Dear Minister Clark As a…

Dear Minister Clark

As a practicing professional planner, Ontario resident, and parent of young children I am deeply concerned with the impact of the proposed legislative and policy changes proposed through the province's "More Homes Built Faster" plan, including Bill 23. The alleged goal of the plan is to increase housing supply and affordability; however, the effect of the legislation will mean increased costs for all through municipal tax hikes and servicing of outward suburban expansion at the expense of dismantling the regional and environmental planning framework that Ontarian's rely on to plan our communities for the future.

The following are my main concerns with this flawed omnibus bill:

Development Charges:
Reducing the ability for a municipality to collect development charges will not address the affordability crisis. Municipalities prepare development charge by-laws based on detailed studies that follow a prescribed process to ensure that growth pays for growth. Reducing this critical revenue source will mean that a municipality will either need to make up the short fall through increased taxes to which everyone must pay, or cancelling or reducing services and projects. This will mean a delay in housing that is dependent on DC funded infrastructure and reduction in community services for existing and future residents. It is unclear why the government assumes a land developer will pass savings through reduced development charges onto purchasers of homes. Any constraint on the ability of a municipality to collect development charges needs to be met with additional and permanent funding from the province.

Parkland:
Public parkland plays an important role in planning complete and healthy communities. The need for quality outdoor space within easy reach of one's home is well documented, and this was particularly evident during the COVID-19 pandemic when Ontarians flocked to municipal parks and trails. Bill 23 plans to cut parkland dedication requirements in half. Cash strapped municipalities will be required to purchase additional land to provide for viable public parks. In all likelihood Bill 23 will result in new communities being underserviced in public space, which is a disservice to future residents in Ontario's cities.

Removal of Regional Governments as a Planning Authority and Eliminating Conservation Authorities role in Development Review:
Regional Governments and Conservation Authorities play a critical role in the land use planning framework in southern Ontario. Regional governments apply a wholistic lens on matters relating to growth management, transit, regionally significant environmental features, safe and clean drinking water supply and cross border municipal infrastructure. Priority consideration of these important Region-wide systems will be lost if all planning decisions are devolved to individual lower tier municipalities who are focused on matters affecting their local municipal boundaries. This will result in uncoordinated growth and loss of prime agricultural land and environmental areas in the form of costly car dependent suburban expansion.

Conservation Authorities take an even broader watershed level view on land use planning and municipalities rely on the expertise of Conservation Authorities in the review of development applications. Bill 23 will cut out Conservation Authorities review of development applications and result in development that negatively impacts the natural environment.

Site Plan approval changes:
Bill 23 proposes to scope the site plan review process by eliminating the ability for a municipality to comment on external and sustainable design matters. This will result in in development that is out of character for an area and the inability of a municipality to implement green development standards, which is an important tool in advancing measures to address climate change adaptation and mitigation.

Merging of PPS and Growth Plan:
In 2006 the province established the Growth Plan for the Greater Golden Horseshoe. Ontario was internationally recognized in its approach to growth management for the most populous region of the country. Now the province is considering merging the growth plan with the provincial policy statement. It is unclear the scope and impact without being provided the new merged document, but the consultation material suggest the impact of the change will enable more outward suburban growth by making it easier to expand municipal settlement areas and increased flexibility in developing rural areas. These suggested policy changes coupled with the recent proposal to expand home construction into the protected greenbelt are significant steps backward in regional planning.

Making it easier for developers to build low density housing at the fringe of communities will not lower costs for Ontarians. Reducing development charges with the expectation that developers will pass those savings onto purchasers is naïve; "trickle down" economics does not work. It is unconscionable that in the time of a global climate emergency the province is cutting out the review of Conservation Authorities to comment on impact to the natural environment, curtailing the ability of municipalities to mitigate and adapt to climate change and paving the way for suburban sprawl. For the sake of all Ontarian's, especially future generations, please reconsider this legislation.