Bill 23 is not needed to…

Bill 23 is not needed to build more homes quickly. Approvals are not the issue. Strategy Corporation reports that the GTHA (Greater Toronto and Hamilton Area) already has over 200,000 approvals for housing that are not being built. Environmental Defence has documented that the GTA already has over 80,000 acres of land designated for development within existing municipalities, without taking 7,400 acres away from the Greenbelt, as proposed.

The problem of slow development approvals is only partly caused by the pace of municipal approvals and mainly by:
• Incomplete submissions
• Submissions that are multiples of the height and built form standards in the local Official Plan, leading to extra time for comments and reviews.

The Bill should be changed to allow municipalities more flexibility in how to implement the Province’s “gentle density” strategy.

Subject to some amendments to the Planning Act, but with less oversight than is in the Bill, municipalities should retain the right to develop their municipality the way they want and in lock step with the wishes of their residents, their natural topography, and their natural resources, and not have that level of detail replaced by central decision making by the Provincial government.

To prevent significant property tax increases, compensate cities for loss of revenue from reduced or eliminated Development Charges, Community Benefit Charges and Parkland Dedications.

Residents in new housing deserve access to the fresh air and green spaces that existing residents enjoy, and that right should not be diminished by reduced parkland dedication.

To replace the proposed 50% parkland designations reduction in higher density residential developments, retain the ability of the City of Toronto 2022 Official Plan proposal of a fairer system of Parkland Dedication calculations. To ensure a comprehensive municipal parkland strategy, allow cities to accumulate reserves year-over-year for larger projects but require public reporting of costing and project reserve totals.

The Bill should allow appeals by third parties against developers or municipalities under a pre-defined set of conditions that should be provided as part of the Bill. For Committees of Adjustments (CofAs) the definition of what constitutes a ”minor” variation should also be defined, including what would be the cumulative impact of several variances in the same appeal.

If maintaining the right of appeal at the Ontario Land Tribunal (OLT) or Committee of Adjustment (CofA) is to include indigenous communities, then all communities should be included, not just indigenous ones.

Eligible public bodies should include incorporated bodies representing citizens such as churches, resident associations and service organizations and charities, if the nature of the appeal meets one or more predefined criteria. Mediation should be a requirement before a formal appeal.

Residents and municipal Councils should have a right to told what real estate developments are being proposed for their communities. Restore the rights of third parties to appeal to the OLT, but reform the process to moderate third-party participation by using education, pre-hearing mediation, higher but not prohibitive fees, and establish set costs for delays and lost appeals.

Residents should have a right to told what real estate developments are being proposed for their communities and municipalities or developers should be required to notify local residents.

Please remove the elimination of aesthetic architectural requirements for new buildings in the Bill. There should be minimal, aesthetically pleasing, architectural treatment standard for new buildings, beyond the basic structural requirements of Ontario’s Building Code.

The Bill should be amended to retain municipalities’ ability to set green standards that include limits on energy intensity and greenhouse gas emissions for new buildings to help Ontario and Canada meet our climate change mitigation/reduction targets.

Amend Bill 23 by deleting in Schedule 1 “(2) Subparagraph 2 iv of subsection 114 (5) of the Act is repealed” and delete in Schedule 9 “(2) Subparagraph 2 (d) of subsection 41 (4) of the Act is repealed”. Replace those two sections with the following wording in both Schedules:
• (d) matters relating to sustainable design if an official plan and a by-law passed under subsection (2) that both contain provisions relating to such matters are in effect in the municipality.

While some authority could now be reduced for minor development applications, where a municipality could provide this against set criteria through their existing building departments, CAs should be allowed to protect and designate wetlands and formally provide advice to Municipalities through agreements for CA services.

Money for Bill 23 compliance costs Bill should be provided by the local real estate developments or the Province, rather than being added to the residential tax base.

New developments should be required to provide equal cost rental replacement units for people displaced by a demolition.

Create clearer planning ground rules to educate residents groups about the Government’s development goals.