RE: Ontario Greenbelt…

RE: Ontario Greenbelt Alliance Submission on Bill 108, ERO 019-0017 and 019-0016

Thank you for considering our submission on Bill 108. The Ontario Greenbelt Alliance represents over 120 groups across the Greater Golden Horseshoe. With a short four week submission period and a quick three day turnaround for the Bill (June 1st submission date) many of our members are unable to make submissions. Between the June 1st submission date and the proposed June 4th time allocation date for the Bill the Alliance is concerned that the government will not have time to fully consider our submission and make the necessary amendments to balance the need for low cost housing with local government autonomy, a protected environment and continued citizen involvement in community planning. We encourage the government to defer the vote on Bill 108.
The More Homes, More Choice Act amends 13 pieces of legislation with the intent to make it easier to bring affordable housing to market. As written the Province’s Housing Supply Action Plan and Bill 108 do very little to increase the supply of affordable housing (ie. housing for the 20th-60th household income percentiles). For instance, it is highly unlikely that developers will pass along any cost savings from building new homes onto consumers. Instead taxpayers will be subsidizing developers. In certain instances the proposed legislation is directly contrary to increasing the supply of affordable housing, such as restricting the use of inclusionary zoning only to major transit stations. Even the proposed deferral of development charges for rental apartments is of questionable benefit given virtually all new rental units (apart from government subsidized units) are luxury units. Going forward to provide needed housing the province will need to continue to subsidize community housing for vulnerable people.

Ontario Greenbelt Alliance members are generally YIMBY’s (yes in my backyard). We have been supportive of encouraging a diversity of housing to provide housing for seniors and low-income Ontarians to create complete communities. Rather than moving forward to support affordable growth many of the changes in Bill 108 are aimed at increasing the supply of single detached houses. Yet, single detached homes are the most expensive type of housing for new homebuyers and they also are more expensive for municipalities to service.
Perhaps most discouraging is that Bill 108 affirms many of the recommendations made by the development industry. The Bill does not satisfy other business interests including farmers. Collectively, these changes increase municipal debt, reduce citizen and municipal input, control and restrict appeal rights. Bill 108 increases the burden on municipal taxpayers from lower phased in development charges and increased debt. For example, deferring development charges on commercial and industrial development projects requires taxpayers to subsidize developers and business. Increasingly Ontario has been moving to a funding model for new development that requires growth to pay most of its share of capital costs. This model has enabled our communities to have parks and community facilities ready for new residents without burdening existing residents with increased costs. Moving away from this model, capping fees that support sustainable growth, reducing parkland in cities will reduce the livability and prosperity of new communities.
Other amendments severely reduce long held protections that support the health and prosperity of our communities and natural areas such as restricting and limiting Conservation Authority oversight, the Environmental Assessment Act, the Endangered Species Act and the Ontario Heritage Act. There is a lack of transparency in Bill 108 as it includes significant new authorities to impose future restrictions by ministerial driven regulations that are unknown at this time. Further time is needed to understand and comment on the impact of these proposed changes.
The proposed amendments to the Planning Act regarding the Local Planning Appeals Tribunal gives developers an upper hand, diminishes the important role of our elected officials in managing growth and development and limits the ability of citizens to participate in a meaningful way. Returning to OMB rules will result in housing delays and higher prices the opposite of the governments intention, to speed up and lower the cost of new housing.
The majority of the changes in Bill 108 are supported by the development industry only. Many municipalities are requesting a deferral or oppose Bill 108. To date, local and regional municipalities including Burlington, Halton, King, York Region, Kingston, Oakville, Aurora, Brant, Guelph, Hamilton, Archipelago and Lennox-Addington have voiced issues with the bill. At this time, many citizens are unaware of how the Bill will affect their community and their taxes.
The Ontario Greenbelt Alliance encourages the government to provide more time for municipalities and stakeholders to comment on Bill 108. We urge the government to seriously consider how these changes will affect the health and prosperity of communities across Ontario.