Concerns Regarding Bill 17 –…

Concerns Regarding Bill 17 – Protect Ontario by Building Faster and Smarter Act
ERO Number 025-0461

Dear Minister Flack,

South Junction Triangle Grows (SJTG) is a Toronto-based community group advocating for responsible, community-centered urban development. We work to ensure that new housing and infrastructure projects balance affordability, smart planning, and respect for the local environment and residents. We appreciate the government’s efforts to address housing challenges; however, we have significant concerns regarding Bill 17. Our concerns are outlined below.

1. Erosion of Municipal Planning Authority
Bill 17’s provisions requiring ministerial approval for changes to official plan requirements for complete applications undermine local autonomy. Municipalities possess the contextual knowledge necessary for effective planning, and this shift could lead to one-size-fits-all solutions that may not suit local needs. The Ontario Land Tribunal already
erodes local authority, as noted in a recent Office of the Ontario Auditor General report. Bill 17 will only deepen this problem.

2. Overemphasis on Speed Over Quality
While accelerating development is important, the bill’s focus on speed may compromise the quality and sustainability of housing projects. Eliminating requirements for studies such as sun/shadow, wind, urban design, and lighting could result in developments that negatively impact communities, not build them for the long-term.

3. Insufficient Affordable Housing Measures
The bill lacks robust mechanisms to ensure the development of genuinely affordable housing. Without clear mandates or incentives for affordable units, there’s a risk that the accelerated developments will not address the needs of low- and moderate-income residents. This needs to be addressed immediately.

4. Enhanced Ministerial Powers Without Adequate Oversight
Expanding the Minister’s authority to impose conditions on MZOs without sufficient checks and balances raises concerns about transparency and accountability in the planning process. SJTG argues this will simply cause more legal challenges.

Additional Concerns
While Bill 17 emphasizes the importance of accelerating housing near transit, SJTG notes that this approach overlooks several critical realities. First, the bill lacks meaningful attention to social or deeply affordable housing, instead facilitating primarily profit-oriented developments.

Second, while transit-oriented development is important, people still rely on cars and trucks for everyday movement and goods delivery. These needs are not adequately addressed.

Finally, we urge the government to focus on completing major transit projects before greenlighting high-density developments that depend on those systems; otherwise, communities will face congestion and service gaps without the promised benefits.

While the government claims Bill 17 responds to municipal needs and accelerates housing delivery, past initiatives have failed to meet housing targets, even after rule changes that counted long-term care beds as housing starts. Without stronger affordability guarantees and support for medium-density, community-appropriate housing, this bill risks repeating the same mistakes: benefiting developers without meaningfully solving Ontario’s housing crisis.

Recommendations
Maintain Municipal Autonomy – Allow municipalities to determine complete application requirements without mandatory ministerial approval. Municipalities understand their own local needs best.

Ensure Comprehensive Planning – Retain requirements for essential studies to maintain the quality and livability of developments. Removing these requirements is illogical and does not lead to “smarter” outcomes.

Strengthen Affordable Housing Provisions – Incorporate clear targets and enforceable requirements for affordable housing units in new developments. This is absolutely essential.

Implement Oversight Mechanisms – Establish transparent processes and oversight for the use of MZOs to prevent potential misuse.

We urge the government to reconsider the provisions of Bill 17 to ensure that the goal of increasing housing supply does not come at the expense of thoughtful, community-centered planning.

Sincerely,
South Junction Triangle Grows