Dear Minister Calandra, The…

Dear Minister Calandra,

The Township of Ramara has reviewed the proposed Bill 185 Cutting Red Tape to Build More Homes Act, 2024) and the Updated Draft Provincial Planning Statement. The Township is submitting the following comments for consideration:

RE: ERO 019-8369, Proposed Planning Act, City of Toronto Act, 2006, and Municipal Act, 2001 Changes (Schedules 4, 9, and 12 of Bill 185 - the proposed Bill 185, Cutting Red Tape to Build More Homes Act, 2024)

Limits on Third-Party Appeals

The Township supports the limitations on appeals for municipal-led Official Plan and Zoning By-law Amendments. The Township has concerns regarding restricting appeal rights for privately initiated amendments to a municipal Zoning By-law as it reduces the public engagement of the amendment. Instead of limiting appeals on privately initiated Zoning By-law Amendments, a screening tool at the Ontario Land Tribunal could be considered to dismiss appeals of amendments that are supported by planning policy as demonstrated by both developer and municipal planning reports.

Repeal of Application Fee Refund Requirements

The Township is pleased to learn of the Provincial governments plan to repeal this legislation. This legislation was difficult for developers, municipal staff, commenting agencies and subject matter experts peer reviewing the submission.

Repeal of Mandatory Pre-consultations

The Township of Ramara has always had a voluntary preconsultation by-law. When the legislation was passed for mandatory pre-consultations our processes were updated and refined with the creation of work flows. The Township is currently working on standard Terms of Reference for the most commonly requested studies. A data analysis was undertaken for the processing timelines for Site Plan Applications comparing the timelines for approval before the mandatory process versus after the mandatory process.

Time Period Average Approval Time for Site Plan Approval
January 2020 – September 2022: 362 days
September 2022 – present day: 54.4 days

The refinement of municipal process and the importance of pre-consultation to identify required studies prior to making an application is evident in the data above. Keeping in mind, the mandatory preconsultation process has only been in existence for just of a year, it is anticipated that all planning applications will have an expedited review due to this process. The Township of Ramara staff schedule a pre-consultation meeting within two weeks of receiving the application, and distribute the meeting record within two weeks of the meeting date. While we understand some developers outside of our borders have expressed concern with the two step preconsultation approach, the added legislation in Bill 185 will afford developers the opportunity to appeal what is being requested offering protection from any unjustified delays. The Township of Ramara does not expect to see a reduction in uptake of pre-consultation due to the feedback received to date regarding the updated process, but would encourage the continuation of Provincial support for this integral step in the process. It has shown in its short time of existence a great benefit and has improved the working relationship between the municipality and the applicants.

Use it or Lose it Framework

The Township supports the use of lapsing periods for site plan applications and subdivisions allowing for conditional approvals for reserving capacity. It would be essential for the municipality to be protected from any legal recourse for the lapsing of approvals and/or the refusal of any sought after extension if deemed appropriate to refuse.

Newspaper Notice Requirements

The Township supports the ability of posting notices of applications on the municipal website where no printed newspaper is available. On individual applications, staff have found it most effective to have a sign posted on the property and mailing notices to those in the prescribed area due to the lack of newspaper in our area and the seasonality of our residents. Recently the municipal wide notices have been sent to a local online newspaper. The news and notices section of the newspaper’s website does not have near the reach the municipal website and social media channels seem to. The municipality also has its own monthly newsletter. Residents are encouraged to subscribe to updates on the municipal website to receive notification for planning application notices, which is seeming to be quite effective.

Signed,

Walied Zekry
Director of Building and Planning
Chief Building Official
RAMARA TOWNSHIP