On behalf the Ontario…

On behalf the Ontario Federation of Agriculture (OFA), please find attached our submission with respect to ERO #019-6163 - Proposed Planning Act and City of Toronto Act Changes (Schedules 9 and 1 of Bill 23, More Homes Built Faster Act, 2022).
OFA comments to the Ministry of Municipal Affairs on Housing regarding the Changes to the Planning Act, as proposed under Bill 23, More Homes Built Faster Act, 2022. OFA applauds the provincial government for proposing to override existing municipal Official Plans and Zoning By-laws to intensify housing development within existing urban boundaries by permitting up to three additional residential units per lot. However, OFA believes the government should take a more assertive approach to end exclusionary "single detached" zoning and allow for mid- to higher densities (beyond just three units) as-of-right provincewide. OFA wants this proposal to be applied to rural and smaller-town municipalities within designated settlement areas. To clarify, OFA opposes any re-introduction of severances in the agricultural area and desires to work with the Ontario government to increase density and housing in rural Ontario in ways that do not sacrifice farmland. Regarding changes to Site Plan Control, OFA wants to see the matters that municipalities can regulate Section 41 of the Planning Act remain intact as Site Plan Control is a critical tool to help municipalities build climate-resilient, sustainably designed, transit-supportive, complete communities and ensure that any development will be compatible with its surrounding land uses. OFA is opposed to removing planning responsibilities from certain upper-tier municipalities and urges the Ontario government to regulate all upper-tier municipalities as "upper-tier municipalities with planning responsibilities." OFA worries that these changes to Ontario's land use planning system will disproportionately impact rural municipalities as they may not have the capacity (e.g., staff, budgets, or expertise) to adopt these downloaded responsibilities and keep up with the pace of policy implementation. We recommend the Ontario government financially assist municipalities in achieving any goals related to updating and implementing municipal plans, policies, and procedures that will address housing and other matters of provincial interests. OFA is opposed to removing third-party planning appeals and urges the Ontario government to look for alternative options to address the appeals backlog and streamline processes at the Ontario Land Tribunal. We maintain our stance on limiting appeals to exclude municipal decisions that conform to the PPS, provincial plan, or other, preserving the end of de novo hearings as part of the Tribunal hearing format, and limiting hearings to those based on errors in law or procedures. OFA is against the removed requirement for a public meeting to be held for a draft plan of subdivision as it diminishes opportunities for meaningful public engagement and stakeholder input to design farm-friendly development encroaching into agricultural areas. Lastly, OFA is against proposed changes to Section 23 on Ministerial Authority to amend Official Plans and, instead, would like to see the Ontario government create an independent, non-partisan Office of the Legislative Assembly to provide oversight of the municipal implementation of provincial land use plans and policies. OFA appreciates the opportunity to provide our feedback and agricultural perspectives on the proposed Planning Act changes. We look forward to working with the provincial government and our municipal counterparts to sustain our province's housing supply and communities.