We are writing to you on…

We are writing to you on Bill-23 More Homes Built Faster Act, 2022. We recognize the importance of accelerating affordable housing in Ontario and appreciate aspects of the bill that will ensure greater attention to housing intensification, which can in turn address rising greenhouse gas emissions in the region.

We are concerned about the Act’s impacts on municipal green development standards. Specifically, it appears that this legislation includes clauses that will inadvertently make future homes more unaffordable and less efficient for Ontarians. These clauses in the legislation narrow site planning authorities to an extent that they will prevent municipalities from addressing energy efficiency and climate change in new buildings. This legislation as written would override council-approved sustainable design standards in Toronto, Ottawa, Brampton, Ajax, Whitby, Pickering, Markham, and other municipalities across Ontario. They risk causing disorder in the development process as municipalities with green development standards would have to redesign existing processes, creating uncertainty for both development departments and developers across Ontario. Ultimately, excluding energy, sustainability and climate from consideration in the planning process will leave new housing exposed to spiralling energy costs and carbon prices.

Energy efficiency compliments affordable housing

Municipal energy and sustainability standards are well established parts of the planning process that happen concurrently with other review and approvals. The process has never been known to delay development, and further, there has never been a building permit or occupancy permit denied based on municipal energy requirements. Energy efficiency rather improves affordability by ensuring quality homes with lower operating costs. New housing built to municipal green standards also qualifies for financial incentives including the CMHC Eco Plus mortgage insurance rebate, and Toronto’s Development Charge Refund Program.

What we suggest

Our recommendation is to provide a carve-out for green development standards with the proposed changes below:

Amend Bill 23 by deleting in Schedule 1 “(2) Subparagraph 2 iv of subsection 114 (5) of the Act is repealed” and delete in Schedule 9 “(2) Subparagraph 2 (d) of subsection 41 (4) of the Act is repealed”

Instead replace those two sections with the following wording in both:

(d) matters relating to sustainable design if an official plan and a by-law passed under subsection (2) that both contain provisions relating to such matters are in effect in the municipality;

This would still reduce the scope of site plan approval processes as per the bill's intent, as illustrated below in comparison to the existing wording in both acts:

(d) matters relating to exterior design, including without limitation the character, scale, appearance and design features of buildings, and their sustainable design, but only to the extent that it is a matter of exterior design, if an official plan and a by-law passed under subsection (2) that both contain provisions relating to such matters are in effect in the municipality;

Result

This will effectively allow municipalities to preserve their long-standing green development standards, allow the bill to streamline development processes, and protect important development work under way.

As a reminder, Premier Ford supported and voted in favour of the Toronto Green Standard when he was a city councillor. Green standards are broadly supported by key development industry stakeholders including constructors, developers, architects, and utilities.

Sincerely,
Bryan Purcell
Vice President, Policy and Programs
The Atmospheric Fund
bpurcell@taf.ca
416-393-6358