As a concerned and committed…

As a concerned and committed citizen of Ontario, I appeal to our provincial government to repeal Bill 66 and leave in place theToxics Reduction Act, 2009.

If enacted, Bill 66 would roll back the legislative provisions that safeguard environmental quality and public health and safety throughout Ontario, and would leave citizens susceptible to a declining quality of life and to unreasonable increases in municipal taxes.

Repealing the Toxics Reduction Act, 2009 (TRA) is a terrible idea. The TRA is not duplicative of requirements under federal law on control of toxic substances. Repealing the TRA would undermine drinking water protection rules and gut rules that help industry reduce the release of toxic chemicals. I support the Canadian Environmental Law Association (CELA)'s Submissions on Bill 66, Schedule 5 (TRA Repeal) to Michael Friesen of the Ministry of the Environment, Conservation and Parks. With Ontario’s emissions of toxic substances to air, land, and water being some of the highest in North America, we should leave the TRA in place.

The exemption of "Open for Business" zoning bylaws from key environmental protection laws, plans and policies, including the Clean Water Act, Great Lakes Protection Act, Lake Simcoe Protection Act, Metrolinx Act, Oak Ridges Moraine Conservation Act, Ontario Planning Development Act, Places to Grow Act, Resource Recovery and Circular Economy Act, puts public health and safety at risk. Our government proposes to further endanger citizens by also exempting these “Open for Business” bylaws from public notice, comment and appeal provisions in the Planning Act. Ontario must not override environmental protection laws, and citizens must retain their right to comment and appeal.

Bill 66 opens up Ontario’s Greenbelt for factory, retail and residential development, just when people are realizing that global warming makes Ontario’s farmland a rare global resource that is becoming more valuable over time. At a time when Ontario needs forward-thinking government action, Bill 66 basically takes us back 40 years.

With regard to factories and stores, it is inconvenient and expensive to build them in the greenbelt. Employment lands should be located within urban boundaries close to infrastructure that supports businesses. Allowing employment uses in the greenbelt or other protected lands, as the Open for Business bylaws would allow, would put a huge burden on municipalities and utilities to provide services and upgrade roads. These services are expensive and building them will cause property tax increases and make it even harder to build public transit.

The Open for Business bylaws would allow developers to use their considerable financial influence to compel municipal officials to make planning decisions detrimental to their constituents. We already have enough well serviced land within urban boundaries to meet development needs of businesses and housing providers. As part of the Ontario government’s housing consultation, the province is asking whether there should be more flexibility regarding the conversion of existing employment lands in urban areas to residential development. Some municipalities have identified surplus lands for new employment uses. In cities like Kitchener and Hamilton where factories have shut down there may be an excess of serviced employment land near new transit lines where conversion makes sense. In some newer greenfield communities, developers own unserviced employment lands they want to build subdivisions on. Ontario does not need to convert protected lands to factory, retail or residential development and it would be a waste of money and of opportunity, to do so.

It’s important for municipalities to do the analysis to understand if there is enough employment land for complete communities or an excess of land. The Growth Plan employment land policies move us towards complete communities where people can live, work and play. If conversion of employment lands proceeds as part of the housing reforms that come out of the current provincial consultation underway, municipalities may be permitted to rezone employment uses approved under the Open for Business bylaw to residential.

As a result there is no demand or need for new lands to be designated for “business” on the Greenbelt, in the Lake Simcoe watershed or on the Oak Ridges Moraine. We can just use the surplus employment lands in towns and cities across the region.

Finally, the province already has the Minister’s zoning order (MZO) which gives it the power to override local planning rules and designate land for development if they want to use it. By proposing that the new “Open for Business bylaw” be implemented by municipalities the province is trying to distance itself from the scrutiny, criticism and accountability that it would normally face when using the MZO. It also increases the number of likely development proposals that will come forward as the development industry is very influential and often funds election campaigns at the municipal level.

Breaking the promise not to open up the Greenbelt, Lake Simcoe Watershed, the Oak Ridges Moraine and source water protection areas to new development shows a fundamental disrespect to voters. The health of our region depends on valuing our farms, forests, clean water sources and nature and building robust and vibrant communities. Bill 66 is damaging to the health of Ontario citizens and our environment.