residential Unit Requirements and Standards":
Requiring a mandatory 3rd unit makes sense if there are municipal services (water, sewer). In rural areas, our rules regarding a mandatory 2nd units at present are that they must annex to the existing well and septic systems - we don't want second wells or second septic systems installed on one property. I am concerned that now requiring a third unit may result in too much pressure on well/septic systems. I suggest that the mandatory 3rd unit apply ONLY to urban municipalities that have municipal services. There it makes total sense - but out in a rural area with no municipal services - there could be environmental impacts.
Further, our municipality has some inland lakes which have been declared by the Province to be "at capacity". As such, no additional lot creation is permitted at these lakes. People can build on the lots they already have (in accordance, of course, with zoning by-law provisions), but they cannot sever the property to create any new lots. This is based on impacts to water quality and/or quantity with additional densities. Mandatory 3rd units will have environmental impacts on these lakes. It is suggested this not apply to waterfront residential homes or waterfront seasonal residential homes as a whole - but - if not as a whole - then AT LEAST where the lake has been determined to be "at capacity" by the Province.

Thank you for the opportunity to comment