I am concerned that Bill 17…

Numéro du REO

025-0462

Identifiant (ID) du commentaire

149417

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Individual

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I am concerned that Bill 17 will slow down the process by creating unnecessary complications and will undermine municipal oversight by restricting their ability to safeguard urban design elements like flood protection, air quality, and energy efficiency. It also eliminates critical checks and balances by mandating automatic approval of development submissions from prescribed professionals, removing municipalities' essential role in protecting public health, safety, and environmental well-being.
Municipalities have a responsibility to oversee urban design in their own jurisdictions
Bill 17 prohibits municipal bylaws relating to construction to speed up project timelines, however, it
introduces new risks and unintended consequences. The language is so broad that it could invalidate
numerous existing bylaws in communities across Ontario, including ones that are critical for health and
safety. For example, it could overrule bylaws that limit heavy construction overnight in residential
neighbourhoods, that prevent homes being built next to industrial plants with pollution beyond regulated limits,
or that prevent tall buildings in the flight paths of hospital air ambulances.
Furthermore, by stipulating that submissions prepared by prescribed professionals be automatically
accepted as compliant with all requirements, Bill 17 effectively transfers planning approval authority from municipal staff to consultants hired by developers. This eliminates key checks and balances in the system, increases risks and liabilities, and creates unnecessary conflicts of interest for designated professionals.
It is essential for the interests of all parties, including the public interest, that development documentation be subject to independent review by qualified individuals at arms-length from the project, such as municipal staff.
Green development standards are essential tools for affordability and sustainability
Municipal authority to enact proven, performance-based green development standards should be made
clear. Green standards ensure buildings are efficient and address extreme weather and climate change.
These standards complement, rather than conflict with, the Ontario Building Code, and there is no
evidence they slow down housing. In fact, Toronto, with its ambitious standards, has seen more
development in recent years than any other city in North America. While green standards add minimal
upfront costs, they enhance long-term affordability and reduce municipal infrastructure expenses.
Without them, future homeowners will certainly face higher utility costs, and city budgets will be further
strained.
Builders need clarity and predictability to build faster. The proposed legislation makes sweeping changes to the role of municipalities in development planning
and potentially invalidates a wide range of existing bylaws across Ontario. The bill as drafted risks creating confusion and disorder, as both municipalities and developers work to understand the implications and adjust policies and procedures. This could lead to housing project delays and exacerbate challenges with land speculation that worsens affordability. Stripping municipal authority to review development submissions also risks increasing the number of disputes at the already overloaded Ontario Land Tribunal.
If a submission from a prescribed professional is unclear or fails to adequately address a requirement,
municipalities may be forced to rely on legal challenges, creating new uncertainty and delays. Rather than accelerating development, these specific changes could have the opposite effect.

I suggest the following changes to Bill 17:
1. Allow municipalities to enact green development standards and bylaws related to construction or
demolition, provided they do not conflict with the Ontario Building Code.
2. Ensure clarity in the legislation and consistency with the Provincial Planning Statement to support
predictable and fair planning processes.
3. Protect public interest and minimize risk by allowing municipalities to continue conducting
independent review of development submissions.