Thank you for the…

Thank you for the opportunity to comment on proposed changes to the Planning Act and Development Charges Act as outlined in ERO 019-6172 and as related to Bill 23, the proposed More Homes Built Faster Act.

As noted in our November 16th submission to the Legislative Assembly of Ontario, Standing Committee on Heritage, Infrastructure and Cultural Policy on Bill 23, the Ontario Public Health Association (OPHA) fully supports the need for Ontario to find more affordable housing opportunities for its residents and create healthy, equitable and climate-resilient communities. At the same time, it is vital that these processes, including legislative changes, are undertaken in a manner that reduces the risk of inadvertent harms and inequities to the health and climate resiliency of communities.

Public health agencies have long recognized the connections between healthy environments and population health, and thus the importance of healthy public policy across all sectors to strengthen health protection and equity. This includes policies related to housing, the built and natural environment, land-use planning, climate-resiliency including mitigation and adaptation, and ecosystem protection.

OPHA supports action to create more rental and ownership types of housing that prioritizes affordable, healthy and environmentally sustainable housing. Actions such as intensification, higher density and transit-oriented development can be health and equity promoting, without compromising other vital attributes required for healthy and equitable communities including: access to, and protection provided by, parkland and other greenspace; access to affordable, sustainable and active transportation; and healthy, energy-efficient housing units.

OPHA urges the Government of Ontario to pursue affordable housing opportunities the Planning Act and the Development Charges Act that, at a minimum:

1. Maintain the existing parkland dedication provisions in order to prioritize equitable access to parks and natural areas for all residential development proposals and types of housing units, including affordable and attainable housing units.
2. Maintain the existing development fees, in order to ensure that development fees pay for growth, rather than passing the expense along to taxpayers.

OPHA does not support changes that would reduce parkland dedication, or exempt affordable housing from parkland dedication requirements. Higher density development must not come at the expense of reduced greenspace. Reduction of parkland requirements and parkland dedication fees will significantly reduce access to local greenspace. This will have negative impacts from a climate resiliency and health perspective, increasing health risks by impacting people’s access to cool outdoor spaces during heat events and disproportionately impacting equity-deserving groups, especially for people most vulnerable who have limited access to parkland and with the least resources to adapt. In addition, a decrease in the amount of parkland represents a decrease in the amount of impervious services, putting direct and immediate strain on municipal stormwater management infrastructure, increasing flood risks and increasing exposure to climate-related health hazards.

Additionally, these lands provide access to greenspace and recreational opportunities for the public. Access to greenspace play an important role to address chronic diseases such cardiovascular disease and diabetes, improves mental health, and helps reduce environmental exposures which impact health, such as extreme heat and air pollution. Reducing parkland dedication also places pressure in intensifying communities where reduced private greenspace and living spaces will put greater pressure on accessing outdoor and recreational amenities within one’s neighbourhood.

From a health equity perspective, OPHA is extremely concerned with proposed changes that will exempt certain types of development, in particular affordable housing from the parkland dedication requirement. There is mounting evidence of the health and equity benefits of access to nature, including parkland for all populations, and in particular, for children and youth and for people living with inequities. As noted in the report Green City: Why Nature Matters to Health – An Evidence Review, frequent access to nearby green space is important, especially for children, and nearby green space may provide added benefit in low-income neighbourhoods.

OPHA respectfully disagrees with the statement on the ERO 019-6172 webpage that these changes to the Planning Act will “provide for more parks quickly”. By reducing the maximum amount of land to be conveyed to the municipality for park or other recreational purposes from the current rate of one hectare for each 300 dwelling units, to one hectare for each 600 dwelling units, the proposed changes will result in less parks provided rather than more parks.

OPHA does not support the ability for developers to identify encumbered lands (e.g., land with underground transit tunnels or other infrastructure) to serve as parkland. Subsurface infrastructure or other easements on the property can significantly hinder the amenities that can be provided by the municipality and the ultimate usability and desirability of the land for parks purposes. For example, trees and certain structures that create a desirable park space require both depth and height. If either are taken away by an encumbrance on title, then the park is compromised.

OPHA urges the Government of Ontario to remove the proposed Planning Act changes with respect to parkland dedication provisions in order to prioritize equitable access to parks and natural areas for all residential development proposals and types of housing units, including affordable and attainable housing units. We urge the Province to not proceed with the proposed change to section 42 (3) and other sections of the Planning Act that would reduce the maximum parkland dedication “… for the purposes of land conveyed, from the current rate of one hectare for each 300 dwelling units to one hectare for each 600 dwelling units; and for the purposes of cash payment in lieu of land, from the current rate of one hectare for each 500 dwelling units to one hectare for each 1000 dwelling units.”

OPHA does not support changes that would reduce development fees. Development fees pay for vital municipal services with public health benefits, including upgrades for climate resiliency infrastructure such as flood protection, transportation infrastructure, public realm improvements, and other amenities and services needed to meet the needs of a growing population. Significant impacts can be expected if the current pool of funding to pay for these services is reduced. Growth will no longer pay for growth, at the expense of healthy, resilient and equitable evolution of our communities.

OPHA urges the Government of Ontario to remove the proposed reductions in development fees, in order to ensure that development fees pay for growth, rather than passing the expense along to taxpayers.

OPHA appreciates efforts to encourage the supply of affordable housing including affordable rental housing; however, this must not be at the expense of parkland dedication provisions, or the ability of the municipality to pay for the essential infrastructure (e.g. water and wastewater services, transportation, utilities, climate adaptation) required for the development. As noted above, building more affordable and attainable housing without providing essential greenspace, will eliminate the health and equity benefits of access to nature for all populations, and in particular, for children and youth and for people living with inequities. It will also greatly reduce the climate-resiliency benefits that greener neighbourhoods provide. This is counter to the equity-promoting and environmental justice measures that Ontarians expect from climate adaptation planning, and the government of Ontario’s commitment to strengthen the province’s resilience to the impacts of climate change and keep communities healthy and safe.

Thank you for considering our concerns and recommendations with respect to proposed changes to the Planning Act as outlined in ERO 019-6172. We would welcome the opportunity to meet with the government to discuss the proposed changes and solutions that address concerns related to this proposed legislative change.

Sincerely

John Atkinson
Executive Director
Ontario Public Health Association

i EcoHealth Ontario resources. https://www.ecohealthontario.ca/resources
ii https://news.ontario.ca/en/release/57998/ontario-launches-first-ever-cl…

More about the Ontario Public Health Association
OPHA has established a strong record of success as the voice of public health in Ontario. We are a member-based, not-for-profit association that has been advancing the public health agenda since 1949. OPHA provides leadership on issues affecting the public’s health and strengthens the impact of those who are active in public and community health throughout Ontario. OPHA does this through a variety of means including advocacy, capacity building, research and knowledge exchange. Our membership represents many disciplines from across multiple sectors.
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