Bill 23 -More Homes Built…

Bill 23 -More Homes Built Faster Act, 2022.

Here are some of my comments:
Bill 23 will encourage rather than reduce urban sprawl. Urban sprawl is one of the driving forces behind the cost of housing in this province because of the cost of servicing car dependent, low density neighborhoods. While the bill addresses intensification around transit, it also, in part by annexing 7,400 acres of the green belt and forcing municipalities to expand their urban boundaries will drive car dependent freestanding single family tract housing.

We need to strive to make every new development into a walkable and cyclable community and actively seek to reduce car dependence by offering good walking and cycling infrastructure along with public transit and local shopping and service opportunities.

Removing the requirement for public meetings and severely limiting the opportunity for public comment and appeals to the Ontario Land Tribunal simply reinforces the notion that the government is not so much interested in a long term housing plan as in a long term developers support program.

Removal of development charges from developments is completely counterproductive. Instead DC's should be revamped to reflect the actual cost of servicing a development. This would mean that suburbia will finally start to pay for the cost of servicing and maintaining the infrastructure associated with urban sprawl and inner city and infill developments will attract lower development charges. Simply removing them only pushes the cost of servicing onto the property tax payer base, or, if the government makes municipalities 'whole' onto the general taxpayer base.

Environmental protections should not be removed from development planning. CA's were formed in the wake of Hurricane Hazel to ensure that we would never again have the kind of large scale flooding that happened then. Removing them from the decision making process will cause developments to be built in areas where they should not be built. As large storm events are becoming more frequent and less predictable, it makes sense to shore up stormwater regulations and development planning rather than water them down.

There are currently 86,500 acres across the GTA zoned and ready for development, along with many more in other areas of the province. There is ZERO reason to remove 7,400 acres from the green belt. Removing those areas from the green belt has a significant stink of corruption around it already, but from a long term planning point of view, it removes both valuable agricultural land in the immediate vicinity of our largest city from inventory, NEVER to grow another crop, and it endangers ground water quality and stormwater control in the GTA. While adding 9,500 acres to the Green Belt is a welcome addition, removing 7,400 acres is not. The Greenbelt also limits urban sprawl. As we look at Mississauga and Brampton in this context it should be noted that both those cities contained the most productive agricultural and horticultural lands in Canada not that long ago. All those were lost to urban sprawl. Never to grow food again. That was the result of dumb planning in the 70's and 80's, and it should never be repeated.

The removal of design considerations from the municipal approval process is poor practice. It leads to poor quality land use. The legacy of the 1960's 70's and 80's many municipalities are only just coming to grips with has been car dependent urban sprawl, which makes servicing of developments incrementally more expensive. While there are very good reasons to streamline the municipal approvals processes across the province, throwing the child out with the bathwater has always been a bad practice and continues to be so.

What should also be undertaken immediately is moving adoption of the 2025 National Building Code forward by 2 years (all major decisions on chances have been taken by now and most comment periods are over) and adopting those changes into the Ontario Building Code immediately rather than 2 years after the NBC updates are published. This is especially referring to the environmental section of the building code, dealing with building envelope design and implementation. Do not give developers the opportunity to cheap out on their buildings as the energy and replacement cost associated with those practices will come back to haunt future home owners, tenants and governments in the form of high energy bills and high repair costs.

Bill 23 needs major revisions, and there needs to be a robust and immediate consultation with all stakeholders to ensure that the bill indeed provides for more affordable housing across Ontario. As written, that will not be accomplished anywhere close to the extent needed. It is time to collaborate to fix this bill. You do not wish to create a 35 year legacy that leaves the province in a poorer housing, environmental and agricultural condition that what it is currently in. Unfortunately that is what bill 23 in it's current iteration will do.