A planning justification report is a document that explains why a development application should be approved, based on planning policy. It shows the municipality how a proposal fits the provincial, county and local rules that apply to the property, and municipalities often request one as part of an application.
You may also see it called a planning rationale or a PJR. The name varies by municipality; the purpose is the same.
Why do municipalities ask for a planning justification report?
Municipalities ask for one because their planning decisions have to follow provincial policy and their own Official Plans. The report gives staff, council or the Committee of Adjustment an organized case to assess against those rules.
Under Ontario’s Planning Act, decisions that affect a planning matter must be consistent with the Provincial Planning Statement, 2024. A planning justification report walks through each relevant policy and explains how the proposal meets it. Where a proposal doesn’t fit neatly, it explains why the proposal still represents good planning.
Without that analysis, municipal staff have to piece it together themselves. A clear report helps decision-makers understand the merits of a proposal and supports more productive discussions with staff.
When do you need a planning justification report?
You usually need one for applications that change how land can be used or divided, and for larger or more complex proposals. Your municipality will tell you whether one is required, typically at a pre-consultation meeting before you apply.
| Application |
Planning justification report usually needed? |
| Official Plan amendment |
Yes |
| Zoning by-law amendment |
Yes |
| Plan of subdivision |
Yes |
| Condominium |
Yes |
| Minor variance |
In certain situations |
| Larger or complex proposals |
Often |
Pre-consultation is where you find out what the municipality expects, including the scope of the report and any other studies it wants.
What’s in a planning justification report?
A planning justification report typically covers the property, the proposal and a policy-by-policy analysis, and ends with a professional planning opinion. The usual sections are:
- Site and surroundings. Location, size, current use, neighbouring uses and features such as shoreline, wetlands or farmland.
- The proposal. What you want to do and which approvals you need.
- Policy analysis. How the proposal fits the Provincial Planning Statement, any applicable provincial plans, the county Official Plan, the local Official Plan and the zoning by-law.
- Supporting studies. A summary of findings from other reports, such as servicing, environmental or traffic studies.
- Conclusion. The planner’s opinion on whether the proposal represents good planning.
The length depends on the application. A report for a small rezoning is much shorter than one for an Official Plan amendment supporting a new subdivision.
Why does location in Simcoe County change what’s in the report?
Location changes the report because properties in Simcoe County can fall under several layers of policy, and each one has to be addressed.
Which Official Plans apply depends on the municipality. The County of Simcoe has 16 member municipalities. Each has its own Official Plan, and those plans must conform to the County Official Plan. Barrie and Orillia are separated cities: they aren’t governed by the County Official Plan and have their own.
The Lake Simcoe Protection Plan adds another layer. Planning decisions for land in the Lake Simcoe watershed must conform with the plan’s designated policies. The Lake Simcoe Region Conservation Authority reviews applications for their impact on the watershed.
The same proposal can therefore need a quite different report in Oro-Medonte than in Orillia. Knowing which policies apply before the report is written helps avoid it being sent back for missing analysis.
Who writes a planning justification report?
A land use planner usually writes it, because it requires professional judgment on how policy applies to a specific property. The planner reviews the policies, coordinates with any other consultants on the project, and responds to municipal comments once the application is submitted.
What affects the time and cost to prepare one:
- the type of application,
- how many policy layers apply,
- whether other studies are needed first, and
- how much revision the municipality asks for after review.
Frequently asked questions
Does a planning justification report guarantee approval?
No. It sets out the planning case, but the decision rests with council, the Committee of Adjustment or, on appeal, the Ontario Land Tribunal.
Is a planning justification report the same as a planning rationale?
Usually, yes. Municipalities use different names for the same type of document; your pre-consultation notes will say what they expect.
Do I need one for a minor variance?
Only in certain situations. Most minor variances don’t need a full report, but some municipalities ask for one on more complex requests. Confirm with your municipality before applying.
What happens if municipal staff disagree with the report?
Staff may ask for revisions, more information or changes to the proposal. The planner responds to those comments, and this back-and-forth is a normal part of most applications.
Morgan Planning & Development is a land use planning firm in Orillia, founded in 2009. Our team includes Registered Professional Planners who work with property owners, builders and developers across Barrie, Simcoe County and Muskoka. We prepare planning justification reports for rezonings, Official Plan amendments, subdivisions and more.
Not sure if your application needs one? Tell us about your property, your timeline and your budget, and we’ll walk you through what your municipality is likely to ask for. Let’s Discuss Your Project
