Members of the Committee;…

ERO number

019-6163

Comment ID

69849

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Individual

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Comment

Members of the Committee; Ministers Clark and Smith, Premier Ford

I am writing too express my strong opposition to Bill 23 and associated policy proposals that weaken Ontario environmental protections and undermine public involvement of Ontario Residents in the process of land use planning and decision-making. I make the maximum contributions I can to both the provincial and federal Conservative party and just voted for Ford provincially – BUT HIS BILL WAS NEVER ARTICULATED AS PART OF A PLATFORM. IT REDUCES MIGHT RIGHTS AND I AM PISSED OFF.

• This legislation is egregious to the rights of homeowners and residents. Bill 23 revokes "third party" basic rights to appeal development proposals approved by municipal councils to the Ontario Land Tribunal. Premier Doug Ford did not campaign on reducing the rights of voters, neither did any other member of this government. By privileging developers’ and indigenous groups’ rights of appeal and eliminating those of homeowners, Residents Associations and Environmental Groups. It is wrong and must be removed.
• It reduces transparency, a cornerstone of good governance, through the Removal of requirements regarding public meetings on certain planning matters.
• It limits the power of conservation authorities (CAs) to regulate or prohibit development that negatively impacts wetlands, rivers, or streams, to provide expert review of planning applications, and to appeal planning decisions. Conservation Authorities are the knowledge box on their local ecological area. To ignore their input and expect municipalities to develop this expertise is at best naïve and at worst foolish and cynical. Please remove this aspect of the legislation.
• It amends the Ontario Wetland Evaluation System, ensuring that very few wetlands in Ontario will be deemed provincially significant and protected from development. Ontario and the world at large are on the edge of a climate crisis. Wetlands serve several important ecological functions
• It impoverishes municipal coffers by limiting the collection of development charges, parkland dedication fees, and community benefit charges (in the name of reducing housing costs, but these savings can be pocketed by the developer rather than drive down actual production costs or the ultimate cost to homeowners
• It removes basic site plan control, regardless of location, for all developments of up to 10 residential units, further restricting residents (and town councils) rights and ability to have a say in local development
• It promotes municipal development approvals, rather than mandating the construction of housing units themselves - this is likely to encourage more speculation rather than actual construction. For example, the District of Muskoka has over 5,000 draft approved housing units over half of which have been approved for over a decade and if built would more sufficiently address housing supply and affordability in the District of Muskoka. What is lacking from the current legislation is a requirement for developers to act on existing approvals within reasonable timeframes. Land speculation is a significant concern across our province where many draft plans of subdivision and other approved developments (such as zoned and site plan approved properties) are being sold and re-sold at rapidly rising prices, rather than being developed with the housing they are approved for. Changing the focus of the legislation from the development approvals process to the timely development of housing units themselves, coupled with controls surrounding land speculation would more adequately address the housing affordability and supply issue.
• It promotes the creation of a natural heritage offsetting policy and “pay to slay” fund that could lead to widespread and extremely risky trade-offs, where existing natural areas are sacrificed on the faulty premise that they can be recreated or restored elsewhere
• It practically removes of the role of seven regional municipalities (Simcoe, Durham, Halton, Peel, Niagara, Waterloo and York) in planning matters, thereby eliminating coordinated efforts to protect farmland and natural areas, determine optimal locations for development and infrastructure, and efficiently deliver municipal services.
In the face of unprecedented and accelerating biodiversity loss and the ever-worsening climate crisis, it is vital that your government do its utmost to protect the farmland, wetlands, forests, rivers and other natural areas that sustain us. As Ontario’s Housing Affordability Task Force explained in its 2022 report, we do not need to sacrifice environmental protection to address the housing crisis. That’s because “a shortage of land isn’t the cause of the problem.” (p.10) There is a vast supply of land already open for development within existing municipal settlement boundaries. And there seems to be a wide array of approvals that have not been built despite longstanding approvals to do so

Please rework this legislation!