Dear Conservative government…

Dear Conservative government:

You make it difficult to make specific comments on your proposed legislation when your wording is so vague. While you may claim (after the commenting period has closed) that there was a public consultation period and that there were "few objections", a single month to comment on a wide range of legislative changes that are vaguely worded is insufficient and very UNdemocratic!

Your published goals for bill 108 (Schedule 12) are:

"
* Streamline development approvals processes and facilitate faster decisions
* Increase the certainty and predictability of the planning system
* Support a range and mix of housing options, and boost housing supply
* Address concerns about the land use planning appeal system
* Make charges for community benefits more predictable; and
* Make other complementary amendments to implement the proposed reforms, including in relation to transitional matters."

With respect to

* Streamline development approvals processes and facilitate faster decisions
* Increase the certainty and predictability of the planning system
* Address concerns about the land use planning appeal system

To achieve these goals, you only speak vaguely of increasing ministry powers, forcing shorter periods of time for approvals by municipalities and limiting or removing rights of appeal. Measures such as these do not address problem areas in meaningful ways. They are all measures that limit or prevent dissenting voices from being heard and their opinions considered. Efficiencies that limit democratic rights and processes are not acceptable!

With respect to

* Support a range and mix of housing options, and boost housing supply

Your only mention of this in the body of the proposal is:

"by requiring municipalities to authorize an additional residential unit in both the primary dwelling and an ancillary building or structure."

While, again, quite vague, this seems like nothing more than allowing municipal dwelling construction bylaws to be ignored. Zoning laws have a purpose. If you are truly interested in providing a mix of housing options then there are many better options to consider than simply removing bylaws. Removing bylaws will have clear consequences beyond the goals you state. What, for instance, will stop someone from using their newly constructed residential unit as an AirBNB rental!

With respect to

* Make other complementary amendments to implement the proposed reforms, including in relation to transitional matters

This is so confusing and vague that comment is impossible.

Finally, with respect to

* Make charges for community benefits more predictable

You provide a couple of details and, indeed, such a change would make the charges more predictable. Unfortunately, it is clear that they would also make the charges to developers inappropriately low and not proportional to the impact of the development on the community. Predictability of the charges, even if complex, can be achieved (if, indeed, that is a current problem) without changes that effectively remove the intended purpose of the community benefits charge. Inappropriately low community benefits charges force the community costs of developments onto municipalities which, in turn, will be paid for by taxpayers.

My overall impression of your proposals is to be cynical. It appears that your overall goals are to increase Provincial powers, make land developer's lives easier, and push the consequences of those easier land development processes onto the public and the municipalities. Your "efficiencies" will almost entirely benefit land developers (all at the taxpayers expense), and your plans to implement these changes will cripple existing bylaws and rules meant to encourage consistent, livable spaces.

Is this part of your "Plan for the People"?