Comment
Please see our full submission in the attached letter.
The main points we make in our letter are as follows:
1. The stated purpose of the proposed Open-for-Business Zoning By-law (OFB-ZBL) has no basis in fact. Many studies show sufficient land already designated and set aside to accommodate anticipated needs for employment lands for years, perhaps decades. In Durham Region alone, 56% of such designated land has yet to be built on, and another 17% remains underutilized. Want of suitable land is not why large industrial manufacturers may be reticent to locate their operations in Ontario. A far more likely reason is the uniquely high cost of electricity in the province.
2. Implementation of the OFB-ZBL would interrupt coordinated land-use planning at all levels of
government. The result would be the fragmentation of policies and practices across the province, with chaotic, unfair, and destructive results. Chief among the victims would be our vitally important agricultural sector. Re-enabling urban businesses to randomly fragment agricultural lands would weaken the viability of the surrounding agricultural area and the fabric of rural life.
With the damaging effects of climate change becoming more and more apparent, and with our population continuing to grow, any legislation that could result in the loss of farmland or harm the agricultural sector can only be considered deeply irresponsible.
3. The process laid out for permit approvals discards transparency. Regulations exist for a reason. They must not be overridden without in-depth review and public consultation. To prevent public oversight of development plans represents a clear breach of public trust. The OFB-ZBL rejects the importance and necessity of open, coordinated planning and critical oversight to prevent abuses. The current system could be streamlined, to everyone’s benefit, but it should not be made a
secret process with no right of appeal once the decisions are made public.
4. Schedule 10 denies vital health protections. If this legislation became law, a number of important
environmental protections embedded in at least five existing provincial Acts would no longer apply for new industries under the OFB-ZBL. Surely the Government of Ontario can find ways to declare the province open for business without intentionally putting the health and even the lives of its population at risk? If new industrial uses – considered and approved in secret – go on to contaminate our air, soil, or drinking water (and it would only be a matter of time), it will be the Provincial Government, with its flawed legislation and failure to regulate, that will be held to account.
We respectfully ask the Premier to keep his word – to continue to protect the Greenbelt (including the
Oak Ridges Moraine), which provides so many Ontarians with their drinking water, food, fuel, recreation, livelihoods, and economic benefits. Premier Ford must keep his promise; Schedule 10 must be removed from Bill 66.
Mary Delaney, Chair, Land Over Landings
Supporting documents
Submitted January 20, 2019 4:20 PM
Comment on
Bill 66, Restoring Ontario’s Competitiveness Act, 2018
ERO number
013-4293
Comment ID
20456
Commenting on behalf of
Comment status