Two part comment: 1) Bill…

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019-6216

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78407

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Comment

Two part comment:

1) Bill 23 needs to be repealed as it does nothing to address affordability and only serves to benefit developers. The Greenbelt lands are NOT needed to address the housing crisis - there is enough designated lands to meet Ontario's housing targets for decades. This BILD bill (this cannot have been drafted by any professional planner working for the pubic service) only serves to create more environmental degradation, and urban sprawl, reduce our ability to feed our population, and will increase taxes for already struggling, existing homeowners. The Ford government promised on several occasions that they would not open the Greenbelt for development. The false narrative they uses to justify their reversal of that promise is a slap in the face to all Ontarians. They need to reverse this terrible decision. Specific comments * are outlined below. I would like assurances that the government is taking these comments seriously and we are not just going through some "public consultation MOTIONS".

2) Should the current continue with this egregious legislation, then the following needs to be considered in the policy framework:

*at least 50% of all housing within the (current) Greenbelt lands must be affordable. If the government and developers are TRULY serious about affordability then they need to put their money where their mouths are and make it happen - 50% minimum.

*The existing taxpayers must NOT be on the hook for infrastructure associated with developer's housing projects. Development charges should NOT be reduced / frozen (except perhaps for lands already municipally serviced and where truly affordable housing is being constructed). All infrastructure costs should be born by the developers who wish to develop their lands and not by existing taxpayers.

*Parkland dedication needs to be maintained. People need green spaces for mental health because any community being built needs to be a COMPLETE community with parks and linked greenspaces / natural spaces. Active parkland should not be built into protected natural areas. We should have learned this from COVID!

*No development should be permitted within flood plains, wetlands, woodlands, erosion hazards and valleylands - ever! Woodlands and especially wetlands are needed for flood attenuation, and provide significant natural capital benefits that cannot be replicated artificially. We all have learned from COVID that these lands are also needed for mental health benefits they provide.

*Conservation authority involvement in the planning process is absolutely essential to ensure wholesome planning considerations. Municipalities do not have the detailed and specific expertise to deal with natural hazards and natural heritage protection and they do not have the science to guide them - but CAs do. Currently, conservation authorities provide valuable cost-savings to municipalities through their MOUs by undertaking natural heritage reviews for development applications on behalf of municipalities. This eliminates the need for individual municipalities to hire additional staff to carry out these reviews. It is absolutely essential to good planning to involve conservation authorities in the planning process. Reviews are consistent and thorough, and MOUs provide a level playing field for all developers and for municipalities. This service should be maintained for cost-savings to municipalities (and thus, all homeowners), consistency for developers and long-term rational planning decisions. Removal of this service will be a huge disservice to municipalities, and increase the cost of housing and ultimately result in long-term tax increases because "fulsome" planning has not been undertaken. The current government's proposal to eliminate this service flies in the face of their purported cost-savings and makes be believe that they simply have a hate-on for CAs - their is no other justification for it!

*No conservation authority lands should be designated for development. Most of these lands are hazard lands (flood plains, erosion hazards), and / or are required for environmental protection and bio-diversity. Natural areas provide a key benefit to all Ontarians for long-term climate change adaptations, natural hazard protection/mitigation, and for mental health benefits (yes, we need natural areas for rest and relaxation, and mental restoration).

*Planning authority must be maintained at the regional / county level so that there is consistency and overall coordination of planning requirements, infrastructure servicing etc. Having one single coordinating body provides streamlining and significant cost-savings as opposed to every municipality now fighting with each other over varying municipal requirements / wants / needs. Currently, many aspects of lower tier municipal official plans defer to upper tier official plan policies. We need this overall coordination!

*The Minister should absolutely not have the authority to amend official plans. This is not fair to that democratic process of official plan reviews that are undertaken at the municipal level. The Minister needs to stay in his / her own swim lane. The minister does not have the expertise that professional planners have and has no business meddling in municipal planning decisions.

* Third party appeals should definitely be permitted! This is really unfair to not allow appeals where people's lives can be so negatively impacted by development. Third parties often have valid concerns and these concerns need to be taken into account in the development process / development decisions. This should be a fair and democratic process. We should have some say in how our communities develop.

*All development should be consistent with the policies in provincial planning documents - e.g., PPS, Greenbelt Plan, Oak Ridges Moraine Conservation Plan, Growth Plan, NEDP etc. These documents went through the fulsome public consultation process and demonstrates the peoples will. The current bill (23) did not.

As an aside - It is clear that this bill hands over all authority to big developers at our expense. It is astounding and unbelievable that the Ford government did this and under such rhetoric. I have worked with the development industry for about 35 years. In that time I can honestly say that they themselves are driving up the cost of housing. When I queried a big developer in 2019 as to why they were not developing one of their sites (that I had provided final sign-off for months earlier), they responded that they were waiting for housing prices to increase so it would be more profitable for them. That came right from the proverbial horses mouth!