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Re: Land use planning and appeal system review

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January 10, 2014

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Hon. Linda Jeffrey
Minister of Municipal Affairs and Housing
17th Floor
777 Bay St
Toronto ON M5G 2E5

Dear Minister Jeffrey,

Thank you for this opportunity to provide our comments to the Ministry of Municipal Affairs and Housing’s Land Use Planning and Appeal System Review. Please find attached the Ontario Human Rights Commission’s written submission.

The Ministry has taken many steps toward its goals of ensuring accessible, healthy, affordable and equitable housing across Ontario, increasing social well-being, and creating complete communities. The OHRC has been pleased to provide comment and work with MMAH staff on a number of initiatives.

Community advocates and the OHRC have identified a number of ways that planning can create barriers that contribute to discrimination under the Code. In particular, many groups identified by Human Rights Code grounds are more likely to require affordable, supportive and low-cost housing, so they are disproportionately affected when such housing is restricted. The OHRC has previously provided input to the Ministry’s review of the Provincial Policy Statement, 2005 (PPS), has produced guides on human rights in municipal planning and licensing, and intervened in related cases brought by community groups.

Human rights principles and protections must be part of a comprehensive, integrated and long-term planning approach. Because human rights can be affected by land-use planning, and because of the interrelationship between human rights and the provincial housing goals, the land use planning system would benefit from a more preventative, proactive approach to preventing and removing discriminatory barriers.

This submission sets out a number of steps that the Ministry and municipalities could take to enhance municipal compliance both with the Code and with the Province’s housing and other planning goals, preventing both social hardship and costly litigation.

We would welcome the opportunity to discuss these issues further. If you or Ministry staff have any questions about the OHRC’s submission, please feel free to contact me, or Jacquelin Pegg, Inquiry Analyst, at 416-326-9863.

Yours truly,


Barbara Hall, B.A., LL.B., Ph.D. (hon.)
Chief Commissioner