Municipalities are taking too long to process site plan applications and that is costing the Ontario economy roughly $3.5 billion a year, up from roughly $300 to $900 million a year in 2018, says the Ontario Association of Architects.
A recently released 31-page report undertaken for the OAA by Altus Group reveals Ontario municipalities are taking an average of 23 months to review site plan applications, far exceeding the provincially mandated 60-day timeline.
One of five approvals needed before an application can proceed to the building permit stage, site plan review is the technical process dealing with building layout, massing, access, parking and landscaping.
鈥淭hese delays are having significant financial repercussions. For a 100-unit apartment building, site plan holdups result in additional monthly costs ranging from $230,000 to $299,000, placing further strain on developers and homeowners alike,鈥 says the report.
鈥淓very additional month a development application sits in the site plan review process represents a delay in the time the development would reach completion and come to market.鈥
The largest cost to a municipality is the lost property tax revenue. While a development application is working its way through the review process, 鈥渢he underlying land will either remain vacant or underutilized.鈥
And in a market with limited supply, additional months of site plan review time are costly to first-time homebuyers due to the inability to purchase a home and begin building equity sooner.
A 鈥渟ignificant risk鈥 to potential homeowners and office investors is higher development charges, which are passed on by the developers. Development charge bylaws expire every five years and new higher rates may be imposed by municipalities.
In a news release accompanying the study, the OAA says there鈥檚 an 鈥渦rgent need鈥 for policy reform to reduce housing-related delays and consumer related costs amidst the backdrop of provincial legislation such as Bill 212.
Among its recommendations are three key ones, two of which were already recommended by the government鈥檚 own Housing Affordability Task Force:
- Extend the site plan exemption, as defined under a section of the Planning Act, which applies to the development of 10 residential units to 30 units.
- Further support the creation of accessory residential units by amending a Planning Act regulation to increase the number of dwelling units allowed on a residential lot from three to five.
- Give 鈥渢eeth鈥 to the 60-day timeline by requiring municipalities to approve applications by the deadline. A failure to either approve or refuse an application (listing reasons why in writing) within that time period would result in the application being deemed approved.

鈥淢eaningful policy changes are necessary to ensure municipalities adhere to deadlines and build the housing supply Ontarians urgently need,鈥 says OAA president Ted Wilson.
Using building permit data, email surveys by architects and its own municipal studies, Altus conducted its research between June and December of last year. Its report was then submitted to the OAA which conducted its own analysis, says Wilson.
This is actually the third report the OAA has undertaken on site plan delay issues and is an update on those reports. Undertaken in 2013 and 2018, they were part of a process to monitor changes to the Planning Act which impact site plans.
In light of significant changes made to the site plan process with the passage of Bill 23, More Homes Built Faster Act, there was need to update the report, he says.
In series of emailed questions, Wilson was asked to elaborate on key sections of the report. One of those questions was the challenges of reviewing a large number of site plans within the 60-day period in large municipalities such as Toronto.
鈥淵es, the OAA supports a 60-day timeline for approval. We understand that a 60-day timeline may seem daunting, perhaps even for architects. But we must all learn to do better, because the timeframes to be competitive have been objectionably set by our peers.鈥
Wilson also referred to the Housing Affordability Task force report which noted that, 鈥渢he U.K. and the U.S. approve projects three times faster without sacrificing quality or safety.鈥
聽OAA advocates for these reforms through ongoing discussions with government stakeholders, he says.
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