I am extremely concerned and…

I am extremely concerned and disheartened by the lack of consultation on this proposed legislation. The legislation should be tabled, thoroughly consulted on and revised substantially.
Ontario is facing a housing affordability crisis – more so than a supply crisis. If more homes are built, developers will not flood the market with housing to drive down prices and therefore Bill 23 will not have the stated intent. Instead, this Bill proposes to remove the ability of municipalities to fund affordable housing through development changes. This will then fall on the taxpayers and make it even less likely that true affordable housing projects are constructed. Meaningful change to address housing affordability would include changing the way that housing ownership can occur. For example, allowing individual unit ownership within an existing dwelling as occurs in Europe. While I do agree with the portion of Bill 23 that would allow additional units in single detached zones, it is notable that municipalities have approved many housing units which developers have failed to construct. Meaningful change to address housing supply would include changing funding rules to allow developers to start projects, addressing supply chain issues and the lack of available trades.
I am further concerned with the revisions to the Ontario Wetland Evaluation System and Conservation Authorities Act. Wetland protection has been adopted widely and many decisions, including urban boundary expansions, land acquisitions and disposals have been made under the assumption these lands are not developable. Wetlands are valuable natural heritage features that mitigate biodiversity loss, flooding and other impacts of climate change. Further, tough lessons have been learned by municipalities and private citizens about what happens when you construct in a wetland. Continuous flooding results in law suits, property damage and the inability to obtain insurance coverage. We know better – why would we need to repeat past mistakes?
Further, there is ample land available for building without developing our natural heritage features and wetlands. In Niagara Region the new Regional Official Plan (recently approved by the Province) included land needs assessments until 2051 and urban boundary expansions were included in the Plan accordingly. The Province included even further urban boundary expansions into the Regional Official Plan that were not required. No wetlands or natural heritage features are required for development lands in the planning horizon.
Removal of Regional planning approval and incorporation of the Regional Official Plan into Local Official Plans will result in an inefficient and uncoordinated approach to land needs, natural heritage systems, transportation and servicing. These things should be looked at regionally. Further, with respect to natural heritage features, failure to consider the overall system is unscientific. The link between access to nature and the mental and physical health of human beings is well documented. Removing our wetlands and protections of the natural heritage system will mean that the mental and physical health of Ontarians will suffer.
The removal of the public from the development application process is also concerning. No public meetings for subdivisions will mean that the public has no ability to provide meaningful input that often results in better development. No appeals to the Ontario Land Tribunal on Zoning By-law and Official Plan amendments by the public or any commenting agency including the Region and Conservation Authority removes important checks and balances from the democratic process.
Bill 23 also proposes to remove the requirement to provide building elevations as part of site plan approval applications. With intensification and redevelopment occurring in existing neighbourhoods at an unprecedented rate, urban design is key to ensuring neighbourhood character and compatibility. This in turn helps preserve the quality of life in communities for existing residents who should also be considered. Bill 23 encourages quantity over quality.
Please consult with municipalities, land use planners, residents, lenders, trades, etc. etc. rather than simply the development industry to understand the issues to bringing additional housing to market before throwing out more proposed legislation. The constant barrage of changes to the Planning Act and other legislation over the last four years has been extremely disruptive and resulted in more confusion and delays to developers than simply leaving things alone.