The City of Waterloo is in the process of drafting a land use planning tool called the Community Permit Planning System (CPPS), an initiative that has a goal of streamlining the planning approvals process for development. The CPPS is proposed to apply to the Uptown Primary Node and Erb Street corridor and would combine Zoning By-law Amendments, Minor Variances and Site Plan applications into one single application and approval process.
In principle, Build Urban is supportive of CPPS as tools that are inherently focused on streamlining development processes in priority growth areas. At the same time, Build Urban is keenly interested in ensuring the CPPS and associated urban design guidelines provide a fair, reasonable and transparent process for new developments moving forward.
We have been actively engaged throughout this process and recently submitted our second round of comments in response to the draft CPPS By-law. We will break down what we view as key improvements from the first draft, what still needs refinement and discuss how a thoughtful implementation of the CPPS has the potential to unlock new housing opportunities across our region and province as a whole.
To start, it is important to acknowledge that the City has made meaningful improvements in the revised CPPS draft. Many of the key recommendations from our initial submission, including an expanded variation threshold and simplifying certain provisions, have been incorporated. That’s a step in the right direction, and it shows a willingness to collaborate and adapt.
The CPPS has a lot of potential, but several elements of the revised CPPS draft require further consideration. Here are some of the adjustments Build Urban recommends to make a tangible difference:
Don’t Hold Up Small Projects
Currently, the CPPS applies to all developments in the area, even smaller five to ten-unit properties. That might not sound like much, but these smaller projects are exactly the kind of missing middle housing we need more of, fast.
Under the Planning Act, projects that have fewer than ten units are exempt from site plan approval. Fundamentally, the Planning Act recognizes that smaller projects may not warrant the same scrutiny of larger scale projects and that municipalities should be removing barriers to these missing middle forms of housing. As currently drafted, the CPPS is proposed to apply to all projects, including these smaller scale ones.
Consistent with Provincial leadership, we recommend that these projects be either exempt from the CPPS entirely or made optional, so the process is made as efficient as possible, especially for smaller community-needed builds.
The Importance of Timelines
A foundational element of the CPPS is the ability to fast-track development applications through one standardized application. In the current draft of the CPPS, the City has proposed that this 45-day review timeline start after comments come in from City departments and outside agencies.
But that is far from how it is supposed to work. Under the Planning Act, the review period is meant to start once the application is submitted, not after everyone has had a chance to have a say in the matter.
This causes a delay to the timeline and adds uncertainty to the process. We recommend that the review clock begin once the required submission materials are in and that the comments from staff and agency be removed from the ‘completeness review’ stage of the process.
Conditions of Approval
The draft CPPS has a long list of conditions the City can attach to an approval. While many of these make sense, like requiring agreements for off-site parking or ensuring environmental protection, a few need clarification and may go beyond what the Planning Act allows.
Why This Matters: Housing Acceleration Goals
Just like the CPPS, Build Urban supports efforts that aim to reduce barriers and speed approvals, but we must keep the process focused and fair.
The CMHC Housing Accelerator Fund is focused on the same goals, helping cities like Waterloo unlock new housing supply by fixing the systems that slow things down. As CMHC puts it, “The Housing Accelerator Fund aims to remove barriers to encourage local initiatives to build more homes, faster.”
We agree, and we think a few improvements and adjustments to the CPPS will help Waterloo hit that target.
We’ve requested a follow-up session with City staff and consultants to keep the dialogue open. The CPPS has real potential to make housing approvals faster and smarter, but it needs to be built with the end-user in mind. At Build Urban, we’re here to help shape a system that works not just for developers, but for the future of housing in Waterloo.