There are many reasons why I…

There are many reasons why I am opposed to Bill 66. In brief, these are outlined in a Region of Waterloo report, including the following:

· Lack of prescribed consultation;

· Risks to health, safety and the environment, including groundwater protection;

· Non-applicability of Provincial and Municipal plans and policies…

Municipal councils in the Region of Waterloo have overwhelmingly stated their opposition to Bill 66 in its current form.

That opposition is based on the provision that a municipality can pass an Open for Business bylaw. If such a bylaw is passed, there would be:

· no need to follow planning documents that have been created over many years;

· no requirements for public consultation;

· no appeal could be made against any municipal act

The impact on the future of our cities, our countryside, our natural resources, and on cultural and natural heritage is clear. These are outlined below.

1. Impact on Planning

If a municipality passed an exemption under Bill 66, zoning by laws would not need to conform to any official plans. Site plan approval would not be required. There would be no protection to the natural or built environments. Famous structures that attract tourists from around the globe could be flattened. A municipality could demolish any building or cultural feature it wanted. A bylaw could be passed that is exempt from all planning and environmental law such as the Planning Act, Places to Grow Act, and the Planning and Development Act. The planning process is out the window and there is no appeal process.

2. Impact on the Environment

Urban growth tends to be expansive rather than focused on the existing land that has already been developed in urban areas. We need to resist that tendency to sprawl, thus putting our agricultural and forest resources at risk.

More than half of Waterloo Region's growth comes from building in existing urban areas. This investment in our urban centres means we can keep growing while preserving the rural communities and farms that make Waterloo Region unique. This is not a short-term concern. We need to protect farmland and natural areas from urban sprawl. Farmland, cultural and natural landscapes provide urban dwellers with respite from stress. Natural environments provide us with clean water and clean air. These are qualities that have made Ontario a wonderful place to live, work and play.

3. Impact on Heritage

The impact on built heritage and cultural landscapes is obvious since Bill 66 circumvents planning by municipal government. There are many examples where protection of our built heritage has been put at risk despite good planning. An Open for Business bylaw could bypass the Planning Act and Provincial Policy Statement. The latter states clearly that "Significant built heritage resources and significant cultural heritage landscapes shall be conserved."

The bill also impacts on archaeological heritage. Ontario has a rich history of occupation that dates back at least 12,000 years. The archaeological assessments completed each year in advance of development help fill in the gaps in the story of our province, Indigenous Peoples and more recent settlers.

Archaeology gives a voice to many who have been written out of the history of our province. Indigenous and descendant community participation in the process of archaeological investigation has recently amplified that voice. Bill 66 threatens to allow municipalities to opt out of the research that comes from excavations prior to construction.

The Ontario Archaeological Society has stated clearly: “Under Bill 66, a municipality will be able to circumvent… the Provincial Policy Statement… and Official Plan requirements…. The protection of heritage is a mandatory provincial interest under the Ontario Heritage Act, not a decision of convenience at a municipal level. Bill 66 needs to be amended to restore the requirements that protect our heritage for the generations to come.”

The Architectural Conservancy of Ontario has stated that Bill 66 would allow the development of major employment and economic growth opportunities. We could see many more demolitions of heritage buildings. In the past, demolitions have taken place despite protections, including Carnegie libraries, fire stations, city halls and other valuable buildings of historic and cultural significance. Should a builder decide to demolish an historic building, under an Open for Business bylaw, there would be nothing anybody could do to protect it.

Under Bill 66, the lack of heritage protections would mean that we further write out of our history the richness of Indigenous Peoples as well as those settlers whose descendants form a majority of today’s population.

Bill 66 puts the cultural and natural landscapes of Ontario at risk. I ask that you reject this bill in its current form.