To: Standing Committee on…

To: Standing Committee on Heritage, Infrastructure and Cultural Policy

Re. Serious Concerns about Bill 23 in relation to impact on food security

Date: 4 December, 2022

False Dichotomy

In Bill 23 the Ontario government is proposing to address a crisis in housing by stripping

away measures that place any constraints on uncontrolled urban development and

protect our non-renewable land resources—including farmland, wetlands, greenspaces

and foodlands. This destroys, in one omnibus bill, the balance formed through a

decades-long negotiation over sound policy.

The predictable, long-lasting consequences of this open assault rest on a falsehood:

that we have to choose between protecting the land and building housing. Groups

across Ontario, including groups focused on food and farming, have long presented

reasonable, evidence-based options that demonstrate how we can both provide

needed, affordable housing and conserve lands that are essential to build sustainable

communities across the province.

In fact, many of the principles underlying the relevant existing policy structure and

regulations (e.g the Provincial Policy Statement, Growth Plan) have worked toward the

essential balance between housing and conservation—a balance that we must find in

order to build sustainable communities.

Communities have presented better solutions for More Housing, Faster

We in our communities have the knowledge of how to build housing and protect

farmland and the environment. Our local leaders have spoken about the type of

inclusive neighbourhoods that use both intensification and inclusionary zoning targets

to build with balance in our communities.

A shortage of land isn’t the cause of the problem. Land is available to meet projected

targets inside municipal boundaries. Local, grassroots, informed organizations have

identified strategies to build more houses, faster in our communities, in a way that

supports our communities—with livable neighbourhoods for all, meaning greenspace

and agriculture spaces maintained in urban, suburban and rural neighbourhoods.

The shortage is in political will. Bill 23 places unnecessary constraints on useful tools

like inclusionary zoning, purposefully removing solutions that have been tested in

communities throughout Turtle Island—where most communities have found benefits

are achieved in the 10-15% range, not the 5% this Bill enforces. This Bill has to centre

the solutions that maintain multiple benefits to our communities.

Food Security Requires Affordable Housing

When housing is not affordable, families must move further away to find housing they

can afford, often in low-density communities with inadequate, expensive transit

infrastructure required to be built, that is not sustainable as density is required for

affordable transit. This escalates urban sprawl, paves over more natural spaces and

foodlands and increases carbon emissions. Urban sprawl solutions also means getting

to food is harder to achieve.

Bill 23 makes housing less affordable by:

Removing rental replacement requirements;

Reducing municipalities’ capacity to pay for affordable housing through development

costs;

Allowing developers to create less affordable housing, by lowering limits on inclusionary

zoning (to only 5%) and using a market-based definition of “affordable” housing

Bill 23 also guts green building standards, which instead need to be enhanced to

include food production. Housing and food security must be planned for together.

Food Security Requires Access to Land

Individuals and Families are increasingly needing to choose between rising costs of

housing and rising costs of food. The continued rising cost of food shines a light on the

urgent need for both affordable housing and to protect all foodlands and farmlands as

key components of our current and future food security.

Disruptions to long food supply-chains, increased transportation expenses, crop failure

in other parts of the world, and the need to limit our use of carbon-based fuels, require

us to increase our food security by deepening our access to sustainably-produced,

locally-grown food.

Relying heavily on urban sprawl as a solution, instead of densification, whittles too much

of the already small share of land devoted to local agriculture.

In an urban context, Bill 23 means developers will be required to provide less

greenspace—meaning fewer opportunities for urban food production and food forests,

all part of building community food resilience, with food of choice.

Food security requires Conservation

Throughout Ontario, when we say Bill 23 has a negative impact on the environment, on

lands, on waters - we are identifying a negative impact on food security and on food

sovereignty.

Food is grown, harvested, and processed in our communities, from the land, the waters,

the forests—with our continued food security resting on us doing this in a sustainable

manner.

Despite daily acknowledgements that Ontario rests on Indigenous lands, under treaty or

unceded, the Indigenous principles of conservation of lands, and of sustainability for

seven generations forward, are not part of this Bill.

Allowing “offsets” for wetlands and woodlands through developer fees will be an

ecological disaster that will stretch into our farmlands, impacting the ability of our farms

to provide ecosystem services over the long term. In the face of a rapidly changing

climate and uncertain seasonal weather patterns, the disruption of complex wetland

systems can have massive impacts on above- and below-ground waterways, and the

production potential of adjacent agricultural lands.

Bill 23 also eliminates the ability of conservation authorities to protect watersheds and

greenspaces, by eliminating their ability to holistically manage watershed resources.

Many of the duties of Conservation Authorities are being dumped into the laps of

municipalities—without the resources and expertise to effectively carry out those

responsibilities.

Food Security Requires Farmland Protection

Permanently protecting agricultural land in the province is crucial—once it’s lost to

development, it is gone forever. Disruptions to long food supply-chains, increased

transportation expenses, crop failure in other parts of the world, and the need to limit

our use of carbon-based fuels, require us to increase our food security by deepening

our access to sustainably-produced, locally-grown food.

While this legislation pays lip service to the need for farmland protection, Bill 23 will

instead:

accelerate farmland grabbing, placing more non-renewable farmland under the control

of speculators and developers;

re-zone thousands of acres of prime farmland to allow for development;

increase land prices—something that new and young farmers can not afford—and

increase the cost of producing food locally;

eliminate agricultural systems mapping and impact assessments, critical tools for

evidence-based decision-making (https://ontariofarmlandtrust.ca/2022/11/10/bill-23/);

increase fragmentation of rural and agricultural areas, placing further strain on rural

communities;

attack meagre regional planning efforts to control urban sprawl, and dramatically alter

the long-term planning framework, the Provincial Policy Statement;

increase uncertainty over planning and conservation efforts, from the farm level to the

municipality, and will do irreversible harm to the ability of our regions to produce good

food over coming generations;

eliminate the growth plan density requirements;

remove key infrastructure planning elements of the growth plan;

allow settlement area expansions (Growth Plan, Planning Act changes);

separate development approvals (municipal) from infrastructure planning (upper tier)

(Planning Act changes)

prevent public and conservation authorities from appealing sprawl proposals to the

Ontario Lands Tribunal (Proposed Amendments to the Ontario Land Tribunal Act, 2021)

facilitate developer appeals of official plans by eliminating a 2-year timeout (Planning

Act amendments)

allow developers to reduce payments for new infrastructure costs of sprawl

(Development charge changes)

Food Security Requires a Sustainable and Responsible Approach

With Bill 23 the provincial government is taking an unbalanced, radical approach that

will produce harm—an approach that seems to be singularly driven by the developer

lobby’s profit-driven priorities - there is NO other beneficiary. Rather than increasing

enforcement to make up for the multi million dollar revenue shortfall in development

fees, this legislation reduces those fees for developers—without acknowledging that the

shortfall left in municipal budgets is most often made up for by cutting community and

social services, already insufficient to make up the serious gap on income security

policies, also set at the provincial government.

Similarly, many changes in Bill 23 take responsibilities away from Conservation

Authorities and hand them to municipal governments, who often have no experience or

resources to carry out these duties.

The downloading of responsibilities to municipalities without the attendant budget; the

promotion of housing construction without the associated municipal revenues required

to service those neighbourhoods; the wholesale removal of regulations that hinder

some home building, but which are required to prevent negative outcomes from

construction elsewhere: this is an approach to governance that does not attempt to look

for balance.

While Ontario has not found this perfect balance to date, what we have developed is an

approach that introduces change in a manner that recognizes the need for balance. For

one bill to tilt policy and slash regulation in so obviously one-sided a manner is

undemocratic and unaccountable to people living in Ontario, policy experts, and our

lower-tier governments.

Food Security Requires Food Sovereignty

Bill 23 erodes our food sovereignty, our food security, our democratic processes.

It must be pulled now, and re-started with guiding principles that balance the long-term

mutually-supportive needs for housing, ecological services and farmland protection,

and adopt an inclusive, collaborative approach that targets livable neighbourhoods,

farmland protection, food security and participatory governance.