"Because I Said So!"

May 10, 2023


"Because I said so."   How many of us had parents who used that line?  How did it make you feel?  Frustration and injustice?


Exercising authority must always have a higher purpose.  So what was the higher purpose of the recent amendments made by the Province to Guelph's  Official Plan (OPA) 80?



In July 2022, Council unanimously approved "Shaping Guelph" our Official Plan Amendment (OPA) 80 which focused on ambitious housing targets to address the urgent need for more affordable housing, and to put our OP into alignment with provincial priorities spelled out in Bill 109 and Bill 23 to "build more homes faster."  We did everything the Minister asked us to do.


On April 18, the Minister of Municipal Affairs and Housing, the Hon. Steve Clark, sent back our OPA 80 with 18 amendments, which came into immediate effect on the day it was issued, and are NOT subject to appeal.  No rationale was given for the amendments, and no public input (or council input, or city planning staff input) was sought.


In other words, "because I said so."   


Sorry Minister, that's not good enough.  My wardmate Cathy and I are not afraid to raise our voices when things just are not right.  We need reasons, evidence and logic. The ministerial amendments do not build more housing faster.  In fact, I believe they will slow down new development, make it less affordable, and the review process was undemocratic.  For that reason, yesterday evening I brought forward a motion that Guelph City Council write a letter expressing our concerns to the Minister directly.  If we are truly "partners" in building this province, we must operate in a climate of honesty, mutual respect and open communication.  


Below is a copy of the motions and draft letter that I proposed be sent to the Hon. Steve Clark, Minister of Housing and Municipal Affairs.  Scroll down to go directly to the draft letter.



Council Planning May 9th, 2023 


WHEREAS Official Plan Amendment (OPA) 80 submitted by the City of Guelph to the Province in July 2022 represented over three years of public engagement with residents of Guelph and significant financial and human resources; 


WHEREAS the city of Guelph recognizes and appreciates the need to build more housing in our community to meet the needs of current and future residents; 


WHEREAS OPA 80 (July 2022) submitted by the City of Guelph was in compliance with population and job targets and planning regulations in Bill 109 and Bill 23, as well as in alignment with municipal master plans, including but not limited to; water supply, wastewater, stormwater, transportation and infrastructure renewal; 


 WHEREAS the City of Guelph submitted its pledge to the Province with commitments to work co-operatively to meet the provincial housing targets of 18,000 new units by 2031; 


WHEREAS the City of Guelph believes that construction of new housing is a collaborative process which includes political leadership at all levels of government, city planning staff, citizens, developers, homebuilders and community partners; 


WHERES the changes made by the Province have the potential to significantly impact the character, cultural heritage resources, urban forest, tourism, and infrastructure capital plan of the area within the Downtown Secondary Plan; 


WHEREAS the valued expertise of conservation authorities on the management of flood plains and watershed health plays an important role in risk assessment and the planning process;


WHEREAS the changes made by the Province have the potential to place a significant financial burden on current residents: 


WHEREAS our role as elected councillors as described in the Ontario Municipal Act is to act as “a representative, a policy-maker, and a steward;




Moved by Councillor Caron, seconded by Councillor Goller. that 

  1.  City Staff be directed to: 
  1. Report back through the multi-year budget process on the financial and human resource impacts in response to provincial amendments to OPA 80 and Bill 23,
  2. Notwithstanding the removal of the legislative role of the GRCA, that city planning applications continue to be circulated to the GRCA as a valued stakeholder for their input and expertise, (this clause was WITHDRAWN because GRCA is prohibited from commenting by the province),
  3. Bring forward through the multi-year budget process the necessary resources to expedite recommendations in the Cultural Heritage Action Plan (CHAP) on lands affected by the OPA 80 provincial amendments, including financial incentives for conservation/restoration of designated properties,
  4. During the next five-year OP amendment process, initiate a public consultation exercise and bring forward recommendation(s) for additional future View Corridors that may be appropriate to protect sightlines for significant municipal landmarks, including, but not limited, to the Basilica of our Lady Immaculate (ie. from Turfgrass, Starkey Hill, etc.) for inclusion in the next OPA cycle,
  5. That a plan for a future Downtown Park be referred to the 2024-2026 multi-year budget, in response to higher heights and densities in the downtown major transit station area.
  1. That the Mayor be directed to send a letter to the Hon. Steve Clark, Minister of Municipal Affairs and Housing, expressing City Council's response regarding the impact of the amendments made to Guelph OPA 80 "Shaping Guelph" and OPA review process, as outlined in the draft letter attached.
  2. And that the letter be copied to MPP Mike Schreiner and the Association of Municipalities of Ontario, Grand River Conservation Authority (GRCA),  Ontario’s Big City Mayors, Minister of Economic Development, Job Creation and Trade, Minister of Finance, Minister of Infrastructure, Minister of Transportation, Minister of Environment, Conservation and Parks.





Honourable Steve Clark 

Minister, Municipal Affairs and Housing 

Queen’s Park, 

Toronto, ON 


Dear Minister Clark: 


This letter is the collective response from the Guelph City Council to recent changes made to our growth management plan “Shaping Guelph” – Official Plan Amendment (OPA) 80 -- unanimously approved by Guelph City Council on July 11, 2023.  These comments reflect the voices we have heard in our community about the impact of the provincial amendments to OPA 80.


We acknowledge that the amendments made to our OPA 80 are now in full force and effect and are not subject to appeal. That being said, we feel that it is important for you to fully understand the impact of the changes on our community, our professional staff and the elected council at City Hall.   


We recognize and appreciate the goal of this government to build more homes, as quickly as possible, to address the real and immediate housing crisis in Ontario.  We share your commitment to rapidly increase housing supply in our city and province, and have pledged to meet the housing needs of our increased population target of 208,000 residents by 2051.  More specifically, we have also recently submitted our pledge to work collaboratively with local and inter-governmental partners to build 18,000 new housing units by 2031.



  • You asked us to bring our Official Plan policies, targets, and land use designations into compliance with Bill 109 and Bill 23. We did this with OPA 80 and our recently approved draft comprehensive zoning by-law.


  • You asked us to plan for an increased population of 208,000 residents and to prepare for more jobs and economic opportunity in our employment areas. We successfully did so in our OPA 80 submission.


  • You asked us to update our master plans for water, wastewater, stormwater, transportation, and other master plans requiring long-term financial capital investment, in order to build the necessary infrastructure and services to accommodate increased population targets.  We did this with OPA 80.


  • You asked us to plan sustainably, to increase density throughout the city, and preserve the environmental features that protect our most valuable resources.  We did that in OPA 80.


  • You asked us to do our planning work in accordance with the Ontario Planning Act and consult our residents, our industry stakeholders, our business partners, and our development community.  We did this over 18 months and their collective and balanced input is reflected in OPA 80.


On April 12, we received your amendments to our Official Plan. We recognize and appreciate the role the Ministry plays in the review process for municipal Official Plans. The Ministry has traditionally played the role of ensuring that all municipal plans are in compliance with provincial regulations. Minor edits are expected to ensure alignment, clarity and conformity. 


We are concerned that some of the amendments to Guelph’s OPA 80 went beyond that role.


We have now had an opportunity to review the 18 amendments made to our OPA 80.  We are concerned that our mutual goal to build more homes faster will now be more challenging and may have the opposite effect.  We are also concerned that


In summary, our concerns are outlined below for your consideration: 


  1. Our long-term capital financial plan and our infrastructure master plans have been updated to support densities and heights as proposed in our OPA 80 submission. With increased heights in the downtown core, we must start fresh with new plans, which will likely mean both a delay in major projects (ie. Wyndham Street infrastructure renewal) and increased costs.
  2. The expertise and experience of our Grand River Conservation Authority regarding flooding and health of the watershed is essential to future planning.  As a groundwater dependant community, source water protection and groundwater recharge is crucial to our water supply quantity and quality. The removal of the GRCA as part of the land use application process does not remove the need for due diligence needed by local planning authorities. This work still needs to be done, and those costs will now be borne by municipal planning departments through consultants or in-house staff. This will further increase costs to the municipal tax base and has the potential to slow development.
  3. The City of Guelph OPA 80 was the result of three years of community consultation and significant financial resources, and was passed unanimously by Guelph City Council. The provincial amendments that have been made do not reflect the collective engagement process (which included developers, builders and businesses) and did not have any opportunity for public response prior to being ordered into full force and effect.  This is contrary to the principles of the Ontario Planning Act and erodes public trust in government.
  4. The ERA submissions received and considered by the Ministry were almost entirely (22/24) submitted by individuals, agents, organizations or corporations advocating for private development interests in site specific properties.  Site specific amendments in the modified OPA 80 reflect many of the requests made in these submissions. Most of the submissions relate to developments that have never been before Council. The core values of land use planning include transparency, public consultation or hearings, and reasoned consideration of input from professional planning staff who were instrumental in the initial submission.
  5. In the consideration of amendments, no consultation or site visits took place with our planning staff or city officials. We value a partnership approach to land use planning and addressing our housing crisis and hope that you agree that collaboration and open communication is a more effective means to achieve our mutual goals.
  6. The reduction in employment lands hinders the City’s ability to meet our job targets and contradicts the OP stated goals of building complete communities where jobs are accessible by active or public transportation.



We bring our comments to you in the spirit of open communication and a commitment to work together to meet mutual goals to address the housing crisis.  Only when we work together can we be effective in building public trust and building a great city and a great province. 





Mayor Cam Guthrie 

on behalf of Guelph City Council  


Mike Schreiner, MPP, City of Guelph 

Association of Municipalities of Ontario  

Grand River Conservation Authority (GRCA)

Ontario’s Big City Mayors

Minister of Economic Development, Job Creation and Trade

Minister of Finance, Minister of Infrastructure

Minister of Transportation

Minister of Environment, Conservation and Parks.