To Whom It May Concern, The…

To Whom It May Concern,

The City of Brampton (hereinafter referred to as ‘the City’) is supportive of efforts by the
Province to address the housing affordability crisis. The City appreciates the opportunity to
provide comment on the Proposed Planning Act and City of Toronto Act Changes (Schedules 1
and 9 of Bill 23) and offers the following comments to assist the Province. The City’s
assessment of these proposed changes indicates that they will have far-reaching social,
economic, environmental and financial impacts.

In many circumstances, the City is currently undertaking work to achieve the aims outlined in
Schedules 1 and 9, including:
 Working to address missing middle housing typologies and supporting neighbourhood
intensification, while considering the design and integration of intensification in a manner
that respects the unique context and neighbourhood character. This work is being done
through the Official Plan Review and Comprehensive Zoning By-law reviews.
 Supporting higher density around transit, which will be evaluated through the Major Transit
Station Area studies being conducted by the City. However, staff have determined that
completing a proper analysis will take more than the proposed one-year timeframe. .

Appendix 1 provides detailed comments and questions outlined in the table. There are a number
of key comments summarized below:
 Proposal: Changes are proposed to exempt all aspects of site plan control for
residential development up to 10 units (except for the development of land lease
communities).

City Comments:
 Site plan control provides a key opportunity for the City to ensure that the design of new
buildings integrates into the existing urban fabric and supports the goals and objectives of
the community area. Site Plan also plays a critical role for the City to promote sustainable
design (e.g., use of Green Development Standards) and enables the City to take a
comprehensive approach to planning and designing sustainable communities.
o The Urban Design Review Panel, a third-party review process, has been
formalized in the City of Brampton to assist the City in its review of new
developments. To communicate their role, a letter has been provided to the City of
Brampton to submit with its formal comments on Bill 23, and is attached as
Appendix 2.
 There are neighbourhoods within the City where site plan control plays a critical role,
especially where zoning requires updating. Site plan control in Brampton has played an
important role to support contextually appropriate gentle intensification in the existing
neighbourhood context.
 With the aim to address the missing middle, site plan control ensures that the development
of new missing middle housing typologies is appropriately integrated into the surrounding
context, while protecting valued natural heritage assets.
 The City is working currently to achieve simplified, more strategic Official Plan policies and
Zoning By-law regulation by using site plan control as a tool to protect against potentially
negative impacts on the existing community.

City Recommendations:
 The City recommends that the Province not proceed with this proposal. Site plan control
plays a key role in determining appropriate infill and gentle intensification in existing
neighbourhoods.

Proposal: Changes are proposed to remove the planning policy and approval
responsibilities from certain upper-tier municipalities (regions of Durham, Halton,
Niagara, Peel, Simcoe, Waterloo, York). These proposed changes would come into
effect upon proclamation at a future date. The Minister will become the new
approval authority for all lower tier official plans and amendments. The Minister’s
decisions cannot be appealed.

City Comments:
 The potential removal of upper-tier panning responsibilities places a large burden on local
municipalities, with a significant administrative cost, staffing pressures to accommodate
the increased workload, and requires local municipalities to overcome knowledge gaps.
The coordination and collaboration between regional and local planners have been highly
successful.
 While the City appreciates opportunities to streamline development related approvals, it
is unclear how removal of Regional approval for Official Plans, plans of subdivisions, and
consents to sever does not eliminate the need for Regional oversight and coordination
of major planning issues given their ownership of assets across lower tier municipalities
 Incorporation of the Region’s Official Plan into the Brampton Plan will cost time and
money, delaying the implementation of the updated Brampton Plan policies.

City Recommendations:
 The City recommends the Province reconsider this proposal as an actual reduction in
costs and time is unlikely given the potential unforeseen impacts and onus now placed on
local municipalities.

More generally, the City has concerns about themes in this ERO posting around reduced public
engagement, tight timelines to comply with proposed regulations, and the large financial burden
these proposals will place on the City. These administrative costs are compounded with other
increased costs to municipalities identified in other Bill 23 registry postings.

The City of Brampton would like to thank the Province for the opportunity to provide feedback and
comments on the proposed changes.

Sincerely,
Steve Ganesh, MCIP, RPP
Commissioner (A)
Planning, Building & Growth Management