Subject: Invitation to…

Subject: Invitation to Public Comment - The Ministry of Municipal Affairs and Housing,Environmental Registry of Ontario (Notice 019-2811)
Dear Minister Clark:
Thank you for the opportunity to comment on the changes enacted through Bill 197, the COVID-19 Economic Recovery Act 2020, that was passed on July 21, 2020.

We are very strongly opposed to the changes enacted under Bill 197, specifically with regard to the enhanced powers granted to the Minister of Municipal Affairs and Housing to unilaterally remove municipal use of site plan control, require agreements between the municipality and development proponents concerning site plan matters, and make amendments to Minister’s Zoning Orders that use any of these enhanced authorities without first giving public notice or requiring public consultation.
These enhanced powers must be repealed and the power to determine the site plan controls returned to the municipalities. Further, and most importantly, no development should be allowed to take place in Ontario without the meaningful engagement and democratic consent of the people. These conclusions are confirmed and justified by the Federation of North Toronto Residents’ Associations (“FoNTRA’) in its 16 October 2020 letter to you regarding Minister’s Zoning Orders. The FoNTRA letter contends that “the current use of Minister’s Zoning Orders…undermines the legitimacy of the statutory planning system. By stripping provisions for notices, public meetings, and rights of appeal from the zoning process …the MZOs do not do so much as cutting red tape as purging ordinary citizens from the democratic planning process” and reasonably concludes, asking “the government to confine the use of MZOs to extraordinary situations arising from the pandemic and to swiftly discard the recent wide-spread and undemocratic enhanced approach…without notice, without public consultation, and without the right of appeal.”

Clearly, the process which has led to the zoning and MZO approval of the Xinyi Glass Factory in Stratford is a prime example of how the MZO process can result in failure to provide for and include tribal and local community involvement in the public vetting and approval process for a highly complex, energy intensive facility, a continuously peak operational facility by necessity, which will have the potential to present unforeseen sustainability demands and impacts, both direct and indirect, on what is already an economically successful small community which enjoys a stable, very unique and reknown international cultural attraction in the Stratford Festival and its venues.

Sincerely Yours,