As a citizen of Ontario I am…

As a citizen of Ontario I am deeply troubled by Bill 23 and the proposed amendments to the Greenbelt Plan. Many of the Ontario government’s actions can only be described as undemocratic, as there is no mandate for these sweeping reforms. The province is dismissive of stakeholders, municipalities, ENGO’s and NGO’s that express concern or opposition. This head in the sand behaviour reflects an unwillingness to acknowledge the magnitude of public concern and to fairly listen to all experts and stakeholders.

With regards to Bill 23 I offer the following comments and recommendations:
1. Slow down: Do not pass Bill 23 or support the Proposed Amendments to the Greenbelt Plan until proper consultation is completed with affected stakeholders, key interest groups including Association of Municipalities of Ontario (AMO), the Ontario Chamber of Commerce, Conservation Authorities (CA), and affordable housing advocates. The housing rationale used for these measures must be demonstrated to be sound; to date the measures proposed are not supported by planners, municipalities or housing advocates.
2. Allow Conservation Authorities to maintain their current role in permitting in regulated areas, allow them to conserve land, reduce pollution via land use planning review and permits. Don’t further consider land owned by CA’s for housing development. Uphold the purpose and rationale for CA’s, namely preservation, conservation and stewardship of land with natural hazard risks.
3. Abandon the abolition of Regional Planning: There are issues with regional planning, but the only support for the proposal to eliminate the important coordinating role of regional government, particularly for infrastructure planning, is from land speculators and developers. If there’s a rationale for the government’s proposal that serves the public interest, please provide an explanation of this.
4. Do not encroach on the Greenbelt and Oak Ridges Moraine: There’s enough land to build the housing that Ontario needs for 30 years. Even BILD has said they don’t need Greenbelt. Stop unjustifiable Greenbelt land removals. The government should be doing everything in their power to protect the prime agricultural lands of the Greenbelt. Protection of Greenbelt lands builds Ontario’s resiliency against unstable globalized food supply systems , and the increasing impacts of climate change.
5. Protect Wetlands, Natural Heritage, Species at Risk and Ontario from the inevitable risks of Climate Change. Do not change the OWES wetland evaluation system. Maintain strong prohibitions on alteration of landscape in Ontario’s Natural Heritage System (NHS) and its features in the Provincial Policy Statement (PPS). Do not allow offsets, trades, or “compensation” agreements. Capitalize on the free service provided via natural asset management instead of infrastructure and capital intensive engineered solutions that are ultimately ineffective against the increasing impacts of climate change.
6. Allow Members of the Public and CA to appeal Official Plan, Zoning Bylaw Amendments and Sprawl Proposals to the Ontario Lands Tribunal. Make the playing field level once more by providing the same rights to both project proponents and community players interested in challenging and/or improving planning proposals/Official Plans. Consider threshold levels to reduce appeals abusing the process.
7. Do not override Official Plans. For better or worse they are far more democratic than the proposals flowing out of the government of Ontario at this time.

PROVINCIAL POLICY IN DISARRAY, DISREGARDED, DISRESPECTED
Recommendation: Provide evidence-based rationale for policy changes & clean up your own house first
The changes, even simple administrative matters, do not appear well thought out. It seems implausible that the Ministry of Municipal Affairs and Housing (the Ministry) has or will have the capacity, staff and administrative processes in place to be the approval authority for lower tier Official Plans and Amendments. The Ministry hasn’t provided basic data on whether the Growth Plan is effective or ineffective, if municipalities are meeting greenfield density targets or have adequate housing supply approved in the pipe-line. This Ontario government has failed to provide reasonable evidence supported by data, facts or figures province-wide to justify such broad sweeping legislative changes.
Provincial ministries with conservation, preservation, endangered species protection remain critically underfunded. The province has failed to address recommendations and shortcomings brought forward by the former Environmental Commissioner and now the Auditor General. Illegal land use is rampant on prime agricultural land, trees are being felled illegally. Our bylaws and penalties are ineffective, the province is absent or worse giving approvals in the absence of approved zoning and then expecting by-law officers to enforce nuisance and traffic impacts. The changes to CA’s will leave Ontario’s Natural Heritage vulnerable and exposed because there will be no publicly funded institutions with sufficient resources left to speak, and act to protect our natural heritage. It is reckless to make these changes in the absence of any real and meaningful attempts to address the already identified shortcomings that have forced CA’s to take on the very roles the province seeks to or has already eliminated.

MASSIVE FINANCIAL IMPLICATIONS FOR MUNICIPALITIES
Recommendation: Consult with AMO and municipalities to ensure these changes do not bankrupt municipalities and do not affect the levels of services and park land that Ontarians have come to expect.
Municipal staff are warning of staggering losses as a result of reduction in development fees; the City of Markham estimates that property taxes would have to increase by 50 to 80 percent just to maintain existing services. It is foolish to believe that smaller municipalities with less resources will have or be able to obtain specialized staff with the expertise to adhere to specialized specific provincial policy plans and the knowledge to protect residents from natural hazards. Contracting out these services opens up a whole other set of administrative, financial and accountability issues that again do not appear well thought out. Reducing parkland requirements is the exact opposite of what we learn that we need most for our communities during the pandemic.

CONSERVATION AUTHORITIES
Recommendation: Allow Conservation Authorities to maintain their current role in permitting in regulated areas and allow them to conserve land and reduce pollution via land use planning review and permits.
Ontario residents trust CA’s because they have demonstrated they have the staff, expertise and resources to comment on complex planning applications with environmental and natural hazard risks. Further, they have been responsible stewards for the conservation and preservation of the lands entrusted to them. To direct CA’s to put a list of land together suitable for development is nonsensical. Land comes into their ownership because it has been donated with expectations of having conservation status in perpetuity, or the lands contain environmentally significant features and natural hazards that require protection.

CONCLUSION
If Bill 23 is passed in its current form then the Ontario government will have failed to listen to professionals, subject matter experts, and ignored science and established best practices. It will have failed to protect land that will be critically important to reducing the impacts and adapting to climate change - CA regulated land, the Greenbelt and Oak Ridges Moraine. They will have failed to provide the type and diversity of housing needed by Ontario’s most vulnerable communities. The implications of Bill 23 place unacceptable fiscal and legal risk upon the Government of Ontario, municipalities and taxpayers - it is short-sighted and reckless.
We urge you to slow down. Do not pass Bill 23 or the proposed Greenbelt removals . Consult properly, and do the job that only the government can do: protect the public interest.