There is a clear need for…

There is a clear need for affordable, attainable housing and rentals in Ontario, however,
I have several major concerns about the proposed amendments. I summarize my concerns associated with Bill 23 below and propose solutions to these problems.

#1 Urban green areas (i.e., parklands) are vital to communities and their residents. A review of 68 studies indicates that urban green space has positive impacts on human health with observed decreases in mortality, heart rate, and violence, and increases in attention, mood, and physical activity (Kondo et al. 2018). Scientific consensus is that exposure to nature improves cognitive functioning, emotional well-being, and other dimensions of mental health (Bratman et al. 2019). The proposed amendments reduce parkland requirements by 50% (s 42(3) and (6.0.1). Reducing parkland requirements will increase human morbidity with costs to residents’ wellbeing and increased health care costs both to the individual and Ontario. Furthermore, reducing parkland requirements will indirectly increase costs by reducing water infiltration and thus increasing flood risk at a time when climate change is increasing the frequency of severe weather precipitation events. Parkland requirements must be maintained at the current level, or the amount of parkland per dwelling increased, to maintain or improve residents’ health, wellbeing, and financial security, and to mitigate urban flood risk associated with severe weather events.

#2 I support – in principle – municipalities being able to count privately owned public spaces towards parkland requirements provided the municipality and landowner(s) enter into a conservation easement that maintains public access and green area in perpetuity. My support for this depends on the nature of the future regulation as short-term agreements and agreements or allow for the erosion of green space or public access would not serve the same functional role as urban parkland.

#3 Incenting the development of parklands is admirable but requiring municipalities to allocate or spend at least 60% of their parkland reserve is short sighted. Forcing action will prevent some municipalities from optimizing parkland with respect to residents’ needs. This will increase financial costs to residents, municipalities, and Ontario over the medium-term by reducing the effectiveness of parklands at improving residents’ health and wellbeing, and protecting private property and municipal infrastructure. Parkland spending should be incentivized through other means such as creating a provincial fund dedicated to supporting the development of urban green areas that are expected to protect public infrastructure from severe weather and serve densely populated communities.

#4 I promote increasing the supply of affordable housing, attainable housing, and rentals but do not support reducing or exempting development costs that are used to recover costs associate with water supply, wastewater, storm water, electric power, transportation, transit, police, fire, ambulance, and numerous other critical services. Reducing development costs is unsustainable and increases financial risk to residents, municipalities, and Ontario as these costs would either need to be recovered through increased property taxes (i.e., benefiting development companies at the cost of residents) or run the risk of infrastructure failure thereby increasing costs to the government. Development charges should be structured to promote affordable residential units and reduce low-density housing while maintaining municipalities’ ability to deliver critical services. I recommend subsidizing affordable residential units by increasing developing charges associated with low-density housing and other space-intensive developments to simultaneously promote affordable housing while maintaining the funds required to appropriately manage developments.

#5 I support the “additional residential unit framework” as a means of gentle intensification but, as above, do not believe that they should be exempt from development charges or parkland dedication. Gentle density could have dramatic impacts on transportation, water, sewer, and other infrastructure and will increase municipalities burden related to both infrastructure and building permits. As a result, development charges must be maintained for gentle intensification.

Resources

Bratman et al. 2019. Nature and mental health: An ecosystem service perspective. Science Advances 5: p.eaax0903.

Kondo et al. 2018. Urban green space and its impact on human health. International Journal of Environmental Research and Public Health 15: 445.