I am commenting on the…

I am commenting on the proposed Ontario Bill 23 Built Homes Faster as a profoundly concerned citizen of Ontario.

Note my concerns and comments also apply to the proposed adjustments to the Greenbelt Area boundary and Oak Ridges Moraine Conservation Plan regulations as described under ERO 019-6217 and ERO 019-218 as well as amendments to the Conservation Authorities Act among others.

I am opposed to Bill 23 because it will cause harm to the health and well-being of Ontario’s environment, economy and society. If passed, the implementation of Bill 23 will result (in the short and long-term) in the:
• loss or degradation of wetlands, forests, meadows, conservation lands and farmlands;
• degraded surface and groundwater quality; reduced and less reliable supply of drinking water; reduced and less reliable supply of irrigation water for farming and water for manufacturing;
• greater risk of more frequent and severe flooding; degradation of local and regional air quality;
• loss of economic prosperity to farmers and rural farming communities; increased food insecurity;
• loss of tourism dollars as Ontario’s much-visited natural landscapes are transformed; loss of economic productivity;
• decreased physical and mental health outcomes for Ontarians from loss of natural spaces that are accessible (e.g., free and/or local) in areas where population pressure is greatest;
• significant increases to the cost to municipalities to service new developments in greenfields; and,
• significant increases in costs to municipal and the provincial government to address the exacerbated effects of climatic events due to loss of natural spaces and ill-planned development (floods, urban/suburban heat islands, pests etc.).

This list is not exhaustive.

Please note that my opposition to Bill 23 should not be construed to mean that I am opposed to development. I am not, but I am opposed to short-sighted and poorly planned development that will be counterproductive to its stated goal of building more affordable homes for as many people as possible.

Below I offer more detail on some of how the implementation of Bill 23 will result in negative impacts to Ontario’s environment, and a bit of detail about impacts on human health and the economy.

Impacts on Wetlands, Forests, Meadows, Natural Spaces and Conservation Lands

Bill 23 will result in the loss or degradation of wetlands, forests, meadows, conservation lands and farmlands; degraded surface and groundwater quality; reduced and less reliable supply of drinking water; reduced and less reliable supply of irrigation water for farming and water for manufacturing; greater risk of more frequent and severe flooding; and degradation of local and regional air quality because:

Proposed changes to the Conservation Authorities Act (CA Act) under Bill 23 would severely limit/prohibit the ability of Conservation Authorities (CA) to protect Ontario’s natural heritage and farmland. In part this is because under Bill 23:
• The terms "conservation of land" and "pollution" would be removed from the CA act and the terms "unstable soils and bedrock" would be added;
• CAs commenting and review as part of the planning and review process would focus only on natural hazards with no ability to provide comment on natural heritage ecology, wetlands and biodiversity;
• CAs would be prohibited from partnering with municipalities and providing their expertise with regard to planning applications;
• Municipalities would be forced to find outside agencies to advise them of the risks associated with a development application;
• The ability of CAs to conduct their work would be significantly impeded due to the proposed changes to allow the minister to freeze planning and permitting fees at current levels, preventing recuperation of funds from costs associated with CA's involvement in development applications;
• CAs would be required to identify lands which could support housing developments and give them up for development, including donated land; and,
• The interconnectedness of watersheds, wetlands, and natural areas could be ignored. This means that wetlands would no longer be assessed as “complexes” (individual wetlands spread throughout an area) which increases the risk of developers applying to offset provincially significant wetlands because they would be downgraded due to changing definitions.
o For those not familiar with the ecological term of a wetland complex, the Beverly Swamp in rural Hamilton, the largest remaining wetland in southern Ontario, is an excellent example of a provincially significant wetland complex https://caroliniancanada.ca/legacy/CarolinianSites_BeverlySwamp.htm

Why We Should Care about Loss of Wetlands, Forests, Meadows and other Natural Spaces?

Why is the preservation of natural heritage features and systems critical, especially in a rapidly urbanizing region like southern Ontario?

The value (monetizable and otherwise) of natural heritage features and systems cannot be overstated. Wetlands in particular have enormous value “because they function as the downstream receivers of water and waste from both natural and human sources. They stabilize water supplies, thus mitigating both floods and drought. They have been found to cleanse polluted waters, protect shorelines, and recharge groundwater aquifers. Wetlands also have been called nature’s supermarkets because of the extensive food chain and rich biodiversity that they support. They play major roles in the landscape by providing unique habitats for a wide variety of flora and fauna” https://www.tandfonline.com/doi/full/10.1080/21513732.2015.1006250

Wetlands and the services they provide are particularly important in southern Ontario with its growing population and concomitant intense development pressure. However, most of Ontario’s original wetlands (85%) have been lost, and the pace of loss of the remaining wetlands is increasing:
• Between 2011–2015, a total of 7,303 ha of wetlands were lost. This total is higher than the previous 6,152 ha lost between 2000 and 2011. This loss represents 0.7% of remaining wetland area in southern Ontario, a value slightly greater than the 2000–2011 assessment which represented a loss of 0.6% of remaining wetlands.
• The rate of wetland loss between 2011–2015 (1,825 ha per year) is considerably higher than the rate of wetland loss previously assessed for the decade between 2000–2011 (615 ha per year). https://sobr.ca/indicator/loss-of-wetlands/

Since land conversion is the primary cause of wetland loss in southern Ontario, policies and other actions by the provincial government should focus on the preservation of remaining wetlands, instead of greater removal of them as would result from implementation of Bill 23.

Forests are also key natural heritage systems. Forest floors, their uneven surfaces (hummocks and depressions) and soils thick with rich biological activity, are very effective at filtering rainwater and storm water runoff, thereby preventing floods, and allowing for the percolation of water to groundwater that recharges streams and rivers. As water filters through soils, contaminants and excess nutrients from adjacent urban/suburban areas and agriculture are removed https://www.sciencedirect.com/science/article/abs/pii/S2212428417301056

Maintaining sufficient forest cover to support wildlife such as bats and birds also provides economic benefits such as pest control https://phys.org/news/2022-11-young-trees-insect-bugs.html as well as tourism https://www.todocanada.ca/50-nature-attractions-hotspots-in-and-around-…
Without wetlands and forests to trap, filter and store water, there is an increased risk of damaging and expensive flash flooding, and a reduction in the quantity and quality of groundwater for private and municipal drinking water wells, as well as water needed to irrigate high value crops like vegetables https://www.sciencedirect.com/science/article/abs/pii/S2212428417301056 .

Headwater Streams – So Valuable and So Threatened under Bill 23

It is clear from the Overview Map, provided as supporting material under this ERO posting, that much of the land (8 of the 11 sections) proposed to be redesignated under or removed from the Greenbelt Plan/Oak Ridges Moraine Conservation Plan appears to be in headwater geographies (e.g., sections 1, 2, 3, 4, 5, 6, 7 and 8).

Headwaters are the source and upper branches of streams and rivers. Headwater streams are the smallest branches (that may or may not flow all year around) that join up with other small branches to form larger branches that become the main reach of a stream or river as it courses its way to a lake or sea. As with forests and wetlands, the ecosystem functions that headwater streams provides to humans include flood control, control of soil and sediment erosion, reduction of excess nutrient delivery to lakes, and, because of their very high habitat diversity, they provide valuable habitat for aquatic organisms such as amphibians, fish and invertebrates that are the key food source for recreational and commercial fisheries https://academic.oup.com/bioscience/article/55/3/196/249658 .

Headwater streams are very small and as a result they are heavily influenced by the quality of the terrestrial land that surrounds them. Because of this, they are very sensitive to disturbance such as urban development with its introduction of paved surfaces, erosion, flooding and introduction of chemical pollution. The benefits, environmental, economic and social, of protecting and wisely managing headwaters are well-established as these extension publications from large land grant universities in the United States evidence https://lgpress.clemson.edu/publication/the-importance-of-headwater-str… and https://hgic.clemson.edu/factsheet/protecting-headwater-streams/ .

Fragmentation of Natural Spaces

Bill 23 will result in the development of greenfields that currently support natural ecosystems (wetlands, forests, meadows etc.) in a fragmented and randomized way radiating out in a leapfrogged, unconnected fashion from urban centres.

Removing natural habitat in a location by new development has an impact on the larger ecosystems that is more than just that of removing one small woodlot, or one small wetland.

Here is an analogy: when a quilt has one patch removed, it no longer is as effective at keeping a person warm. When enough patches have been removed, the quilt ceases to be able to keep a person warm at all. The same applies for the loss of natural spaces. When a small woodlot or small wetland in an ecosystem complex is developed, the loss of habitat and introduction of chemical, light and noise pollution by the development means that the larger ecosystem no longer functions as well. And when enough areas (disconnected or otherwise) are removed (“death by a thousand cuts”), the ability of the entire ecosystem to function properly is badly damaged https://www.science.org/doi/10.1126/sciadv.1500052 . The whole is greater than the sum of its parts.

This is one of the many reasons why the proposal under Bill 23 to “replace” lost Greenbelt lands with other protected areas, hundreds of km away in some cases, (some of which are already protected under other legislation, meaning there would be a net loss of habitat) will not ameliorate the impacts of the removal of greenspaces in the Greenbelt.

Food and Health for Ontarians

Farmland in southern Ontario inside and adjacent to the Greenbelt is some of the best farmland in both Ontario and in Canada http://omafra.gov.on.ca/english/landuse/agsys.jpg .

Unfortunately, much of this most productive farmland has already been lost forever to urban sprawl in Peel, York, Durham, Halton, Hamilton and Niagara, amongst other areas. This farmland, with its rich soil and mild temperatures, supports Ontario's most valuable crops, and provides good income for Ontario farm families and communities. These high value crops include vegetables and fruits, which in many cases can only be grown in only very few places in Ontario. In our world of supply chain disruptions and food insecurity, the ability to grow and sell local food is invaluable.

Natural heritage systems are also critical for the physical and mental health of Ontario residents.

Developing lands in the Greenbelt will introduce roads that will result in greater number of cars on the road for longer times (the opposite of what is needed to ameliorate climate change). Air quality is a significant health risk in the GTHA, mostly due to commercial and personal vehicle emissions. Poor air quality has both a significant human health and economic cost to Ontario https://clearingtheair.ca/ .

The majority of people who live in urban and suburban southern Ontario do not have the means to own or access cottages or recreational areas outside of their cities. As a result, the existence of natural heritage areas in close proximity to large urban populations is critical for the physical and mental well-being of people. Witness the heavy use of conservation areas in Hamilton and Halton during the 2020 COVID-19 pandemic lockdown: https://www.thespec.com/opinion/contributors/2020/11/07/pandemic-bringi… and https://www.theglobeandmail.com/life/health-and-fitness/article-pandemi… .

Developing natural spaces will have detrimental effects on Ontarians trying to visit them for passive recreation (e.g., hiking), and at the same time will significantly increase the pressure on remaining protected parks and public natural places https://www.thespec.com/local-haldimand/news/2022/06/16/binbrook-conser… .

Strategic, long-term development planning that benefits Ontarians now and for future generations is what is needed, rather than short-term goals with questionable benefits.

As mentioned before, I am not against development; more affordable and livable housing is needed in southern Ontario. This need will only increase due increasing population pressure from natural growth and immigration. However, what is required is intelligent, far-sighted and systems-approach to planning for Ontario that integrates long-term environmental and economic sustainability.

Such “smart growth” is not as straightforward as business-as-usual (or hyper-business-as-usual as represented by Bill 23) but it would result in more prosperous, equitable and livable communities. To modify Freilich’s comment (1999, as quoted in https://cdnsciencepub.com/doi/10.1139/l04-116) “In combating sprawl, it is not necessary to give up the [Canadian] dream; it must only be slightly revised”.

Here is an example that is a small move towards a smart growth approach: Bill 23 proposes that under some conditions, developers’ fees will be waived or reduced to build more “affordable” homes in the Greenbelt. However, rather than waiving development fees on easy-to-build lands like farmland (where people would need to own at least one car to live and work), an alternative proposal would be to waive or reduce fees to develop city brownfields. Brownfields are more expensive to develop because the land often has to be remediated (which is why green and whitefields are more attractive to developers).

Developing on lands inside existing urban boundaries would mean more homes built better and affordable. By that I mean homes (a mixture of single dwelling, townhouse, low rise and high rise) are built where work, school, shopping and play are walkable and already linked up to expensive infrastructure like water and sewage (and roads) https://cdnsciencepub.com/doi/10.1139/l04-116 .
Bill 23 as currently proposed will result in the uncoordinated development of housing that is not accessible (physically or financially) to low- and middle-income households, thereby further increasing the disparity of standard of living among Ontarians.

Development in green and whitefields are also not economically sustainable for municipalities. Development fees and property taxes from the newly built homes do not cover the lifecycle costs of services (water, sewer, roads, etc.), which must then be paid for by ongoing tax increasing taxes to all municipal residents. In contrast, development in urban areas already serviced by this expensive infrastructure is more economically sustainable and in fact can be a source of municipal income https://www.cbc.ca/news/canada/ottawa/urban-expansion-costs-menard-memo…

There are current examples of attempts at sustainable long-term development planning in Ontario. The city of Hamilton and the region of Halton recently submitted Official Plans to the province that rejected the expansion of urban boundaries for greenfield growth in favour of creating sufficient homes to meet anticipated population growth by developing available land within existing urban boundaries:
• Hamilton https://www.hamilton.ca/build-invest-grow/planning-development/official… and https://www.hamilton.ca/build-invest-grow/planning-development/official…
• Halton https://www.halton.ca/The-Region/Regional-Planning/Regional-Official-Pl…-(ROPR)

However under the Planning Act, the Ontario government recently (November 2022) amended the Official Plans of both municipalities to expand urban boundaries for residential development into greenfields: https://ero.ontario.ca/notice/019-5732 and https://ero.ontario.ca/notice/019-5684 . This decision by the province represents a lost opportunity for Ontario to be a leader in planning for economic and environmental prosperity.

Bill 23, and decoupling environmental protection and smart planning from development will result in net economic loss for Ontario, and a reduced standard of living for Ontarians.

Lessons can be easily learned on what to do (and not to do) from other jurisdictions. There are countless studies and policy documents on the negative environmental and economic impacts of urban sprawl in comparable jurisdictions in the US https://www.nature.com/scitable/knowledge/library/the-characteristics-c… and Europe https://www.eea.europa.eu/publications/urban-sprawl-in-europe. International organizations have also weighed in on the impacts of urban sprawl https://www.oecd.org/environment/tools-evaluation/Policy-Highlights-Ret…

We already know what is the best policy for long term economic and social prosperity for Ontarians, and fundamental to that is the preservation of Ontario’s environment.

Thank you for your careful consideration of the information I have presented above.