Site plan approval (SPA) is where many investors get their first real taste of the planning process — and where many timelines fall apart. It’s not a building permit, and it’s not zoning. It’s a separate approval that controls how your building sits on the site and how the site works.
When Do You Need Site Plan Approval?
Site plan control applies to areas a municipality designates in its site plan control by-law. For residential projects, the key rules are:
- 10 residential units or fewer: generally exempt since Bill 23 (2022) — unless any part of the land is within 120 m of a shoreline or 300 m of a railway line.
- 11 or more units: generally subject to site plan control.
- Mixed-use and commercial projects: often subject, depending on the municipality’s by-law.
Always confirm with the municipality. Their by-law and the provincial rules both apply.
What Site Plan Reviews (And What It Doesn’t)
SPA looks at the site and how it functions: building location, access and driveways, parking and loading, grading and drainage, stormwater management, servicing, garbage storage and collection, fire access, lighting, landscaping and walkways.
Since Bill 23, municipalities have more limited power to control the exterior design and architectural details of residential buildings through site plan. In practice, expect fewer architectural style comments — but just as much engineering scrutiny.
Your Typical Site Plan Team
| Consultant | What they do |
|---|---|
| Architect / designer (that’s us) | Site plan, building plans and elevations, coordinates the team |
| Planner | Planning strategy and any planning reports (more common if zoning relief is also needed) |
| Civil engineer | Grading, servicing, stormwater management, functional servicing report |
| Ontario Land Surveyor | Boundary and topographic survey |
| Landscape architect | Landscape plan, tree planting, buffering |
| Arborist | Tree inventory and preservation plan |
| Traffic / transportation engineer | Traffic impact or parking study, where required |
| Geotechnical engineer | Soils report |
| Environmental consultant | Phase One ESA (and Phase Two, if needed) |
| Noise / acoustic consultant | Noise study near major roads, rail or industry |
| Electrical / lighting | Photometric plan, where required |
Not every project needs every consultant. The municipality’s checklist decides — which is why a good pre-consultation matters.
The Process, Step by Step
- Pre-consultation (optional, but recommended). Since Bill 185 (2024), municipalities can no longer make pre-consultation mandatory. We still recommend it: it tells you exactly which studies the City expects, so your application isn’t deemed incomplete.
- Prepare the submission. Drawings, reports and studies from the full team. Typically 2 to 4 months.
- Formal application and completeness review. The City confirms everything required is included.
- Circulation. The application goes to planning, engineering, transportation, forestry, fire, waste, the conservation authority and others.
- First comments. Often 6 to 12 weeks after submission.
- Resubmissions. Two or three rounds are common, each taking 4 to 8 weeks between our revisions and the City’s re-review.
- Approval and site plan agreement. Many municipalities require a site plan agreement registered on title.
- Securities and fees. Letters of credit or cash securities for site works, plus fees, are usually required before final approval.
- Building permit. Many municipalities won’t issue a building permit until site plan approval is in place.
The Realistic Timeline
The Planning Act gives municipalities 60 days to decide on a complete site plan application. If they don’t, the applicant can appeal to the Ontario Land Tribunal.
In practice, appeals for non-decision are rarely the fastest route. And since Bill 185 repealed the fee refund rules, there’s less financial pressure on municipalities to hit that 60-day mark.
Realistic expectation: 6 to 18 months from pre-consultation to approval, depending on the municipality, the site and how complete your first submission is.
What REIs Get Wrong
- Not budgeting for the full consultant team and securities
- Skipping pre-consultation and getting an incomplete application notice
- Waiting on one consultant who holds up the whole resubmission
- Assuming site plan approval means the building permit is approved too
- Designing an 11th unit without realizing it triggers site plan control
How Rojas Empire of Design Helps
We start small, so you don’t spend big before you know. Before you hire anyone else, we prepare schematic drawings — a site plan, floor plans and elevations — and take them to a pre-consultation meeting with the City. The goal is to find out exactly what the City is looking for and what its main concerns are with your proposal.
That meeting produces the City’s list of required studies and its key concerns. If that list is manageable, you move forward with a clear scope for every consultant. If it’s too much — too many studies, too many costs, too much risk — you can walk away, having only paid for the architectural side instead of a full consultant team.
From there, we help with:
- Feasibility first — is SPA needed, and is there a smarter path (like staying at 10 units)?
- Consultant team assembly and coordination, once you decide to proceed, with a full fee and scope breakdown upfront.
- Complete, coordinated submissions to reduce resubmission rounds.
- Managing City comments across disciplines until approval.
- A seamless transition from site plan approval into the building permit.
Final Thoughts
Site plan approval is manageable when you go in with the right team, a complete package and realistic expectations. It becomes painful when you go in expecting 60 days.
Thinking about a project that may need site plan approval? Send us the address and unit count. We’ll tell you whether it’s required and what your team should look like.
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