I have worked on a town…

I have worked on a town advisory committee for the past four years, and one of the very important gains that our committee made was to move the town towards creating Green Development Standards (GDSs), which are at this time in the process of being developed. Bill 23 would remove the ability of a municipality to implement GDSs, which are critical to the creation of sustainable communities in this time of a need to fully address the climate emergency. Many of the GDSs would require implementation at the local level, and this ability is being removed by Bill 23. Sections of Bill 23 that restrict a municipality's ability to act on the climate emergency should be removed. Indeed, municipalities need stronger tools to act in this manner, not weaker ones.

Bill 23 reduces the amount of parkland that a developer has to set aside. During Covid it became very apparent that people need open space and parks at critical times, and that parkland space in many areas was already insufficient. To reduce the amount of parkland that a municipality can require in new subdivisions at this time is short sited and unconscionable, especially since the previous amounts allowed were already insufficient.

Municipalities require some control over external elements of buildings in order to provide for some aspects of environmental protection, sustainability, and overall aesthetics in relation to surrounding buildings and the surrounding environment, as well as for health, and accessibility. Bill 23 appears to remove many of these abilities, but, from the latest version on the ERO, it appears some appropriate amendments have already been made, although not all.

Forests, farmlands, and wetlands play very important roles in water retention, groundwater recharge, prevention of flooding, wildlife protection, providing habitat for endangered or at risk species, reducing pollutants in water bodies, and over all sustainability that is essential for minimizing the effects of climate change. Conservation Authorities in Ontario have a significant influence on these lands through their role as stewards of large land areas , as well as through their role as the retainer of significant amounts of knowledge and expertise in understanding natural, and man-made (e.g. dams, retention ponds etc) systems at local and regional (e.g. watershed) scales. This knowledge is very important in assuring that any new developments do not overly damage balances that currently exist and damage our abilities to reach some degree of sustainability. Bill 23 would severely reduce the ability of Conservation Authorities from commenting on new developments. The parts of the bill that restrict Conservation Authorities form commenting on developments should be removed, as should the parts that force Conservation Authorities to approve some developments.

Not only does Bill 23 severely restrict Conservation Authorities from commenting on developments it also would remove planning responsibilities from some upper tier municipalities. This would remove virtually all regional perspectives from lower tier Official plans and many other planning responsibilities and make the Minister the approving authority, with no right to appeal. This looks like a recipe for removing regional based environmental protection, proper coordination of services and planning between municipalities, and sustainability, from the planning process. The adverse consequences of this could be highly significant and should be thoroughly investigated prior to these aspects moving forward. It would be preferable to remove these sections from Bill 23.

Bill 23 would remove public meeting requirements for draft plans and subdivisions as well as revoke third-party appeal rights of official plans and official plan amendments, zoning by-laws and zoning by-law amendments, consents, and minor variances to the Ontario Land Tribunal, limiting appeals to the developer and certain other specified parties. These changes would effectively remove the public from the planning process and from appealing new developments, which goes against well over 50 years of established democratic planning principles. There does not appear to be a demonstrated need for doing so, and the sections that limit public participation should be removed from the bill.