Comment
Theme 1: Less affordable housing
I am happy that the provincial government is concerned about the lack of affordable housing for Ontarians. However, Bill 23 has failed to act decisively to ensure affordable homes will be built where they are needed inside existing cities.
Building at the outskirts of the city means that this homeowner needs to own at least one vehicle, but likely two vehicles because they will have to drive everywhere they need to go – adding to their cost of living. This will require the taxpayers of each city to spend more on building and maintaining roads – adding to property tax increases. It will lead to poorer health outcomes since these people, especially children, will spend more time in vehicles and less time in more healthy modes of transportation, like walking- adding to health care costs.
For renters Bill 23 is stripping away or severely weakening two major tools Cities can use to address housing affordability. 'Inclusionary zoning' can require developers to include a certain portion of units that meet affordability criteria in new builds and 'rental replacement' protects tenants when a developer demolishes or converts an existing rental housing property. Both of these must stay and in fact be encouraged.
Let’s work together to find better ways to incentivize housing for homeowners and renters in areas that already have infrastructure. This will accelerate housing starts, as infrastructure adds a significant time delay, and costs, to projects.
There is a big difference between “affordable housing” and “social housing” and “supportive housing”. We need all three! We need housing that is affordable for the average person, but we also need more social housing. Very little (if any!) social housing has been built in decades, yet our population has increased. We need to catch up on the inventory of social housing. Here in London, the wait list for social housing is over 6,000, with a waitlist of 10 years! This is especially harmful for single mothers – how can youth become contributing members of society when they begin life at such a disadvantage? As a resident of Ontario, I am not proud of this.
We know that the opioid crisis is accelerating. We have more people living on the streets with mental health challenges, which only get worse the longer they remain homeless. Supportive housing provides “housing first” strategies with supports that help individuals become more stable and see a road to recovery through community.
Housing that brings communities together, with green spaces that draw children out to play. Housing that addresses the full spectrum of housing needs. That is the Ontario that I dream about.
I ask that you rescind Bill 23 and look for other ways to encourage truly affordable housing for the residents of Ontario.
Theme 2: Loss of Wetlands, Farmland and Natural Areas
I agree that we need more housing, but I strongly oppose Bill 23. Bill 23 will put housing in the wrong places! A shortage of land is not the problem. We have seen in other municipalities that they can meet housing needs from within existing urban boundaries.
By building within the existing urban boundary, we optimize investments we have already made in infrastructure, making future growth more affordable. We DO NOT need to sacrifice nature for housing.
I strongly disagree with the weakening of Conservation Authorities and limiting their ability to comment and issue permits. We need Conservative Authorities to continue to protect our precise natural areas as they are core to climate change mitigation and adaptation, flood protection, biodiversity conservation and recreation.
We have seen in the pandemic, the need for natural places for our mental health. If Bill 23 passes, it will unleash bulldozers and backhoes on vast areas of wetland, forest and other sensitive areas, currently off-limits for development. Protections such as the requirement for provincial approval for the sale of conservation land will be replaced with simply a “notice of proposed disposition”. This smacks of a lack of transparency.
Bill 23 will also prohibit Conservation Authorities from providing Municipalities with the information they need in order to start protecting conservation lands themselves when they consider land use planning approvals. Municipalities will no longer be allowed to contract with municipalities to provide reviews of planning applications. Most smaller municipalities do not have staff to do this specialized work.
This Bill would remove the power of Conservation Authorities to regulate or prohibit the destruction of woodlands, wetlands, river or stream valleys, within their jurisdiction, in almost every case. It does this through Section 7 of the Bill, which would amend s. 28 of the Conservation Authorities Act to 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, or impact on species at risk.
Theme 3: Loss of Municipal Democracy
I strongly oppose Bill 23! One of the most concerning amendments is the ability for the provincial government to impose sprawl on municipalities. The provincial government already has the ability to do this if there is ‘an adverse effect on provincial issues’ as defined by the Provincial Policy Statement. It also removes the ability for the municipality to correct these situations once notified.
Ordinary people like me will lose rights. No longer will we see notices for future development. No longer will we have the right to appeal municipal planning decisions.
Already, municipalities are experiencing how difficult it is to maintain urban infrastructure under their current limits of revenue generation. By arbitrarily reducing the amount of development charges that can be assessed to developers, it handcuffs municipalities to make development pay for itself. The reduced development charges will translate into higher taxes without any guarantee that developers won’t just pocket additional profits and continue to sell or rent at the existing market prices. Instead, we will have large, luxury housing built on the fringes of the city that is financed off the backs of lower income residents through their property tax bills.
Bill 23 needs to be revoked. Building low-density housing on the periphery of existing urban growth boundaries will lead to new infrastructure being required that will be more expensive for municipalities to maintain overall, likely resulting in property tax hikes. Especially the case in areas where new infrastructure will be built over, or near natural heritage features like wetlands, and may be prone to flooding and other disasters under climate change.
Theme 4: Climate Impacts
Given the lack of Climate leadership from the Ontario government, Cities, Regional and local governments will need to shoulder the burden of diverting new homes away farmland and natural spaces, slashing carbon emissions, and ending car-dependency.
Climate Change requires that we drive vehicles less - yet mandating that new housing happens on the outskirts of cities instead of increasing the density within the existing city boundary means that Londoners have to choose between housing or climate action. We need to make climate actions easier, not more difficult!
We need to support climate-friendly initiatives, like improved public transit. This requires more density in our existing city boundary to be cost effective and operational viable. Opening up the zoning rules to allow more “gentle density” within current single-family housing zones will allow for townhouses and low-rise walk-ups that can double the density of our cities without sprawling onto farmland.
Now more than ever, we need a Conservation Authority that will ensure the protection of homeowners from flooding. Building over wetlands not only removes this flood protection system, but obviously indicates a location that attracts water! Building up nature is an important climate solution. Instead of removing it, we need more protections - because we are not just protecting nature, we are protecting ourselves and our homes!
We know that builders are always looking for the “best and highest use” for land. Like most corporations, this means focusing efforts on making the most profit. These houses take longer to construct, use up more of our limited construction talents, and more construction materials. As we face the climate crisis, we need to understand how the housing that is presented to us limits the climate friendly options we have available to us. Building within the existing city boundary ensures that housing is more climate friendly.
Schedules 1 and 9 of Bill 23 propose amending the City of Toronto Act and the Planning Act to remove the authority of municipalities to impose conditions on new site plan approval related to sustainability and/or building exteriors in new building design. Basically means that the City will be very limited in what they can require of new development in terms of energy efficiency, infrastructure for active transportation, green infrastructure, bird friendly design, etc. Existing green standards like the Toronto Green Standard would be rendered obsolete / no longer enforceable. Would basically leave it up to developers to implement sustainability in new building designs on a purely voluntary basis. For these reasons Bill 23 needs to be revoked.
Submitted December 4, 2022 11:26 AM
Comment on
Proposed Amendments to the Greenbelt Plan
ERO number
019-6216
Comment ID
77980
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Comment status