The Waiting Game

A few weeks ago we discussed pre-consultation, the first step of the development approval process. Step Two of the approval process is application submission, circulation and review. At this point, you have submitted your development application to the municipality for review. The municipality has 30 days to determine if the application is complete.  As mentioned in the previous blog, a complete application means all required items have been included in your application submission. This includes all the items identified on the application form and everything addressed at the pre-consultation meeting (i.e., fees, concept plan or site plan, and technical studies/reports, etc).

The purpose of application circulation and review is to ensure compliance with all applicable policies and regulations that govern the municipality, thereby ensuring responsible planning and development in the interest of the public. However, the method by which it is conducted is onerous, and long delays can occur as municipalities often operate at their own pace. For this step in the process, patience is key.

What Causes Delays?

In addition to the sometimes glacial pace at which this step progresses, delays also occur when an application is not deemed complete. This is often attributed to lack of information submitted as part of the application. The applicant must ensure that all accurate information and requirements necessary to make an application complete are included.  You may be thinking, “Isn’t the point of pre-consultation to ensure all requirements are identified and explained to the applicant so they can include it as part of their application?” While that is correct, sometimes mistakes can be made and details missed. It is important to ensure that there are no errors or omissions when submitting an application, otherwise Step Two essentially starts over. You must also address any planning and policy issues that may be related to your application.

When your application is deemed complete by the municipality, a letter is sent acknowledging receipt of your complete application and the application package is circulated to different municipal department staff and commenting agencies, where it is reviewed. The following is a list of those who generally review and comment on most Planning Act Applications:

Engineering/Public   Works Department School Board
Building   Department Health Unit
Local   Conservation Authority Fire Department
Planning   Department Government Ministries with vest interest (i.e., Ministry of   Environment, Ministry of Municipal Affairs and Housing)
Economic   Development Department


The outcome of the circulation may result in a list of additional requirements to complete prior to obtaining approval. The circulation of an application to numerous commenting agencies is, again, where major delays in the process can occur.  There is no set time in which comments must be received, but based on our experience this particular part of the process can take a long time due to limited personnel and resources. Furthermore, depending on the complexity of the application and the supporting technical reports, the municipality may require that an independent peer review of the reports be undertaken, at your expense. This also delays the process. In addition, it is difficult to predict the comments/requirements that come back from the reviewers. Comments from agencies/departments may also be complicated and require additional time and money for consultants.


Application circulation and review, or what we like to refer to as the waiting game, is a necessary evil. It is a part of the development approval process that can take the most time, and can be quite frustrating. This should not deter you from future development plans, however, you should be aware that there is much more to the process than simply submitting an application. To see your development through to the end, satisfying the requirements imposed by the municipality is necessary and cannot be ignored.