The following comments…

The following comments reflect concerns over the overall effects of the package of changes proposed by the Ford government. They will lead to higher property taxes, greater uncertainty in parkland provision and less of it to serve higher density communities when it is needed more than ever, and inequitable social outcomes. The comments are organized into the following categories.

Parkland dedication
No parkland dedication or cash-in-lieu requirements for “missing middle” development is short-sighted Research around the word universally indicates open space to be a fundamental requirement of mental and physical health. This policy is problematic particularly if extensive amounts of infill development occur in a given area that would result in a shortage of open space. Better to have a fairly low cash-in-lieu requirement that still maintains the development incentive, and that the municipality can use to improve or add open space in the same area.

Streamlining the Municipal Planning Process
The removal of regional policy direction is a reckless proposition. Who is going to ensure the availability of regional infrastructure and its timely provision when local municipalities are haphazardly approving development with without ANY oversight from regional and provincial levels?
This is precisely the wrong time to dismantle the regional planning system. The massive amount of forecasted population and economic growth for the GTAH will require coordination and integration of land use planning, infrastructure, environmental planning, and transportation planning. Related challenges cross local municipal boundaries. Regional planning provided the essential policy and planning framework to deal with regional-scale issues, impacts and solutions.
The irony in this measure is that it will result in a lack of planning, no clear path to implementation, and poor decisions that will require correcting at the expense of delays and additional expense to taxpayers.

Third Party Appeals
The text is misleading. “…to limit third party appeals for all planning matters” essentially amounts to a prohibition. This measure also suggests the Ford government has little understanding of what official plans address. OP policy addresses smaller land-specific areas, but also large swaths of land or in the realm of transportation, no private land at all. To deprive a citizen the ability to appeal a general policy relating to, for example, climate change or active transportation, constitutes a draconian clamp-down on democratic process. And to limit third-party appeals for site-specific appeals is also unfair. If, for example, increased traffic on a road from a proposed development directly affects the safety of residents several hundred feet away, they are not considered to have a legitimate interest in the shaping of the development? This is not democracy.

Site Plans
By removing the public meeting requirement for draft plans of subdivision, not even neighbouring landowners (who are not third parties) will have input on matters that will directly affect them.
The success of higher density urban form depends on high quality urban design. If we’re serious about creating liveable cities, then we need sensible architectural and urban design standards and regulations. To remove architectural details and landscape design from site plan control will ensure the lowest common denominator in future Ontario urban development. Is this the kind of urban environment the Ford government wants to leave future generations of Ontario’s residents?

Role of Conservation Authorities
Limiting the role of CAs to natural hazard policies in the PPS will guarantee the loss of significant remnants of natural heritage in urban Ontario. Municipalities do not have the expertise (and often the mindset) to ensure environmental concerns are addressed. And there is no guarantee all municipalities will seek it. The province should include a measure in the regulations to compel municipalities to retain—either in-house or through consultants—the expertise the CA’s will now no longer be able to use.

Analysis of Regulatory Impact
The analysis of regulatory impact is woefully inadequate and disingenuous. Three examples follow:
There is no doubt the construction industry will benefit financially from the changes. But will the people that buy the homes they build? With the removal of the green standard, residents purchasing new homes may find their overall long-term costs will outweigh the possible lower purchasing costs. There is no guarantee that developers will pass on the savings unless the government dictates all savings be passed on and enforce this requirement through audits of developers. And how will the government assess the effects of its legislation on housing prices when they vary from myriad factors and across the province?
The statement that the proposed measures will “reduce costs” is a half-truth—perhaps even a quarter truth. It will not reduce costs for the vast majority of Ontarians who are “private homeowners,” who will be faced with increased property taxes. Moreover, one year in, the new homeowners that may benefit from these measures will suffer from the same property tax increases the rest of us will face.
The statement “there may be costs to municipalities as a result of these proposed changes” has been irrefutably refuted. Assessments from all municipalities and the AMO have concluded the losses will be in the billions of dollars to Ontario municipalities over just a few years. ALL Ontario homeowners will suffer—including those who purchase a new home-- because after their first year ownership higher property taxes forced on municipalities by the Ford government’s legislation will start to eat away any savings from the purchase price.