Greenspace Alliance responds to Ontario’s consultation on land use planning and development charges

8 January 2014

The Greenspace Alliance today submitted responses to the questions posed by the Ontario Ministry of Municipal Affairs and Housing about its (.) Land Use Planning and the Appeal System; and (.) the Development Charges System.

The consultation documents are available from here.

Key points:

On Land Use Planning and the Appeal system:

+ All applications pertaining to a given property should move through the review and approval/rejection process together and be coordinated with any Committee of Adjustment applications.

+ Zoning amendments to implement new Official Plan policies should be completed within a year.

+ Pre-consultation with community stakeholders on development proposals should be obligatory.

+ The role of the Ontario Municipal Board is far too strong.  It should act more like a true appeal body by providing direction regarding disputes and then sending the matter back to the municipality for consensus resolution.

+ Any party to an appeal should be able to do so to a Consolidated Board, composed of members of the OMB and the Environmental Review Tribunal, when both Planning Act and Environmental Assessment Act expertise and jurisprudence would be relevant to the adjudication.

On Development Charges in Ontario:

+ Growth should pay for growth by covering all of the capital costs of growth.

+ Development Charges should vary in accord with the cost of growth in specific areas.  In Ottawa these areas should be: Inside the Greenbelt | Kanata | Stittsville | Orleans | Barrhaven | Leitrim | Riverside South | rural.

+ Deductions for “benefits to existing settlement” should be calculated based on populations in specific nearby areas.  Roads often are a disbenefit to “existing.”

+ The 10% discount for certain services should be abolished, especially for transit.

+ The level of service for transit should be calculated forward-looking, not based on a 10-year historical average.



Media Release: Greenspace Alliance responses to MMAH

PDF version

17 January 2014

For immediate release



Ontario is reviewing the land use planning and development charges system of the province. The Greenspace Alliance of Canada’s Capital has responded to a long series of questions posed by the Ministry of Municipal Affairs and Housing.

On development charges, the responses state that the principle that growth should pay for growth should be more strictly implemented. “Fair development charges would reduce the pressure on the City’s capital budget and potentially on property tax increases, as the real cost of providing infrastructure would be reflected in the development charges,” said Amy Kempster. “The significant differences in the cost of providing infrastructure between Kanata, Stittsville, Orleans, Barrhaven, Leitrim and Riverside South should be reflected in the development charges. Averaging costs over all urban areas outside the Greenbelt does no service to prospective homeowners who could otherwise profit from lower cost development.”

The Alliance supports the City’s position that contributing to the cost of Light Rapid Transit should not be constrained by the 10-year historical level of transit service and that the 10% statutory reduction should not apply. Going further, the Alliance believes that these amendments to the Development Charges Act should apply to all transit investments, not just LRT. “Cities can no longer afford to invest in both roads and transit,” said Nicole DesRoches, co-chair of the Alliance. Transit has to be given priority, not be disadvantaged through outdated criteria.”

On land use planning and the current appeal system, the responses include a statement that pre-consultation with community stakeholders should be a requirement, before applications are formally filed. Planning staff should be as available to provide advice to communities as it is to developers. All applications related to a given property should move together through the review and approval or rejection process.

“The quality and quantity of dialogue at the local level should be significantly strengthened,” said Sol Shuster, summarizing several of the Alliance’s responses. “Both the City and developers should engage far more in genuine public consultation. An ongoing consultation process such as exists in cities like Vancouver would avoid many an OMB appeal.”

The role of the Ontario Municipal Board is far too strong, the Alliance argues, pointing out that this actually impedes dialogue and issue resolution at the local level. The response says that the OMB should act more like a true court of appeal, giving direction on interpretation of policy or law and then sending the matter back to the municipality for reconsideration and consensus resolution among all stakeholders.

The Greenspace Alliance was founded in 1997, works to preserve and enhance green spaces in the National Capital area, and engages with all levels of government. It believes that urban greenness is essential for a community’s quality of life, contributing to personal, social, economic, cultural and spiritual well-being, and connecting us with the natural and cultural history of our region.

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For more information, please contact:

Erwin Dreessen, co-chair – [tel], e-mail []

Access the responses – on land use ; on development charges


Notes from the November 21 2013 workshop

Letter on land use planning – November 2014

The mandate letter from Ontario Premier Wynne to her Minister of Municipal Affairs and Housing included directives about reform of the OMB, Development Charges, and related land use planning matters.  To assist him in his mandate, we sent the Minister selected quotes from our submission of last January to his Ministry.  We copied the Attorney General, Liberal MPP Peter Milczyn (who recently tabled a private member’s bill on the subject) and Minister Naqvi, who has extensively consulted with the Ottawa community about OMB reform.Here is a pdf of our email.

Erwin – 30 November 2014

P.S.: Peter Milczyn’s proposal is embedded in Bill 39, which passed Second Reading with the support of both Liberal and NDP members (34-7) and was referred to Committee on November 20.  David Reevely drew attention to it in a November 27 Ottawa Citizen column, “OMB bill would return power to politicians.” The web site title is more brutal: “Bill would neuter Ontario Municipal Board.” Its most drastic provision is that comprehensive Official Plan Amendments could not be appealed for 5 years!

P.P.S.: The mandate letters are available here.