Dear Mr. Helfinger, RE: 013…

Dear Mr. Helfinger,

RE: 013-4293 Bill 66: Restoring Ontario’s Competitiveness Act, 2018; 013-4125 Proposed open-for-business planning tool; 013-4239 New Regulation under the Planning Act for open-for-business planning tool

I strongly oppose several aspects of Bill 66, Restoring Ontario’s Competitiveness Act, 2018. I disagree with the Government of Ontario’s contention that Bill 66 cuts “unnecessary” and “out of date” regulations (ERO posting 013-4293). This is not true in the case of Schedule 10 which introduces “open-for-business by-laws” that would trump critical requirements under several laws that are designed to protect water, natural heritage and human health and well-being and to ensure fair, consistent and transparent public engagement in land-use decisions.

My concerns, in line with and supportive of Ontario Nature, and their ERO submission, are below and I trust that they will be considered with respect to all three relevant ERO postings (i.e., 013-4293, 013-4125, 013-4239).

- Open-for-business by-laws would circumvent fundamental protections for environmental and human health.

- The potential negative impact of open-for-business by-laws is far-reaching and profound. They would override key operative provisions in the laws listed in Schedule 10, undermining fair and consistent application of laws and policies designed to protect drinking water, natural heritage, farmland and watershed health across Ontario, and leaving communities open to unchecked development.

- Open-for-business by-laws would eliminate opportunities for public input on planning decisions. By-laws passed behind closed doors would trump laws, policies and municipal official plans developed through extensive and open public consultation. Communities would have no recourse to influence or challenge them.

- I question whether there is demand from municipalities for open-for-business by-laws, proposed by the government to make more employment lands available. At the Growth Plan implementation consultation held on November 8, 2018 at Queen’s Park many municipalities indicated that they have a surplus of employment lands. Since the introduction of Bill 66, many municipal leaders (e.g., in Guelph, Aurora, Burlington, Barrie, Oakville, Hamilton, Toronto) have expressed serious concerns about open-for-business by-laws and the circumvention of laws that protect drinking water, farmlands and natural areas and ensure public input and transparency in decision-making.

- Schedule 10 of Bill 66 would turn back the clock on many years of good planning, community input and strong leadership from governments of all political stripes. Open-for-business by-laws would sidestep laws and policies intended to protect the long-term health and resilience of our communities and would facilitate sprawling and unchecked development, threatening sensitive natural features and water resources upon which we all rely. Bill 66 would undermine everything we have learned – sometimes under tragic circumstances – about how to protect our environment and the health of our communities.

I urge the government to avoid similar mistakes and to remove Schedule 10 from Bill 66.

Sincerely,

Cara Gregory
Lake Ontario North Regional Director
Ontario Nature