November 22, 2022 SENT BY E…

November 22, 2022

SENT BY E-MAIL – PlanningConsultation@ontario.ca

Dear Honourable Steve Clark, Minister of Municipal Affairs and Housing

RE: Bill 23, More Homes Built Faster Act, 2022

Proposed Changes to the Planning Act and City of Toronto Act (Schedules 9 and 1 of Bill 23 – the proposed More Homes Built Faster Act, 2022)
ERO Number: 019-6163

This letter summarizes the Town of Erin’s comments to the proposed legislative and regulatory amendments to the Planning Act and City of Toronto Act. We request that the Province consider our comments.
Addressing the Missing Middle
• The Town of Erin is currently constructing a Wastewater Treatment Plant for the Urban Areas Erin and Hillsburgh. The Town has concerns with permitting up to 3 units per lot, as this legislative change was not considered during the calculation of the capacity of the Treatment Plant. The Town requests that the proposed provision be reworded to permit up to 3 units per lot where there is capacity for the units to be serviced by municipal water and sewage.

Streamlining Municipal Planning Responsibilities
• Who will be providing regional oversight of growth management? Some municipalities are more willing to accommodate growth and some municipalities are not. The Regions and Counties ensure growth is appropriate allocated to lower-tier municipalities.

Third Party Appeals
• The Town is of the opinion that limiting third party appeals and removing the requirement for public meetings for draft plans of subdivisions will have a negative impact on the development industry and the planning process. Public consultation and public right of appeal are presently fundamental components of the planning process. Public input is often key to enriching and improving development proposals. Furthermore, resident input is a key component to understanding local conditions and impacts.

Public Meetings
• The public meeting allows the public to learn more about the proposed development, and vocalize any concerns to Council and the municipal planners. Hearing from the public at these public meetings is critical to the planning process as it is a planner’s responsibility to review an application to ensure it meets the public’s interests. Resident input is a key component to understanding local conditions and impacts, and to enriching and improving development proposals.
Site Plan – Exemption for Development up to 10 Units, Architectural Details and Landscape Design
• Many municipalities have urban design guidelines, passed by Council, which are important to the community and address localized conditions. Municipalities use Site Plan Control to apply these important urban design principals and/or guidelines to enhance their community and its attributes. Improvements can include enhancements to the public realm, to parks, and to a neighbourhoods built form and character which contribute to a community’s identity.
• The incorporation of architectural and landscape design elements into the Site Plan review process is not presently a stumbling block to building more homes faster.
• At a minimum, the review of architecture and landscape design should continue to apply to commercial and industrial properties, as the focus of the legislation is to build more homes faster.

Facilitating Aggregate Applications
• A thoughtfully proposed aggregate application will have no need to come back to Council within a 2-year timeout period. This is also a period of time necessary to monitor impacts of an aggregate development.

Conservation Authorities
• Municipalities do not have in-house expertise to comment on the potential impact developments may pose to the Natural Heritage System. As such, municipalities rely on conservation authorities to review technical reports and studies submitted as part of Planning Act applications. As conservation authorities have the expertise on matters related to the Natural Heritage System, they should have the rights to appeal decisions made on applications that will negatively impact the Natural Heritage System. Removing this authority from a conservation authority waters down protections presently provided to our rich natural heritage systems.
• The Province should be supportive of the conservation authority’s efforts to protect communities from flooding and erosion. Rather than stripping away the authority of conservation authorities, the Province should focus on increasing conservation authority resources related to development review.

If you have any questions or concerns, please contact me by email (Jack.Krubnik@erin.ca) or by telephone (519.855.4407 Ext. 253).
Sincerely,

Jack Krubnik, MLA, OALA, MCIP, RPP
Director of Planning & Development
Town of Erin