High Level Feedback: Given…

High Level Feedback:
Given the wide-ranging nature of the proposals related to the Planning Act included within the Bill staff are concerned that not only are the cumulative impacts that these proposed changes difficult to understand, but also are concerned that it will be difficult to monitor the effect of changes in supporting the objective of more homes built faster. In addition, staff are concerned that the proposal has the potential to significantly undermine the matters of provincial interest prescribed in Section 2 of the Planning Act. All would agree that building more housing is a common goal and of critical importance but not at the expense of the matters of provincial interest enshrined through Planning practice in the interest of the public interest.

While not an exhaustive list of the concerns the following elements of the proposal will have the effect of compromising the city’s ability to achieve its strategic goals

1. Exclusion of the Community and disregard for public interest and future residents. The changes proposed through Bill 23 will have the impact of significantly reducing the ability for the local planning context and the community’s vision and input to make its way into the planning process. Combined with Bill 109, there will be a significant reduction in the time in which the community can be engaged on planning matters. Further, the change in approval authority for planning matters from the Halton Region to the Minister could contribute to a more opaque planning process – one that could easily be biased towards special interest groups with little room from transparancy or accountability. Combined with the proposed changes to the CBC, DCs and Parkland Dedication legislation, these changes further erode the city’s ability to deliver the critical elements of a complete community that align with the community vision.

2. Protection of Public Health and Safety- The Province and the City are committed to protecting life and property from natural hazards and the City works closely with many partners including Conservation Halton and the Region of Halton to ensure the health, safety and resiliency of our citizens and systems. The Region of Halton provides coordination, expertise and oversight over many critical systems which ensure the health and safety of our public. Conservation Halton similarly provides the technical oversite and authority which protects life and property impacts due to natural hazards. Staff is concerned that the changes proposed could lead to a disorganized and poorly planned approach to our critical planning systems absent significant time and resources to ensure those critical functions and roles can be addressed. These changes also don’t account for significant regional differences across the province. The City recognizes the importance of expediting planning approvals for residential development however, given the proposed volume of new homes, it remains imperative that applications be reviewed in the context of the whole planning system.

3. Cost of Growth and Impact to the Community. The proposed changes, when assessed together limit the city’s ability to plan for, finance and construct the necessary infrastructure to support growth. The proposed changes represent a departure from the premise that growth should pay for growth and places the burden for that growth on the tax payer.

4. Regional Coordination and Matters of Provincial Interest - The Province and the City are committed to ensuring that the matters of Provincial Interest in Section 2 of the Planning Act are addressed through a systems based approach in planning for infrastructure, Natural Heritage, agriculture, employment and growth management, among others. Historically, Halton Region has shared in this commitment in overseeing the regional market area. Staff are concerned that the decoupling of regional land use planning from regional infrastructure planning could result in delays in the delivery of services including water/wastewater infrastructure, phasing and coordination of capacity allocation between local municipalities, which could have detrimental impacts on the timing and development of new homes and may lead to inequitable financing and capacity distribution.

5. Removal of Planning Act Process for 10-unit (or less) development - Staff is concerned that the exempting of developments with less than 10 units could be counter to the goal of building more homes faster as it could lead to an increase in non-Planning Act applications which may have the impact of slowing down smaller development files, especially in light of the reduced timelines proposed under Bill 109 and the re-direction of resources to meet the time requirements or face penalties. Additionally, staff are concerned that the proposed changes may be indirectly incentivizing development at too low an intensity as it makes smaller scale development the path of least resistance.