I think that Bill 23 is very…

I think that Bill 23 is very problematic in many ways. In general, it seems to simplify the solution for needed housing by encouraging and supporting market economy development as the driving force for growth, and it reduces the power that other stakeholders have in negotiating the goals and means of these projects. Developers work largely for capitalist gain. This can put developers at odds with other values and goals in a municipal or rural area. Some of those other values include sustainability through nature conservation and the preservation of agricultural lands, so important to the continued sustainability of basic urban and rural livelihoods. The fact that developers work for economic profit over other goals is why municipalities have laws to recognize the rights of other values to thrive in cities. We do, absolutely, need housing, but this idea (in Bill 23) to meet our needs through the economic drive of developers can fail miserably. For example, most of the housing needed today is affordable housing. But developers make very little project on that, so developers favor luxury, high-end housing. This is not going to solve our housing crisis, as many of the luxury housing market serves as "investments," which sometimes are not even lived in. In this role as investment, luxury housing/condos also often serves as a second house (or more). What this Bill really fails to put upfront is the need for any new housing to be affordable housing (which could in fact be partially solved [I believe] with a more creative approach to retrofitting and renovating existing buildings [sometimes not even housing--sometimes commercial, or otherwise] into affordable housing.

Some developers find lucrative not only luxury housing--such as condos--but also tract housing. But this kind of housing is only profitable on inexpensive land--which means developers look for this land outside of the high real estate prices of urban centres and instead buy land on the periphery. But this is where a good amount of our rich agricultural land is located--which, through development, is being shrunk and pushed farther from cities. This is just not sustainable. We expect to increase the housing while diminishing the agricultural land that feeds people? This is precisely what is happening and it is a short-term solution which could lead to serious food shortages, as farmers (who actually have very little political power, unfortunately) have pointed out for decades. Some of the land on the periphery of cities has been conserved for wildlife habitats, and here again it seems that this Bill puts the power in the hands of developers over conservation authorities. This land seems to be viewed as an indulgence that we can live without, something that this Bill could allow. But we can't live without it. Birds, insects, other wildlife, wetlands, streams, and forests are not just an indulgence for weekend hikers and bird-watchers. Our entire ecosystem has been damaged and disrupted by loss of food and habitat for wildlife. Insects, for example, pollinate our plants which allows them to fruit. Wetlands provide buffers to flooding and purify our water. Plants, animals, and soils sustain us, but they will not be able to do this much longer if we destroy them. This Bill certainly seems to put nature in a precarious place, where a balance of perspectives is abandoned for (again) power in the hands of developers.

Overall, I think Bill 23 is very flawed in the imbalance of power it will produce.

Regarding Schedule 2 of Bill 23, I would support its removal and replaced instead with the following:

Allow Municipalities to continue voluntary agreements with Conservation Authorities.
Continue to allow municipalities to use existing expertise within Conservation Authorities while saving time and money for applicants.
Development subject to Planning Act authorizations should not be exempt from Conservation Authority permits, and CA regulations should not be delegated to municipalities where there is no organic capabilities.
Watersheds, and not municipal boundaries, should continue to be the scale used to assess natural hazards.
The multi-stakeholder Conservation Authority Working Group should continue working with the Province to provide solutions for shared goals and objectives.
Conservation Authority development fees should not be frozen since they are based on cost recovery.

Thank you.