I am writing to express my…

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019-6196

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72737

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I am writing to express my concerns with Bill 23.

Aside from the bill itself, I have great concern over the democratic process surrounding this Bill:
1. There is very little time for review and consultation on this wide sweeping bill (9 working days) impacting 9 provincial acts.
2. Bill 23 has been announced following a municipal election cycle and will be decided upon as new councils begin meeting, thus in reality eliminating their input. This timing comes across as unjustified, non-collaborative and in poor faith as it directly impacts the development of Cities and their comment should be welcomed with sufficient time.
3. It comes across that timing for Bill 23 has been used as a strategy to circumvent dialogue and collaboration from the most important partners at the table - municipalities.

With respect to the Bill itself, I do not support Bill 23 in its current form for some of the following reasons:
1. We are in a global climate crisis. Bill 23 is single minded, showing complete disregard for the known threats and impacts on our province due climate change.
2. Bill 23 lacks any consideration for the creation of sustainable and climate resilient cities by promoting sprawl.
3. Bill 23 puts the health and well being of residents of Ontario at risk by a) potentially removing some checks and balances offered by Ontario’s 36 Conservation Authorities who’s mandate is to protect people and property from loss of life and property due to flooding b) weakening protections of our natural heritage system including forests and wetlands by allowing offsetting , which will ultimately speed up biodiversity loss and magnify the effects of climate change ultimately negatively impacting health of our citizens.
4. Bill 23 may remove development surcharges which would impact items such as parkland dedication. Municipalities are stretched thin to develop new parkland and maintain existing as per the already abysmal per capita standards. It would seem that the removal of development surcharges would mean that the cost of development then falls on the taxpayer, quickly decreasing the affordability of home ownership of new and existing homes as already high property taxes increase.
5. Bill 23 Removes any powers cities have to build and protect affordable housing.
6. Bill 23 severely limits the building of "missing middle" housing (a variety of sizes and types of smaller, more affordable homes) on land already earmarked for growth within existing urban boundaries and instead legalizes and provokes a massive acceleration of suburban sprawl into wetlands, forests, farmland, and other areas on the rural outskirts of major population centers in Ontario’s most sensitive ecoregions.
7. Bill 23 allows the provincial government to directly impose sprawl on municipalities, without any opportunity to accommodate demand for housing and workplaces in their own way.
8. Bill 23 proposes to entirely eliminate coordinated regional planning in Ontario’s Golden Horseshoe. In Simcoe, Durham, Halton, Peel, Niagara and Waterloo and York Region, regional planning is meant to prevent “patchwork” sprawl that wastes construction resources and infrastructure, to enable regional governments to ensure that development can be serviced effectively, and to ensure that land isn’t wasted.
9. Bill 23 removes Green Standards from development expectations. We are in a climate emergency and this is the time to increase sustainability, not eliminate it.
10. Bill 23 disallows modest, purpose-built walk-up apartments or even townhomes to be built as of right on the existing lots currently being squandered on single detached McMansions.
11. Bill 23 will prohibit municipalities from accessing the expertise of Conservation Authorities (CAs) when considering development applications, forcing them to hire outside agencies to fill that role, at taxpayers' expense.
12. Bill 23 removes the power of the Conservation Authority to deny sprawl by developers and land speculators and permit to build on wetlands, river or stream valleys or to protect anything beyond managing floodwaters and erosion. It would leave vast swathes of Ontario’s most important habitats largely unprotected.
13. Bill 23 removes Conservation Authorities power to regulate and refuse permits based on “pollution or the conservation of land”, and thus remove the obligation of the Minister to consider those matters in appeals.
14. Bill 23 may compel Conservation Authorities to identify their land holdings and make them available for housing, including donated land.
15. Bill 23 will exempt any project that has received land use planning approval under the Planning Act from Conservation Authority regulations regulating water-taking, interference with rivers, creeks, streams, watercourses, and wetlands, or controlling flooding, erosion, conservation of land.

This is the time to think creatively, take an opportunity to address climate change and create a better future for generations to come by considering the impacts of decision making not only on ‘immediate economic gain’ but environment and wellbeing of the constituents you have been honoured the privilege to represent.

Thank you for your time and attention.