Ontario Land Tribunal
Tribunal ontarien de l’aménagement du territoire
ISSUE DATE: March 03, 2023
CASE NO(S).: OLT-22-004369
PROCEEDING COMMENCED UNDER section 34(19) of the Planning Act, R.S.O. 1990, c. P. 13, as amended
Appellant: SOUTH JUNCTION TRIANGLE GROWS NEIGHBOURHOOD ASSOCIATION
Applicant: 2665100 Ontario Inc. et. al.
Subject: Zoning By-law
Description: Proposes an 18-storey mixed-use building at 1423-1437 Bloor Street West and 278 Sterling Road
Reference Number: 21 139658 STE 09 OZ
Property Address: 1423-1437 Bloor Street West and 278 Sterling Road
Municipality/UT: Toronto/Toronto
OLT Case No: OLT-22-004369
OLT Lead Case No: OLT-22-004369
OLT Case Name: 2665100 Ontario Inc. v. Toronto (City)
IN THE MATTER OF subsection 34(25) of the Planning Act, R.S.O. 1990, c. P.13, as amended, and Rule 10 of the Tribunal’s Rules of Practice and Procedure
Request by: 1423 Bloor Street West Inc., Bloor and Sterling Inc., 2726255 Ontario Inc., 2665100 Ontario Inc., 2688627 Ontario Inc., 2659339 Ontario Inc., 2659340 Ontario Inc., 2659341 Ontario Inc., and 2662548 Ontario Inc.
Request for: Motion to dismiss
Heard: January 19, 2023 by video hearing
APPEARANCES:
Parties
Counsel/Representative*
SOUTH JUNCTION TRIANGLE GROWS NEIGHBOURHOOD ASSOCIATION
Cara M. Sweeny*
City of Toronto
Derin Abimbola
1423 Bloor Street West Inc., Bloor and Sterling 2 Inc., 2726255 Ontario Inc., 2665100 Ontario Inc., 2688627 Ontario Inc., 2659339 Ontario Inc., 2659340 Ontario Inc., 2659341 Ontario Inc., and 2662548 Ontario Inc. (“Kingsett Capital”)
Adam Brown
DECISION DELIVERED BY S. BRAUN AND ORDER OF THE TRIBUNAL
INTRODUCTION
1This Decision and Order arises out of the hearing of a Motion brought by Kingsett Capital (“Kingsett”/ “Applicant”) to dismiss the present Appeal without a full hearing. For the reasons that follow, the Tribunal grants the requested relief, having found the Appeal brought by SOUTH JUNCTION TRIANGLE GROWS NEIGHBOURHOOD ASSOCIATION (“Appellant”/ “Association”) raises no apparent land use planning grounds upon which the Appeal can succeed, in whole or in part, and is not worthy of the adjudicative process.
2No previous Case Management Conference (“CMC”) occurred prior to the hearing of this Motion. Although not raised by the Parties at the Motion, the Tribunal hereby grants Party status to Kingsett, as it has a direct interest in the matter being the Applicant and owner of the lands subject to this Appeal.
3The City filed no materials and took no position on this Motion, but appeared at the hearing event to observe and, if necessary, assist the Tribunal.
BACKGROUND
4Kingsett owns the properties known municipally as 1423-1437 Bloor Street West and 278 Sterling Road (“subject property”/ “site”). The subject property is located on the south side of Bloor Street West, bounded by Sterling Road to the east, Perth Avenue to the west and a laneway to the south. It has an area of approximately 2,091 square metres and is presently occupied by several two and two-and-a-half storey buildings, containing both commercial and residential uses, including a number of residential rental units.
5Kingsett applied to the City of Toronto (“City”) for a Zoning By-law Amendment (“ZBA”) to give effect to a redevelopment proposal which contemplates an 18-storey mixed-use building consisting of 197 residential units and a total gross floor area (“GFA”) of 14,643 square metres, including 362 square metres of non-residential GFA, on the ground floor along Bloor Street West and Perth Avenue. The proposal necessitates the demolition of existing buildings which collectively contain 17 residential rental units. As such, the Applicant filed a Rental Housing Demolition application to replace those 17 rental units with units of similar sizes and bedroom types within the proposed development. The City approved a Tenant Relocation and Assistance Plan to ensure exiting tenants reserve the right to return to those replacement rental units at similar rents and are provided with financial assistance to help mitigate hardship.
6For context, there is some relevant history to the matter which the Tribunal considers worthy of note. In January 2021, approximately three months in advance of submitting the ZBA application, Kingsett held a public consultation meeting, at which it presented an initial design and discussed comments and concerns from the local community. Following the submission of the ZBA application on April 9, 2021, Community Council adopted recommendations set out in City Staff’s Preliminary Report (dated June 4, 2021) requiring Kingsett to hold a formal community consultation meeting and to address a number of identified issues. The required meeting was held on September 14, 2021, during which the public were given an opportunity to raise concerns and have questions answered.
7Some nine months into the application review process, Kingsett submitted a revised application in an effort to address concerns raised by the public, as well as input received from various commenting agencies, including but not limited to: issues of transition, podium height, separation distances, on-site open space and affordable housing. City Staff reviewed the revised proposal against the applicable planning framework and recommended approval of same in a Final Report dated June 13, 2022 (“Final Report”). The revised application was considered by Community Council at a final public hearing held on June 29, 2022 and following input from all interested parties, Community Council adopted City Staff’s recommendations at its meeting of July 19, 2022. On July 22, 2022, Toronto City Council approved the impugned ZBA.
8That decision was appealed by the Association on August 17, 2022. The Notice of Appeal refers to a supplementary letter which includes more detail and the Tribunal hereinafter refers to the Notice and supplementary letter collectively as “the Appeal”. The grounds, as set out in the Appeal, are articulated as follows:
Despite repeated meetings and calls for action both formal and informal, the City failed to respond to the multiple issues raised by SouthJTGROWS on behalf of the residents and businesses in this area. SouthJTGROWS seeks to appeal this Zoning By-Law amendment on the following grounds:
Failure to respond to the issues and concerns raised by SouthJTGROWS on behalf of the residents and businesses in the area;
Failure to provide an explanation of the effect, in any, that the written and oral submissions made during public consultations and to City Council had on the decision to permit the amendment (pursuant to s. 34(18.1) of the Planning Act);
Failure to comply with Provincial Policy Statement (2020), the Place to Grow: Growth Plan for the Greater Golden Horseshoe (2020), the City of Toronto Official Plan and the council endorsed framework for the Bloor Street Study: St. Helen’s Avenue to Perth Avenue (2021).
9The Appeal goes on to list a number of apprehensions including, but not limited to: the potential for displacement of tenants and businesses; the cumulative increase in density which would result from this and other pending development applications in the immediate area, and a concomitant adverse effect upon the ability of existing community facilities and the existing transportation network to handle such an increase. With reference to applicable planning policies, it is asserted that the proposal:
is inconsistent with the Provincial Policy Statement (“PPS”) as a result of a failure to provide affordable housing; failure to provide a mix of housing, employment, recreation, parks and open spaces; failure to minimize undesirable effects of development on air, water and other resources and failure to respond to the impacts of climate change; and
does not conform to the City’s Official Plan (“OP”) as a result of the dislocation of existing affordable rental housing and businesses; a focus upon small, unaffordable residential units rather than large, family-oriented housing; overpopulating an underserviced area; a failure to provide greenspace and to consider public safety and the impact of the development on traffic flow; and incompatibility with the character of the surrounding neighbourhood; and
fails to meet the City’s own planning framework and guidelines as articulated in the Bloor Street Study: St. Helen’s Avenue to Perth Avenue (“Bloor Street Study”), as it lacks appropriate transition to surrounding one and two-storey buildings; fails to provide affordable family-oriented units as well as sufficient parking for residents and fails to replace the amount of commercial/employment space that previously existed; will cast new net shadows over existing neighbourhoods; and exacerbate an already glaring lack of Community Services and Facilities in the area.
MOTION TO DISMISS BY THE APPLICANT
10The Applicant seeks an Order of the Tribunal dismissing the Appeal without a hearing, pursuant to s. 34(25) of the Planning Act1 (“Act”) and s. 19(1) of the Ontario Land Tribunal Act 2 (“OLTA”) on the grounds that the Appeal is frivolous, vexatious and raises no legitimate land use planning grounds worthy of the adjudicative process, but rather,
a) makes numerous statements which are patently untrue and which ignore the public record;
b) raises apprehensions cloaked in planning jargon, which are unsubstantiated by any supporting evidence or professional analysis; and
c) raises issues which are not appealable to this Tribunal.
11With reference to the Association’s three grounds of appeal (above at paragraph 8), Kingsett submitted that the first two do not constitute legitimate land use planning issues, but are instead issues which relate to the public process. It was argued that in this instance, a lengthy, consultative and iterative process was followed, during which City Staff considered concerns raised by the public in the course of evaluating the proposed development against the applicable planning framework and that all of the foregoing was duly considered in the decision to approve the ZBA.
12Kingsett submitted that the third ground of appeal also fails to raise legitimate land use planning issues but rather uses planning jargon to advance unsupported apprehensions and demonstrates a willingness to ignore the public record. For example, the Association asserts the City failed to consider their own framework for the site area (Bloor Street Study) and does not offer appropriate transition to surrounding buildings. Counsel for Kingsett drew the Tribunal’s attention to the June 13, 2022 Final Report which includes a detailed review of the proposed development against the Bloor Street Study and concludes that the proposal:
…conforms with the applicable policies of the Official Plan, particularly as it relates to development within Mixed Use Areas and the planned context outlined in the Council endorsed Planning Framework for the Bloor Street Study…
13Finally, although Appeal raises concerns with the demolition of the rental housing units and the potential for displacement of tenants, counsel for Kingsett submitted that this is not a planning issue and is not appealable to this Tribunal. He noted that, in any event, in accordance with the City of Toronto’s Official Plan, s. 667 of the Toronto Municipal Code and s. 111 of the City of Toronto Act, the appropriate and required statutory measures to apply for, and receive, the Rental Housing Demolition Application were followed, and tenants were provided with ample time and support to find appropriate accommodation, which again, is reflected in the public record.
14In support of the Motion, Kingsett relied upon the Affidavit of Peter Smith, a Registered Professional Planner, previously qualified by this Tribunal and/or its predecessors to provide opinion evidence in land use planning. In his Affidavit, Mr. Smith provides an extensive overview of the history of the application and refutes, in a comprehensive manner, the assertion that public concerns were not considered, with reference to a list of revisions made in response to public and agency comments as well as the Final Report which addresses concerns raised during public consultation. Mr. Smith also reviews and refutes each of the concerns raised in the Appeal, concluding that there are no valid land use planning issues raised which are worthy of adjudication.
15Mr. Smith points out that the ZBA was supported by extensive technical studies and approved following careful consideration by both City Staff and expert planning consultants (either retained by Kingsett or the City), whereas the grounds for the Appeal are not accompanied by any supporting evidence or professional analysis. In addition, he references correspondence from the Association, which indicates that, should the matter proceed to a hearing, it has no intention of calling any expert evidence but rather, will rely on the record before the City and evidence from residents and local business owners about the impact of the development.
16In addition to the foregoing, counsel for Kingsett pointed out that, in the face of this Motion to Dismiss, the Appellant failed to file an Affidavit, which is a procedural requirement under Rule 10.6 of the Tribunal’s Rules of Practice and Procedure (“Rules”):
The Notice of Response to Motion A responding party shall serve a notice of response that:
a. states the response to be made, including a reference to any statutory provision or Rule to be relied on;
b. lists the documentary evidence to be used at the Motion; and
c. includes an affidavit setting out a brief and clear statement of the facts upon which the responding party will rely.
17The Tribunal’s attention was also drawn to the case of Bacher v. GR (CAN) Investments et al., 2022 ONSC 2937 (Div Ct.), wherein the court noted, inter alia, that:
In choosing not to file responding affidavit evidence of his own, Mr. Bacher did so at his own peril. Reasons for an appeal are not facts, evidence or prospective evidence. Mr. Bacher did not engage any expert witnesses to respond to the land use planning opinions presented by GR (CAN) and the City. He did not provide any prospect of contrary facts or evidence that would oppose those opinions. Mr. Bacher did not specifically identify valid planning grounds upon which the Tribunal could allow the appeal. By failing to file a responding affidavit, he took a risk that the evidence that was before the Tribunal would be found to show that none of his grounds of appeal were worthy of adjudication. This is what happened in this case. Given that Mr. Bacher is not a land use planning expert himself, the Tribunal was entitled to find that the generalized claims and allegations made in his notice of appeal and response were insufficient alone to support his position that the appeal should proceed to a hearing.
18It was argued that the Association has failed to demonstrate apparent land use planning grounds worthy of adjudication, failed to put its best foot forward to demonstrate it is capable of bringing sustainable evidence to support its Appeal and, similar to the situation in Bacher, filed no Affidavit evidence to defend the present Motion. In light of the foregoing, it was submitted that the only evidence on the record supports Kingsett’s position that the Appeal should be dismissed in accordance with s. 34(25) of the Act and s. 19(1) of the OLTA.
RESPONSE TO MOTION BY THE APPELLANT
19In response to the Motion, the materials filed by the Association include: written argument and case law; excerpts of relevant policy documents; City Staff Reports in relation to other planning applications in the area of the subject site; various emails and letters from community members to the City outlining objections to/concerns with the proposed development and the planning process followed; and transcripts of the community consultation meeting held on September 14, 2021 (although the copy provided to the Tribunal lists the date as September 14, 2022) and the June 29, 2022 Community Council Meeting.
20Ms. Sweeny appeared to argue the Motion and indicated that she has been appearing for the Association on other appeals currently before the Tribunal. She further indicated that, although she is legally trained and practises as a Crown Attorney, she is relatively unfamiliar with land use planning law and the practices/procedures of the Tribunal, save and except for what she has been exposed to in her previous appearances at the Tribunal on behalf of the Association. If she has not already done so, Ms. Sweeny is directed to submit a written confirmation that she is authorized to represent the Association in this and any other matters before the Tribunal pursuant to Rule 4.1 of the Tribunal’s Rules.
21Ms. Sweeny referred the Tribunal to the oft-quoted test in East Beach Community Assn. v. Toronto (City), 1996 Carswell Ont 5740, [1996] O.M.B.D. 1890, 42 O.M.B.R. 5095 (“East Beach”), which set out the following factors to be considered when deciding whether an appeal should be dismissed without a hearing:
a. the authenticity of the reasons stated;
b. whether there are issues that would affect a decision in a hearing; and
c. whether the issues are worthy of the adjudicative process
22She described the area surrounding the subject site as a tiny neighbourhood that is presently experiencing massive change through development. It was explained that the Association (which is made up of over 200 volunteer members of the community), is committed to ensuring all development is responsible and respectful of the limits of the tiny community and, to that end, is currently involved in a number of OLT appeals. The relative size of the Association; its active involvement in this and other appeals; and the legitimate desire of the community to have its genuinely held concerns considered at a hearing were all held out to the Tribunal as being demonstrative of authenticity for the purposes of satisfying the test in East Beach (supra).
23With respect to whether there are issues that would affect a decision in a hearing and are worthy of adjudication, it was argued that if the present development proposal were to proceed, it would have a significant impact upon the neighbourhood because the area’s existing infrastructure and community services are not capable of accommodating the proposed increase in density. It was further argued that were the Association to be successful even on one seemingly minor issue, such as the appropriate location of an entrance to the development, it could potentially affect the Tribunal’s decision on the entire development, given that the relocation of that one entrance could then require the relocation of other entrances, publicly accessible spaces, and so on.
24Ms. Sweeny submitted that successful motions to dismiss usually involve an appeal of a prospective development “by one individual who is opposed, often based on petty reasons”. She held the present Appeal out as being distinguishable from the foregoing given that, in this instance, a large group of people representing the interests of area residents and businesses have raised legitimate concerns that the proposed development fails to meet Provincial and local policies and guidelines.
25On the subject of a lack of expert or objective evidence to support the Appeal, Ms. Sweeny conceded that the Association does not intend to proffer expert evidence because it does not possess the funds to do so. However she submitted, with reference to previous decisions of this Tribunal and its predecessors, that there is no requirement to lead expert evidence and that the hearing “should not be a war of experts, but rather an examination of how the City failed to weigh the evidence properly”. Given the foregoing, Ms. Sweeny indicated that is the intention of the Association to cross-examine expert witnesses and rely on the “experiential testimony of area residents who will challenge the experts’ opinions on matters such as the amount of traffic in the area”. Later, she wavered somewhat with respect to whether expert evidence would be called, noting “if we get closer to the hearing and we need to hire an expert, we will hire one, but we don’t think we need to and we don’t intend to at this stage”.
26With respect to Kingsett’s assertion that the Appeal employs planning language but raises no legitimate land use planning issues worthy of adjudication, Ms. Sweeny submitted that if the Association failed to articulate genuine land use planning grounds in the Appeal, it was because it was not known that such a degree of specificity was required at such an early stage in the process, but that this could be cured either prior to a CMC or prior to the hearing.
27Similarly, on the issue of the Association’s failure to include an Affidavit in the Response to Motion as required by the Rules, it was submitted that the Association was unaware of the filing requirements for a Motion. In relation to both of the above, it was argued that legal requirements cannot be strictly interpreted against the public because it is “patently unfair to expect those who are unfamiliar with the [Tribunal’s] process to know what to file” and, in any event, “a Tribunal hearing is not a formal court process, so it could not have been foreseen that a detailed Notice of Appeal, Affidavits and Affidavits of Service would be required”.
APPLICABLE LEGISLATION
28Section 34(25) of the Planning Act empowers the Tribunal to dismiss an appeal of a ZBA without a hearing.
Dismissal without hearing
34(25) Despite the Statutory Powers Procedure Act and subsection (24), the Tribunal may, on its own initiative or on the motion of any party, dismiss all or part of an appeal without holding a hearing if any of the following apply:
- The Tribunal is of the opinion that,
i. the reasons set out in the notice of appeal do not disclose any apparent land use planning ground upon which the Tribunal could allow all or part of the appeal,
ii. The appeal is not made in good faith or is frivolous or vexatious,
iii. The appeal is made only for the purpose of delay, or
iv. The appellant has persistently and without reasonable grounds commenced before the Tribunal proceedings that constitute an abuse of process.
29The grounds in s. 34(25) are disjunctive and the moving party need only demonstrate that one of the grounds has been satisfied. In addition to the foregoing, the Tribunal is now empowered, by virtue of s. 19(1)(c) of the relatively recently enacted OLTA, to dismiss an appeal if it is “of the opinion that the proceeding has no reasonable prospect of success”.
ANALYSIS AND FINDINGS
30When deciding whether an appeal should be dismissed without a hearing, the Tribunal’s accepted starting point is the decision in East Beach (supra), which establishes that it is insufficient for a Notice of Appeal to simply employ planning language. Rather, there must be disclosure of genuine, legitimate and authentic planning grounds worthy of the adjudicative process.
31In this instance, the Appeal includes matters which are not within the jurisdiction of the Tribunal and/or do not constitute apparent land use planning grounds, including issues with the public process and rental housing demolition. Nevertheless, the Association’s assertions that public concerns were not considered lack evidentiary foundation and are contradicted by the public record which shows, inter alia, that revisions to the proposal came about following public consultation and the Final Report responds directly to concerns raised during that process. In making its decision, the City considered the Final Report and accepted the recommendations therein to approve the ZBA.
32Although the remainder of the Appeal does employ planning language and references several Provincial and local policies and guidelines, it nevertheless amounts to a reiteration of apprehensions previously raised in public consultation and addressed in the studies and reports (including the Final Report) considered by the City in the course of making its decision to approve the ZBA.
33Unsubstantiated apprehensions do not constitute genuine, legitimate and authentic planning grounds worthy of the adjudicative process. The Tribunal acknowledges the size of the Association, the sincerity with which its members hold such apprehensions and their genuine desire to present their personal opinions on the proposed development in the context of a hearing. However, it is trite to say that repetition of an argument does not strengthen the merit thereof and fervour alone does not equate to legitimacy or authenticity. While the Association may disagree with the City’s decision, a Tribunal hearing is not a public meeting nor is it a second chance for residents to repeat, in a different forum, their personal views on a proposed development. The Tribunal’s hearing calendar is a public resource which is to be judiciously managed so as to ensure the efficient resolution of meritorious disputes.
34In order to survive a Motion to Dismiss, the grounds for appeal must anticipate the scope of the Appellant’s concerns and the presentation of contrary sustainable evidence to be called upon which the appeal can be allowed or dismissed. The Tribunal agrees that the Association has not put its best foot forward by failing to submit contrary planning or other objective evidence to defend the present Motion and failing to demonstrate the prospect of contrary sustainable evidence to be called at a hearing. Although documents included in the Association’s responding materials were repeatedly characterized by Ms. Sweeny as “evidence”, it is noted that these were not accompanied by a sworn Affidavit or sworn testimony, could not be authenticated and therefore do not constitute evidence which was properly put before the Tribunal.
35In contrast, Kingsett submitted the sworn Affidavit evidence of a Registered Professional Planner, who confirmed there are no issues with consistency and conformity and opined that the Association has not raised any legitimate land use planning issues. The Tribunal accepts the uncontested Affidavit evidence of Mr. Smith and finds Kingsett has more thoroughly addressed the relevant issues for consideration in the context of this Motion.
36While Ms. Sweeny correctly pointed out that it is not mandatory to call expert evidence at a hearing, the expectation is that some reliable and objective evidence to substantiate the grounds in the Appeal will be led in order to assist the Tribunal in deciding upon the matters before it. In this instance, it is the intention of the Appellant to cross-examine the expert evidence led by Kingsett and/or the City and to rely on the anecdotal evidence of neighbourhood residents. As such, expert evidence in support of the proposal would stand largely uncontested and the Appeal cannot be considered to have a reasonable prospect of success.
37Based on the totality of the evidence, arguments and authorities before it, the Tribunal finds the Appeal raises no legitimate land use planning grounds upon which it can succeed in whole or in part and is not worthy of the adjudicative process. Moreover, in the absence of a genuine commitment to advance contrary sustainable evidence, allowing the matter to proceed to a hearing would be an unwise use of valuable public resources and would result in the Applicant incurring unnecessary costs to defend against an appeal that, in the opinion of the Tribunal, has no reasonable prospect of success. As such, pursuant to the powers of dismissal in s. 34(25) of the Act and s. 19(1)(c) of the OLTA, the Appeal is dismissed.
38As an aside, the Tribunal notes that, in the course of arguing this motion, Ms. Sweeny asserted that if the Association failed to properly articulate legitimate land use planning grounds in the Appeal, it should be viewed as a defect which could be ameliorated if necessary, prior to a CMC or a hearing. In addition, as previously mentioned, she wavered somewhat with respect to the evidence to be relied upon in support of the Appeal, noting that the Association would consider hiring an expert closer to the hearing, if necessary. The act of filing of an Appeal signals an Appellant’s readiness to proceed to a hearing. The grounds articulated therein provide the foundation for the appeal, establishing the case which must be met by opposing parties. The filing of an appeal should not be viewed as an opportunity to stop the clock on an otherwise approved development which then allows an Appellant time to flesh out proper grounds and/or to begin the process of searching for contrary sustainable evidence to prop up the appeal.
39Ms. Sweeny also made repeated references to a lack of familiarity with the Tribunal’s Rules and procedures and the Association’s lack of funds. All Parties who appear before the Tribunal, whether or not they are represented by counsel, are required to be adequately prepared for all hearing events and to familiarize themselves with relevant Rules and legislation. While the Tribunal has repeatedly expressed an unreserved recognition of the ability of unrepresented litigants and residents’ associations to participate in its appeal processes, including those with limited financial resources, procedural fairness dictates that the Rules be consistently applied and not arbitrarily altered to compensate for an Appellant’s apparent lack of resources and/or experience.
ORDER
40UPON APPEAL to this Tribunal by SOUTH JUNCTION TRIANGLE GROWS NEIGHBOURHOOD ASSOCIATION of a decision of the City of Toronto to pass Zoning By-law No. 927-2022;
41AND UPON MOTION to this Tribunal by 1423 Bloor Street West Inc., Bloor and Sterling 2 Inc., 2726255 Ontario Inc., 2665100 Ontario Inc., 2688627 Ontario Inc., 2659339 Ontario Inc., 2659340 Ontario Inc., 2659341 Ontario Inc., and 2662548 Ontario Inc. (“Kingsett Capital”) for an Order dismissing the Appeal under subsection 34(25) of the Planning Act and/or subsection 19(1) of the Ontario Land Tribunal Act, and after the hearing of the motion,
42THE TRIBUNAL ORDERS that the Appeal by SOUTH JUNCTION TRIANGLE GROWS NEIGHBOURHOOD ASSOCIATION is dismissed.
“S. Braun”
S. BRAUN
MEMBER
Ontario Land Tribunal
Website: www.olt.gov.on.ca Telephone: 416-212-6349 Toll Free: 1-866-448-2248
The Conservation Review Board, the Environmental Review Tribunal, the Local Planning Appeal Tribunal and the Mining and Lands Tribunal are amalgamated and continued as the Ontario Land Tribunal (“Tribunal”). Any reference to the preceding tribunals or the former Ontario Municipal Board is deemed to be a reference to the Tribunal.
Footnotes
- R.S.O. 1990, c. P. 13, as amended.
- S.O. 2021, c. 4, Sched. 6

