Ontario's changes to the Site Plan Approval (SPA) process have generated a lot of attention from developers, planners, and architects. The short version: projects up to 10 residential units no longer require Site Plan Approval. The important caveat: the technical requirements that existed before those applications remain largely unchanged.
What the SPA Threshold Change Means
Under recent provincial planning amendments, residential projects that consist of up to 10 units are now exempt from the Site Plan Approval process. This is a meaningful administrative reduction — SPA has historically added 6 to 18 months of municipal review time, along with associated consulting fees and holding costs.
For small infill projects, garden suites, and low-density residential intensification, this exemption removes a significant barrier. Smaller developers working on single lots or small assemblies will benefit most.
What Did Not Change
The exemption from SPA does not exempt these projects from the underlying technical requirements that municipalities use SPA to enforce. Specifically:
- Building permits still require grading plans showing positive drainage from the site
- Stormwater management requirements still apply where the local municipality has them — many Ontario municipalities require a SWM analysis for any development that alters more than a threshold area of hard surface
- Servicing still needs to be confirmed: water, sanitary, and storm connections must be sized and confirmed before construction, and many municipalities still require a Functional Servicing Report or equivalent documentation to issue a building permit for multi-unit projects
- Conservation Authority permits are still required for development in regulated areas regardless of SPA status
What to Expect at the Building Permit Stage
Developers who assume the SPA exemption means they can proceed without engineering documentation are discovering that the building permit counter is where those requirements re-emerge. Municipalities have adapted their building permit checklist requirements to capture the technical elements that SPA previously formalized.
The practical advice: engage your engineer at the pre-application stage for any project under the new SPA threshold. Understand what the municipality requires at the building permit stage before you finalize your schedule. The timeline savings from SPA elimination can disappear if engineering documentation is not ready when the building permit is submitted.