Thank you for accepting this…

Thank you for accepting this submission to Bill 17 on behalf of 50by30 Niagara, a grassroots environmental conservation organization. While we support the intent of Bill 17 to streamline and accelerate housing development, make housing more affordable, and advance transit-oriented communities, we cannot support the Bill as drafted, as it undermines municipal oversight by restricting their ability to safeguard urban design elements like flood protection, air quality, and energy efficiency.

Bill 17 is written from an outdated 20th century perspective, ignoring the fact that Green Development Standards (GDSs) are essential tools for affordability and sustainability. Municipal authority to enact proven, performance-based GDSs should be maintained. Green standards ensure buildings are efficient and address extreme weather and climate change. These standards complement, rather than conflict with, the Ontario Building Code. There is no evidence they slow down housing. In fact, Toronto, with its ambitious standards, has seen more development in recent years than any other city in North America. This component of Bill 17 is unacceptable as, while green standards add minimal upfront costs, they enhance long-term home-owner affordability and reduce municipal infrastructure expenses.

Bill 17 eliminates critical checks and balances by mandating automatic approval of development submissions from prescribed professionals, removing municipalities' essential role in protecting public health, safety, and environmental well-being. Furthermore, by stipulating these submissions be automatically accepted as compliant with all requirements, Bill 17 effectively transfers planning approval authority from municipal staff to consultants hired by developers. This increases risks and liabilities and creates unnecessary conflicts of interest for designated professionals. It is essential for the interests of all parties, including the public, that development documentation be subject to independent review by qualified individuals at arms-length from the project, such as municipal staff. This component of Bill 17 is unacceptable as municipalities have a responsibility to oversee urban design in their own jurisdictions.

Transferring responsibilities from the government to industry players and allowing greenhouse gas emissions to be locked in for years to come is reckless and will not provide the homes that Ontarians need to be more resilient to heat-waves, flash flooding & other consequences of climate change.

We agree that builders need clarity and predictability to build faster. However, the proposed legislation makes sweeping changes to the role of municipalities in development planning and potentially invalidates a wide range of existing bylaws across Ontario. The bill as drafted risks creating confusion and disorder, as both municipalities and developers work to understand the implications and adjust policies and procedures. This could lead to housing project delays and exacerbate challenges with land speculation that worsens affordability.

Stripping municipal authority to review development submissions also risks increasing the number of disputes at the already overloaded Ontario Land Tribunal. If a submission from a prescribed professional is unclear or fails to adequately address a requirement, municipalities may be forced to rely on legal challenges, creating new uncertainty and delays. Rather than accelerating development, these specific changes could have the opposite effect.

We therefore ask, at the very least, for the following changes to Bill 17:
1. Allow municipalities to enact green development standards and bylaws, and protect existing GDS, related to construction or demolition, provided they do not conflict with the Ontario Building Code.
2. Ensure clarity in the legislation and consistency with the Provincial Planning Statement to support predictable and fair planning processes.
3. Protect public interest, informed and democratic decision making, and minimize risk by allowing municipalities to continue conducting independent review of development submissions.
4. Ensure Bill 17 protects affordability and efficiency
Municipalities must have a targeted role to play in development that focuses on health, safety, and long-term affordability for Ontarians while reducing red tape and increasing efficiency.

We urge you to revise the legislation to ensure that all stakeholders, including municipalities, can do their part to ensure streamlined approval and construction of quality buildings in Ontario, affordable for all while curbing destructive emissions that drive the escalating climate crisis which is now the greatest economic and health crisis of our time.

Thank you for your time and consideration.
Sincerely,
50by30 Niagara