My comments are with respect…

My comments are with respect to the following component of Bill 185:
"Exempt publicly-assisted universities from the Planning Act and planning provisions of the City of Toronto Act, 2006 for university-led student housing projects on- and off-campus."

I am deeply concerned about the proposal to exempt universities from the Planning Act and City of Toronto Act. The government has not presented any justification or evidence to indicate how this exemption will lead to on and off-campus housing projects being approved and built faster. I am not convinced this will have the intended effect because compliance with the Acts is not "red tape" leading to delays. Most municipalities that have universities within their boundaries are already prioritizing streamlining applications to build housing, particularly high-density housing and rental units. Professional planners working with universities on such projects are accustomed to complying with municipal requirements under the Planning Act and City of Toronto Act (e.g., site plan approval) and are encouraged to submit components of an application in a timely fashion to avoid delays.

Exempting universities from the Planning and City of Toronto Acts carte blanche, as proposed in Bill 185, could have serious unintended consequences. First, the language of Bill 185 is too vague for consistent interpretation. It says the exemption applies to "university-led student housing projects on- and off-campus". What about the servicing that will be required for those new housing projects? What about the creation of new roads, parking lots, or parkland dedications associated with the projects? What about the applicability of property standards and tree protection by-laws that municipalities derive their authority from through the Acts? It is unclear how the proposed exemption will apply to these and other aspects of planning to support new housing units.

Municipalities that encompass university campuses must not be cut out of campus growth planning. The Acts provide authority to municipalities to approve developments that is necessary to ensure new housing projects align with local regulations and plans and to limit potential negative impacts to surrounding near-campus neighbourhoods. Planning increases in density on and near campuses associated with new housing developments will need to be accounted and compensated for in other aspects of municipal growth and servicing, such as changes to transit routes and road widening.

I am concerned that exempting campus developments from site plan control will result in adverse outcomes and conflicts. I am not confident that planners employed by universities to work on specific housing projects can provide all of the necessary technical background and familiarity with the surrounding municipal planning context. By siloing university housing projects from municipal planning processes, this exemption will lead to projects being approved without considering the complexities of how housing interfaces with neighbourhoods. These projects may be less successful in accounting for the quality of life of people who will live in the housing in the future.

For instance, if exempted from the Planning and City of Toronto Acts, universities would no longer be required to comply with Green Development Standards enforced through municipal site plan control to limit climate risks such as buildings overheating or greenhouse gas emissions exceeding municipal climate change targets. Buildings constructed without site plan approval may compromise natural heritage features on and surrounding university campus grounds, without oversight from municipal staff ecologists. Poorly-situated developments could make it more difficult for municipalities to provide services like waste collection and access to public transit, and lead to myriad public safety concerns such as access for emergency vehicles. Campus developments that interact with natural hazards such as flooding may not consider mitigative measures that are often implemented through municipal site plan control.

I urge the government not to exempt universities from the Planning Act, and to instead address the real causes of housing supply shortages by implementing the remaining recommendations of the Housing Affordability Task Force report.

https://www.ontario.ca/page/housing-affordability-task-force-report

University campuses can continue to build more housing for students, but approvals of housing need to be kept within the purview of municipal planning authority.