Building homes is about more than just bricks and mortar – it’s about shaping communities by delivering attainable housing solutions for present and future generations. However, achieving this vision is increasingly challenging due to the growing complexity and rigidity of municipal Official Plans.
A City’s Official Plan (OP) is the guiding document for development and community building. Setting the growth trajectory for municipalities, the OP’s high-level, goal-oriented contents provide inspiration and guidance for developers and the projects they pursue.
Municipalities in Ontario are required to review and update their OP’s every five years, as per the Planning Act to ensure it aligns with provincial policies, as well as population and economic growth projections. Waterloo city council just approved the first phase of its OP review (OPA 58) and while Build Urban is supportive of refining existing policies and updating legislation to conform with existing legislation, there are concerns with the level of detail OPA 58 contains.
For one, it is extremely prescriptive when it comes to building heights and urban design. In particular, Section 3.4 of Waterloo’s updated OP (”Built Form”) contains categories of permitted heights for low-rise, medium and high-rise developments. It is our contention that building heights should not be defined in an Official Plan. Instead, these details should be addressed in zoning bylaws, which are more flexible and better suited to respond to the unique needs of individual projects and neighbourhoods.
Section 3.9 (“Urban Design”) also uses strong language like “will apply” and “shall consider and align” when outlining design standards. While urban design is an important component of community building, this overly prescriptive approach reduces the ability of developers to innovate or respond to site-specific opportunities. For example, requirements for building facades, streetscapes, or public spaces may unintentionally stifle creative solutions that could enhance the community.
Secondly, the OP review has been unnecessarily divided into two phases. The purpose of the two-phased approach is to ensure the City can access funding available through the federal government’s Housing Accelerator Fund (HAF). This fund, administered by the Canada Mortgage and Housing Corporation, requires municipalities to conduct their OP reviews by a certain time to ensure their land use planning aligns with the program’s goals of increasing housing supply and addressing affordability. While accessing HAF funding is important, prematurely advancing phase one risks locking in policies that could limit flexibility and innovation in the future. Given the OP’s status as the City’s most critical guiding document, it’s essential to prioritize thoughtful, comprehensive planning over accelerated timelines tied to external funding programs.
The impacts of overly prescriptive and poorly thought-out OPs are significant. It can over-complicate and delay the application approval process. It can also add unnecessary costs to the application, which are ultimately passed on to homebuyers at the point of purchase, keeping homes out of reach for many residents in our community.
Build Urban understands the importance of having regulations and policies to guide planning and development. Thoughtful and well-designed frameworks are essential to balancing growth with the protection of community values, environmental sustainability, and infrastructure capacity. However, these regulations must be crafted in a way that fosters collaboration and flexibility, rather than creating unnecessary barriers. By prioritizing principles over prescriptive details, municipalities can provide developers with the clarity and adaptability needed to design innovative, context-sensitive projects that align with broader community goals.
Phase One of the OP review has already been approved by Council. However, Build Urban is urging the City to approach Phase Two with caution. It is crucial to prioritize flexibility, innovation, and collaboration in the planning process to ensure that Waterloo’s OP can effectively support the urgent need for housing while fostering vibrant, adaptable communities.