Proposed Regulations– Complete Application

ERO number
025-0462
Notice type
Regulation
Act
Planning Act, R.S.O. 1990
Posted by
Ministry of Municipal Affairs and Housing
Notice stage
Decision
Decision posted
Comment period
May 12, 2025 - June 26, 2025 (45 days) Closed
Last updated

This consultation was open from:
May 12, 2025
to June 26, 2025

Decision summary

The government has made regulations under the Planning Act and City of Toronto Act, 2006 to identify professional engineering as a “prescribed profession” for the purposes of a complete application

Decision details

The Protect Ontario by Building Faster and Smarter Act, 2025 (Bill 17) made changes to the Planning Act and the City of Toronto Act, 2006 to scope “complete application” requirements, including creating a new regulation-making authority for the Minister to provide greater recognition of technical studies and reports prepared by certified professionals.

“Complete application” refers to provincial and municipal requirements that need to be satisfied before a planning application must be accepted and the statutory timelines for municipal review and decision on the application begin.   

Further to the Bill 17 legislative changes, the Minister has amended 4 existing regulations under the Planning Act to identify professional engineering as a prescribed profession for the purposes of the new provisions that deem material prepared by practitioners of the profession to meet complete application requirements. The Minister has also created new regulations under the Planning Act and the City of Toronto Act, 2006 related to site plan control for these purposes.

The identification of professional engineering as a prescribed profession by Minister’s regulations means that municipalities are required to accept technical studies and reports prepared and stamped by professional engineers in the first instance as satisfying complete application requirements (without requiring further review or revisions).  This designation encompasses all engineering subspecialties as every engineer works under the P.Eng. in their area of expertise.

The Minister’s regulations are intended to help speed up development approvals and reduce some initial application costs associated with development proposals.   

The Ministry has also made technical changes to O. Reg. 197/97 (Consent Applications) to replace the images of the form of consent certificates in the existing regulation with text-based descriptions of the content to meet accessibility standards.

Comments received

Through the registry

310

By email

1

By mail

0
View comments submitted through the registry

Effects of consultation

As a result of the legislative changes made by the Protect Ontario by Building Faster and Smarter Act, 2025 (Bill 17), ERO 025-0462 Proposed Regulations Complete Application proposed a number of changes to scope complete application requirements by future regulation, including specifying certified professionals from whom municipalities would be required to accept studies.  The posting was open for a 45-day public consultation period from May 12 to June 26, 2025.

311 comments were received during the consultation period, including 300 comments submitted directly through the ERO and 11 comments submitted via email.  The majority of submissions were from individuals and municipalities, with some submissions from development and other groups. 

Most of the feedback related to proposed measures to prohibit or limit complete application studies, with generally less substantive detail provided in the feedback related to the proposal for certified professionals as compared with the proposal for limiting or prohibiting studies. 

There were generally mixed views on the proposal regarding certified professionals.  There were some supportive views that the proposal could assist with streamlining and that certain professionals (such as engineers) are bound by strict codes of conduct and liability which ensure high standards.  Others expressed concerns that mandating automatic acceptance of studies by certain professionals removes oversight and eliminates important checks and balances and that there may be risks with potential errors in, or incomplete technical analysis. Various concerns were expressed with questions of potential liability with the identification of specified professions. 

There were some comments that prescribing certain professions for these purposes could lead to overall increase in costs / delays. 

There were some specific suggestions on professions which could be considered for future Minister’s regulations. 

Effects of the Consultation on this Decision

The government considered all the feedback received through the consultation for complete application requirements. 

Making regulations to identify only professional engineering as a prescribed profession is based on the feedback received and the regulation of the engineering profession which is bound by strict codes of conduct and accountability for the accuracy and integrity of the work, as demonstrated through the act of a professional engineer stamping and signing a technical report or document.

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Original proposal

ERO number
025-0462
Notice type
Regulation
Act
Planning Act, R.S.O. 1990
Posted by
Ministry of Municipal Affairs and Housing
Proposal posted

Comment period

May 12, 2025 - June 26, 2025 (45 days)

Proposal details

The government is seeking feedback on potential legislative and regulatory changes to help make it easier and faster to build new homes and infrastructure like transit, roads, and water and wastewater systems as part of the proposed Bill 17, the proposed Protect Ontario by Building Faster and Smarter Act, 2025 and associated regulations.

Schedules 3 and 7 of Bill17 propose to amend the Planning Act and the City of Toronto Act, 2006 to limit complete application (studies/reports) requirements to what is currently identified in municipal official plans, except where the Ministry of Municipal Affairs and Housing approves the changes.

Bill 17, if passed, also includes regulation-making authority that would enable the Minister of Municipal Affairs and Housing to further regulate the reports or studies required as part of a complete application. The changes would enable the Minister, by regulation, to:

  • prescribe a list of subject matters for which studies cannot be required as part of a complete application;
  • identify the only studies that could be required as part of a complete application;
  • specify certified professionals from whom municipalities would be required to accept studies.

Collectively, the proposed changes would have the effect of reducing the number of studies that make up a complete application when proponents submit development proposals to municipalities.

Complete Application Requirements

The Planning Act and its regulations set out the minimum requirements for the information that must be submitted with various planning applications. Currently, municipalities can also require information or materials in addition to the minimum provincial requirements for most of these application types (i.e., official plan amendment, zoning by-law amendment, subdivisions, consent and site plan) as set out in official plan policies.

A planning application is considered “complete” when it contains all the information required by the relevant sections of the Planning Act, relevant Minister’s regulation(s), as well as the additional materials or requirements set out in the applicable official plan.

Complete application requirements ensure the information needed to assess planning applications is included with the application to enable municipalities to make timely decisions.

Proposed Contents of a Regulation

Currently, there is inconsistency in the scope, type and number of studies required for planning applications across Ontario. Municipalities can require various studies and reports, leading to delays and complications in the application process. The government is looking to create more consistent and predictable requirements across municipalities. 

We are consulting on proposed regulations that would, if Bill 17 is passed, limit the information and material that may be required by a municipality as part of an application for an official plan amendment, zoning by-law amendment, site plan control, plan of subdivision or consent.

Specifically, it is proposed that the following topics could not be required as part of a complete planning application:

  • Sun/Shadow: information and material related to the impact of shadows cast by a proposed development on the subject land and on surrounding lands including streets.
  • Wind: information and material related to the potential impacts of a proposed development on wind conditions in surrounding areas.
  • Urban Design: information and material concerning the urban design of a proposed development, including how a proposed development aligns with municipal urban design guidelines or policies.
  • Lighting: information and material related to lighting and lighting levels on the site, including the location and type of lighting fixtures proposed on the exterior of the building and on the site.

We also welcome your thoughts on:

  • What topics or studies should be identified as being permitted to be required by municipalities as part of a complete application?
  • Which certified professionals (e.g., professional engineers) should be included in the list of professionals whose reports/studies would be required to be accepted as final submissions by a municipality as part of a complete planning application

Impact on the Environment

Proposed changes regarding study requirements (complete application) are expected to have a neutral impact on the environment since key studies would be identified in official plans or permitted by regulation. In cases where an exception is required to enable additional studies, municipalities may seek approval from the ministry. However, through consultation, the ministry is interested in hearing perspectives on whether limiting the types of studies that   are permitted to be required as part of a complete application could lead to any unintended impacts on the environment.

Analysis of Regulatory Impact

Building on previous legislative and regulatory changes, the initiatives are anticipated to further support streamlining land use planning processes; building more homes faster; and creating more certainty in the development approvals processes.

Supporting materials

Comment

Commenting is now closed.

This consultation was open from May 12, 2025
to June 26, 2025

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