Responding to Bill 108, More…

Responding to Bill 108, More Homes, More Choice: Ontario's Housing Action Plan, Schedule 12, Amendments to the Planning Act

May 31, 2019

I am writing on behalf of seven Toronto area Canadian Federation of University Women (CFUW) clubs representing over 1000 women who live across the GTA and beyond.
CFUW is a voluntary, self funded, non-partisan women’s advocacy organization with over 100 clubs across Canada, including over 50 in Ontario. CFUW Ontario has policy in place currently that supports housing for all, recognizing that a range of nonmarket and market housing is essential to meet all housing needs and recognizing that housing development and redevelopment should be sustainable, well planned, and ensure livable communities for all.

Overall, we are extremely disappointed that Bill 108 reverses many improvements legislated in 2017 to ensure sustainable growth in Ontario. The Building Better Communities and Conserving Watersheds Act was passed after extensive consultation in December 2017 with the support of all Parties; there was only one ‘nay’ vote.

The purpose of the government’s proposed amendments to the Planning Act is:
• to increase the supply of housing, and
• to streamline development approvals.
However, shouldn’t the emphasis of the policy be on quality rather than quantity? Ontario policy should encourage and support municipalities in the planning and development of the types of housing needed, such as affordable market rental units and nonmarket housing, priority locations and supportive infrastructure. Restricting inclusionary zoning to transit hub areas is far too limiting as the need for affordable housing goes far beyond the proposed areas.

The proposed amendments back track on the modernization of the development appeal process. The Local Planning Appeal Tribunal (LPAT) replaced the Ontario Municipal Board (OMB) which had power to overrule municipal decisions. The proposed changes will strengthen and broaden the authority of the LPAT to in effect re-establish the former OMB. The impact will be the loss of authority for local planning by the municipalities. This also decreases the impact of citizen groups, residents’ associations and groups such as ours in responding to development challenges and advocating for affordable, mixed housing with supportive infrastructure such as parks, transit, libraries, schools and early learning and childcare centres.

Another concern is the shortened timelines for the municipality to evaluate development applications. Limiting timelines for Zoning By-law Amendment (ZBA) applications from 150 to 90 days, and Official Plan Amendment (OPA) applications from 210 to 120 days will severely hamper the municipal planning review process.

These proposed changes to the Planning Act focus too much on increasing supply and on the flawed assumption that increased supply reduces prices. Instead, the proposed legislation places communities at major risk of not meeting the range of needs for housing. The changes support developers over municipalities and the lack of regulations and having such a limited time for consultation contribute to an unsatisfactory process.

Respectfully submitted.

Sheila Lacroix sislacroix@yahoo.ca
CFUW Leaside – East York, on behalf of the following:
CFUW Aurora Newmarket: Lynn Bird klbird@hotmail.com
CFUW Etobicoke - Maure Kentner maure.kentner@gmail.com
CFUW Leaside – East York: Jane Withers jhwithers28@gmail.com
CFUW North Toronto Helen Penfold penfoldhm@rogers.com
CFUW Scarborough Doreen Dickson g.dickson@sympatico.ca
UWC North York: Janet Gordon janetg8094@gmail.com
UWC Toronto Susan Freeman susgula@sympatico.ca