The Role of Planners in Navigating the Housing Crisis
Earlier this year, my colleague Stephen Willis highlighted key changes we can make in our professional world to help address the housing crisis.
As he noted, much of the media focuses on assigning blame, often implicating planners as a perceived cause. I acknowledge my role in this complex situation and believe it's time to dive deeper into the root causes and explore potential solutions. As planners, we are no strangers to change. However, since the onset of the pandemic, the rate and unpredictability of change have been unprecedented, often leading to what can best be described as "chaos." While planners may contribute to this chaos, we are largely reacting to a web of evolving factors driven by various stakeholders. The real culprit behind the current housing crisis is the constant shift in regulations and rules.
In such chaotic environments, planners tend to approach cautiously until we fully grasp the landscape. I call this approach "SAFE" planning—a natural response during turbulent times. Today, SAFE planning has become the default.
Fueled by regulatory flux, this persistent chaos is just as much a factor in the housing crisis as any other issue. In his recent Hamilton Spectator article, Michael Collins-Williams pointed out that Development Charges are soaring to unsustainable levels. Since the fall of 2022, we’ve grappled with legislative shifts driven by Bills 139, 23, 97, and other ongoing regulatory updates—all aiming to spark change.
From my perspective, here are a few key shifts that have contributed to the rise of SAFE planning, especially at the municipal level:
Municipal review timelines have been shortened, with potential refunds if deadlines are not met
Severances and variances are only appealable by "prescribed persons," excluding neighbors
Subdivision plans no longer require Statutory Public Meetings
Residential projects with 10 or fewer units are now exempt from Site Plan control
More stringent requirements for a Complete Application
An increase in OLT (Ontario Land Tribunal) appeals for "municipal non-decisions" when councils delay or are unable to reach a decision.
Faced with these changes, municipalities have understandably taken a more defensive stance. Pre-submission processes (such as Stage 2 Pre-Consultation) have become the norm, often prolonging the approval process. Ironically, this goes against the Ontario Government’s goal of expediting planning approvals to meet the 1.5 million new homes target over the next decade.
Instead of reducing approval timelines, these regulatory changes have unintentionally caused delays. Municipalities work to avoid triggering fee refunds, often resulting in OLT appeals for non-decisions. It’s a lose-lose situation for everyone involved.
The housing crisis, in my view, stems from a combination of parallel yet disconnected factors, including:
Rising interest rates (which are thankfully stabilizing)
High land costs
Development Charges and other municipal fees
An infrastructure deficit
Prolonged approval timelines, which can penalize those who follow the rules
SAFE planning, which stretches the decision-making process
A constantly shifting regulatory environment
Addressing this crisis will require a collective effort from developers, financial institutions, investors, municipalities, and consultants. Only by finding common ground and working collaboratively will we be able to overcome these challenges and move toward a sustainable housing solution.
-- Michael Sullivan, RPP, MCIP, OLE
