A stormwater study removed from an application checklist does not make rain disappear. Nor does eliminating a technical review decide how a project will drain, connect to a street or receive water and sewer service. Cancelled studies and reviews do not disappear. They move, usually to a later stage of approvals, where redesign costs more.
That is the test Ontario should apply to Bill 98, the Building Homes and Improving Transportation Infrastructure Act, which received royal assent on June 2. The omnibus law is designed to accelerate housing supply, standardize municipal planning frameworks, and reform transit fares and service integration. The province is right to pursue consistent rules that can cut repetition and delay.
But standardizing plan structure, study requirements and sequence of decisions is a different exercise from overriding evidence about a particular place. This difference matters more as implementation proceeds. Every task removed from one stage needs a clear home elsewhere. Success should be measured in homes completed, infrastructure delivered and public spaces that people actually use.
Bill 98’s broader planning package is only partly operating. The lot-size provision is in force yet has no practical effect until a regulation sets the cap; 175 square metres remains only a proposal. The standardized official plan framework is not yet in effect, while proposed study lists and broader site-plan reforms remain proposals. Meanwhile, developer-identified parkland rules took effect July 1. Public debate needs to distinguish between enacted law and measures still being designed.
Standardized framework, local choices
An official plan is a municipality’s long-term, land-use policy document. The framework, enacted but not yet in effect, will require common chapters, maps and land-use categories. This common architecture could make plans easier to navigate for residents, applicants and decision-makers alike. It could also make municipal data easier to compare. But a common table of contents is not the same as a common planning answer.
Ontario should set shared headings, definitions, map conventions and core data, while municipalities address water and sewer capacity, flood risk, heritage, farmland and local growth patterns. The framework should be tested in a representative group of municipalities with results published before provincewide implementation.
Secondary plans, detailed policies for a particular neighbourhood or growth area, should remain available when roads, pipes, parks and development across several properties need co-ordination. Within the common framework, municipalities should be able to adopt locally tailored policies when justified by evidence. Standardization should expose local choices, not erase them.
Ask for the right evidence
Before formal review begins, a planning application must include complete information. Ontario proposes two categories: “core” studies that could be requested routinely and “contingent” studies requested only when a site condition makes them relevant. The aim is to reduce arbitrary or late demands. Applicants should know at the outset what evidence is needed, and municipalities should not request a costly report without a planning reason.
Ontario should publish common study names and plain-language instructions for the requirements of each report. The catalogue should stay open. A site condition nobody anticipated when the regulation was drafted is still a site condition and may still require evidence. A request for a contingent study should state the site condition and the decision it addresses. Reports should come from qualified professionals and meet published standards.
After an application is deemed complete, a new study should be requested only in response to new information, a design change or a legal requirement. One municipal lead should combine departmental comments for each unresolved issue. It needs to identify who can resolve the issue and repeat comments should say exactly what is missing. The goal is not fewer facts. The goal is one clear request, one adequate answer and one accountable review.
Modernize the site plan
Site-plan control is the municipal technical review that usually follows decisions about permitted use, height and density. It addresses building placement, access, parking, drainage and other on-site details. Delay causes real problems. Ontario’s consultation cites an average review time of 23 months, far beyond the 60 days after which an applicant may appeal a non-decision. The consultation offers options ranging from faster review streams to removing site-plan control from the Planning Act.
Eliminating the tool does not eliminate issues of drainage, grading, access, loading, waste collection, landscaping or servicing. Moving those elements into zoning could slow early approvals, postponing them to the building-permit stage could make redesign costlier, and leaving them unassigned means municipalities, applicants and future residents inherit a risk nobody has priced.
Before narrowing any planning tool, Ontario should publish a simple transfer map: What question is being removed? Where will that issue be decided instead? Who will decide it? What standard applies? When must it be resolved?
Straightforward projects should receive an expedited review. Complex projects should require a fuller technical review. After a fixed number of review rounds, a senior issue-resolution meeting should be mandatory. Faster approvals come from early co-ordination and clear responsibility — not from pretending necessary work has vanished.
Pair provincial permissions with performance tests
The proposal to cap lot size at 175 square metres illustrates the difference between permission and outcome. Smaller lots support infill, new homes within already built-up areas, and use serviced land more efficiently, but they do not guarantee affordability. Lot size interacts with lot width, drainage, trees, parking, snow storage and access. The proposed rule would change zoning; it would not split a property or establish that a new lot can be safely serviced and developed.
If Ontario proceeds with the proposed lot-size regulation, it should publish guidance for regular and irregular lots and allow a limited, evidence-backed exception for areas with demonstrated servicing, hazards or physical constraints. It should track completed homes and not just applications or requests for exemptions from zoning rules.
Parkland requires the same focus on results. The new rules allow qualifying, developer-identified land, including land affected by easements and publicly accessible space that remains privately owned to count toward parkland requirements. Criteria for access, visibility, soil and usable size are an important floor, not a measure of success.
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How much a conveyance counts is the least settled part of the new framework. On appeal, the tribunal must credit at least 70 per cent and cannot go higher unless the municipality agrees. When a municipality accepts the land without an appeal, the legislation sets no figure at all.
Municipalities should report where these spaces are, how much parkland credit was granted, who maintains them, whether they remain publicly accessible and which local needs they meet. A legally compliant space that is difficult to find, poorly connected or unsuitable for everyday use fails the only test that matters.
Ontario should publish one current Bill 98 implementation table showing what is in force, what awaits a commencement order, what depends on regulation and what remains a proposal. An annual results report should cover review times and rounds, housing starts and completions, infrastructure commitments, municipal costs, parkland delivered and evidence-based local exceptions.
Bill 98 need not force a choice between provincial consistency and local decision-making. The useful distinction is between needless differences in process and real differences in land, infrastructure and risk. Ontario can standardize the first while respecting the second.
Speed matters. But speed is a process measure, not proof of a successful community. The real test is whether reform produces buildable homes, co-ordinated infrastructure and usable public space — without moving necessary planning work to a later, more expensive stage.
