Commercial Real Estate Brokers serving the Greater Toronto Area and GGHA
Why Ignoring a Municipal Comprehensive Review (MCR) Could Cost You Millions
Background: What is an MCR?
In Ontario, a Municipal Comprehensive Review (MCR) is a provincially mandated process that municipalities undertake to update their Official Plans. This review ensures conformity with broader provincial policies such as the Growth Plan for the Greater Golden Horseshoe and the Provincial Policy Statement (PPS).
The MCR is not just a technical exercise—it’s a critical planning mechanism that determines:
- Where cities grow,
- Which lands are brought into the urban boundary,
- Which employment lands can be converted to mixed-use,
- And which areas are preserved as natural heritage or agricultural systems.
In short, the MCR sets the rules for what land can be developed—and when.
The Risk: A Missed Opportunity with Long-Term Consequences
Case Example: A 15-acre parcel on the edge of a designated settlement area.
In 2021, this property was not submitted for review or flagged for urban expansion during the municipality’s MCR process. As a result:
- It remained designated as agricultural, even though neighboring parcels were brought inside the urban boundary.
- It was excluded from future servicing plans for water, sewer, and roads.
- A portion was re-mapped as natural heritage, based on updated environmental data submitted by adjacent landowners.
The landowner did not participate in public meetings or submit any planning justification. By the time they attempted to re-engage in 2023, the Official Plan had already been adopted and approved by the Province—with no further appeal rights available under the Planning Act.
Natural Heritage Removal
Natural Heritage Addition
Natural Heritage Addition
In this instance, they proposed for the natural heritage to be removed as part of an MCR review, making the land developable in the future.
Natural Heritage Addition
Natural Heritage Addition
Natural Heritage Addition
In this instance, they added the area as part of a connection for natural heritage, thereby taking away the future development potential.
Lessons Learned
- Silence is costly: If you don’t participate, planners assume you’re not interested in converting or developing your land.
- Appeal rights are limited: MCR-related Official Plan amendments have restricted avenues for appeal. Missing the window could leave you locked out for decades.
- Policy moves fast: Municipalities often rely on technical studies submitted during MCRs to justify urban boundary expansions or land use conversions. If your land is not included in those reports, it’s likely to be left out.
- You need a strategy: Working with planning and real estate professionals early in the process is key to protecting your interests.
Are You at Risk?
If your land is:
- Designated agricultural or employment
- On the edge of a settlement area
- Within a future growth corridor
- Lacking municipal servicing but near infrastructure
...then you may already be affected or at risk of being overlooked in the next MCR.
Take Action Before It’s Too Late
At Land & Investment Group, we specialize in helping landowners:
- Review Official Plan and MCR documents
- Submit strategic planning justifications
- Navigate public consultations and deadlines
- Advocate for inclusion in urban boundaries or conversion frameworks
Don’t wait for the next planning window to close. Contact us today to assess your land’s position in the current or upcoming MCR process.
This narrative is provided by Arash Fatemi.