For years, the reasoning was simple.
You would analyze a lot, verify its zoning. If the project did not comply with urban planning regulations, the conclusion was clear: the lot lost much of its potential.
Bill 22 changes this logic.
Not because it allows construction anywhere, but because it now gives municipalities permanent authority to authorize, under certain conditions, residential projects that deviate from their urban planning regulations.
In other words: the value of a lot no longer depends solely on what the regulation states. It also depends on a municipality’s willingness to support a project.
Here is a concrete example:
Imagine two neighboring lots. Both currently allow 24 units. A developer estimates that a 36-unit project would be necessary to make the operation profitable.
Before Bill 22, many investors would have dismissed the lot outright.
Today, the question becomes: is this municipality seeking to densify this area? Has it identified a need for affordable or family housing? If so, this lot has far greater potential than current zoning suggests.
Two municipalities with similar zoning can now make very different decisions regarding the same project.
This authority is not new in principle. PPCMOI and zoning amendment applications have existed for a long time and already allow deviations from regulations.
What changes with Bill 22 is the mechanism. A PPCMOI or zoning amendment involves a more cumbersome, more structured process, often longer and politically more exposed for a municipality that must justify a specific deviation. The authority granted by Bill 22 is more flexible: it allows a municipality to act within a framework it has defined in advance, without going through this process for each project.
Result: what sometimes took months of negotiation can now fit into a faster and more predictable process, provided the project aligns with municipal priorities.
The real question has changed
Yesterday: “Does my project comply?”
Today: “Does my project align with the Municipality’s priorities and directions so that it will use the powers granted by Bill 22?”
What this changes for developers
The best opportunity may no longer be the perfectly compliant lot. It may be the one everyone dismissed, because it precisely meets a municipality’s priorities.
This potential does not materialize automatically: conditions vary depending on the municipality’s size and vacancy rate, and the Bill provides for several exclusions. But it fundamentally changes how a lot is evaluated.
APUR’s perspective
At APUR, we do not only look at what a regulation allows today. We also analyze what could become possible, taking into account the legal framework, municipal directions, and local political reality.
Before purchasing a lot, the best decision does not always rest on current zoning, but on its true development potential.
Have you already dismissed a lot for this reason? It may be worth revisiting.