Comments on “Proposed…

Comments on “Proposed Planning Act, City of Toronto Act, 2006, and Municipal Act, 2001 Changes (Schedules 4, 9, and 12 of Bill 185 - the proposed Bill 185, Cutting Red Tape to Build More Homes Act, 2024)”

Attention of Ministry of Municipal Affairs and Housing:

I am writing to object to certain sections of Bill 185, especially Schedule 12, which recommends the removal of the public’s ability to appeal the adoption or amendment of Official Plans and Zoning By-Laws to the Ontario Land Tribunal. Public appeal rights have been around for a very long time. Removal of these rights would be undemocratic. Such a removal is not good because land use planning decisions may have very important impacts on local natural environments, public health, safety, transportation, and even the already built environment. Such decisions may uncharacteristically affect under-served and under-resourced communities.

I strongly recommend removal of sections 3(1), 3(3), and 5(7) of Schedule 12. These are the sections that would affect the public’s ability to appeal the adoption or amendment of Official Plans and Zoning By-Laws under the Planning Act sections of 17(24), 17(36), and 34(19). Removing these public appeal rights, which have been around for a very long time, would be undemocratic. Such a removal of these appeal rights would not be a sign of responsible governance.

Additional comments on Bill 185 as follows:

a) Leave the Community Infrastructure and Housing Accelerator Tool (CIHA) in place, hence no repeal of section 34.1. Ministerial Zoning Orders should not be made vis a vis this tool if proper municipal planning is being done. CIHA facilitates good planning.

b) Preapplication consultations should not be voluntary nor should they be at the discretion of the applicant. Municipalities represent the local citizens, and therefore it is that entity that must have the authoritative say in preapplication consultations. Same argument for municipalities regarding boundaries of areas of settlement. Boundary changes must not be done at the whim of an applicant. These must be considered by the municipality as per the official plan.

c) I disagree with removing planning responsibilities from upper tier municipalities. These entities need to retain planning responsibilities that are of a regional nature.

d) I disagree with exempting Universities from the Planning Act and the planning provisions of the City of Toronto Act, 2006. Many Universities are very large public entities, owning very large tracts of land in many Ontario cities. Hence, I think they need to be accountable under the Planning Act just like others who may be planning development. University led housing projects on and off campus need to be accountable under the Planning Act for their effects on their municipality and how they fit into neighbourhoods.

Thank you for the opportunity to comment on the “Proposed Planning Act, City of Toronto Act, 2006, and Municipal Act, 2001 Changes (Schedules 4, 9, and 12 of Bill 185 - the proposed Bill 185, Cutting Red Tape to Build More Homes Act, 2024)”.