I am writing on behalf of…

I am writing on behalf of the Township of Amaranth in order to outline our specific concerns with the More Homes Built Faster Act, 2022. Our specific concerns pertain to proposed changes to the following legislation: Planning Act; Development Charges Act, 1997; and Conservation Authorities Act.

As it relates to the Planning Act, our first concern arises from the proposed change to additional residential units. Specifically, there are no minimum requirements for septic systems for each additional residential unit. Similar to minimum parking space requirements for each additional residential unit, additional residential units should be prohibited unless adequate sewage services can be provided in a sustainable manner as determined by a Chief Building Official.

Our second concern arises from the proposed change to parkland reserve allocations. Specifically, the requirement that municipalities must allocate at least 60% of parkland reserves at the beginning of each year. As detailed in Section 2 of the Municipal Act, if municipalities are created by the Province of Ontario to be responsible and accountable governments with respect to matters within their jurisdiction, then decisions on how to allocate parkland reserves should be left to individual municipalities.

Our third concern arises from the proposed change to subdivision application public meetings. Specifically, the new requirement that public meetings not be held for each subdivision application. As detailed in Section 1.1 of the Planning Act, if one of the purposes of the Act is to provide for open, accessible, timely and efficient planning processes, then not having public meetings contradicts this purpose.

As it relates to the Development Charges Act, our first concern arises from the proposed change to development charges exemptions. Specifically, development charges for affordable residential units, non-profit housing developments and inclusionary zoning residential units are reduced or eliminated. As detailed in Section 2(1) of the Development Charges Act, if the purpose of development charges is to pay for increased capital costs required because of increased needs for services arising from development, then these development charges should not be reduced or eliminated as development should pay for development. Please note that the Township views affordable residential units, non-profit housing developments and inclusionary zoning residential units as worthwhile endeavors. It is not the endeavors that are the issue rather it is the reduction or elimination of the development charges without them being replaced that is the issue.

Our second concern arises from the proposed change to development charges reserve allocations. Specifically, the requirement that municipalities allocate at least 60% of development charges reserves at the beginning of each year. As detailed in Section 2 of the Municipal Act, if municipalities are created by the Province of Ontario to be responsible and accountable governments with respect to matters within their jurisdiction, then decisions on how to allocate development charges reserves should be left to individual municipalities.

As it relates to the Conservation Authorities Act, our first concern arises from the proposed change to development application reviews. Specifically, conservation authorities may not review development applications under a memorandum of understanding. As detailed in Section 2 of the Municipal Act, if municipalities are created by the Province of Ontario to be responsible and accountable governments with respect to matters within their jurisdiction, then decisions on purchased services should be left to individual municipalities. Conservation authorities have expertise with respect to natural heritage systems and if municipalities choose to use this expertise, then they should be allowed to make this decision for themselves.

Our second concern arises from the proposed change to development permit considerations. Specifically, control of pollution and conservation of land factors are no longer to be considered by conservation authorities when making decisions on development permits. As detailed in Section 0.1 of the Conservation Authorities Act, if the purpose of the Act is to provide for the organization and delivery of programs and services that further the conservation, restoration, development and management of natural resources in watersheds, then control of pollution and conservation of land should be considered when making decisions on development permits. Not using control of pollution and conservation of land as factors contradicts the purpose of the Conservation Authorities Act.

We look forward to your timely response to these concerns. Please contact the undersigned if you have any questions or comments about this matter.

Yours truly,
James Johnstone, Township Planner