February 25, 2023
Toronto City Hall
100 Queen Street West
Toronto, ON M5H 2N2
Attention: Nancy Martins
Re: PH2.2 – Bill 109 Implementation, Process and Technology Improvements
Dear Councillor Bradford and Members of the Planning and Housing Committee
We would like to start off by praising the efforts of the City Planning Division and other City staff to respond to the challenges posed by Bill 109 and its adverse effects on citizen participation in planning issues in Toronto. The proposed process changes have the potential to effect both an increase in review efficiency and an improvement in information availability. The challenge will be to implement these improvements within the very limited application review time permitted by the Provincial Bill.
Technology improvements in the AIC
The technology improvements for the Application Information Center (‘AIC’) will be very helpful. The current version of the AIC is not user-friendly, particularly for an unsophisticated user. The map-based front-end needs badly to be improved, and this is recognized as a priority in the staff report.
To make information on a development more accessible to the public, we suggest that a separate on-line summary document (an ‘Application Summary and Guide to Information’) be added to the AIC, as featured item in the list of items for each application. The purpose of this document would be to provide a brief and easily readable one-or-two-page summary of the application, including minimal information on proposed height and other key statistics, along with hyperlinks to sources of information contained in the documents (the detailed project data sheet, Planning Application Checklist, and other documents submitted as part of the complete application).
A key point we want to emphasize here is the need for a “quick read” summary and navigation guide for each application. Many residents find it difficult to navigate through the many detailed items in the AIC, not knowing which item to access to provide information on a particular point. Making the Application Summary a navigation guide would help users with more access, more detailed information … much more easily.
We believe City Planning is aware of the need for this need — and indeed have recognized this in their comments on ‘Legibility’ in the report. We simply want to emphasize the need for effective communication to lay members of the community.
Automatic notification service
The proposed automatic notification messaging service will be a major step forward in enabling citizens to effectively participate in the planning process. The key requirements here are (1) that citizens be able to register for automatic notifications, (2) that notifications include a brief summary of the application, and (3) that notifications occur as soon as a complete application has been posted to the AIC.
All this is excellent, but will take time to implement. We urge the Committee to make the implementation of this service a priority.
Information to replace the preliminary report
We strongly support the use of a mandatory Planning Application Checklist Package (‘PACP’) as a means of ensuring that a planning application deals with all of the issues raised in the PACP prior to being deemed complete. Quoting from the report (p. 5):
A number of improvements are underway to ensure that the issues that would have been reflected in the Preliminary Report continue to be made available to the Councillor and the public in a timely way after an application has been deemed complete and prior to a Community Consultation Meeting (CCM).
It remains to be seen whether this will work as well as is anticipated. One of the key values of the current Preliminary Report is its identification of the important planning issues raised by a proposed application. It is essential that this continue in the replacement for the Preliminary Report, in whatever form that replacement takes.
It will also be important to ensure that this information is available to the public well before the date of a planned Community Consultation Meeting.
It is going to be a challenge for planning staff to meet the objectives set out in this report by the dates proposed. We applaud the intent. And look forward to its implementation. Given the critical nature of the proposed changes, we urge the Committee to request that the Planning Division report providing an update on their implementation prior to July 1, allowing for public comment.