Site plan review is an…

Site plan review is an important planning process that contributes to a thriving, livable city with a
healthy economy. It ensures that the public interest is considered in a new development proposal, and
that development makes a positive impact on the street, the block, the neighbourhood, and the city.
Building homes is not only about the bricks and mortar of housing, but also about the planning and
design of safe, healthy, sustainable, vibrant, and socially integrated communities -- the places where
neighbours come together; where children play and where elders walk and take tea. It takes a Village.
Establishing these complete communities is especially important where new housing and
intensification are proposed in built up areas to avoid sprawl development. In this regard, there has
been considerable discussion among professionals about the Bill’s proposal to remove site plan
control completely for any building with fewer than 10 units. Proposals for infill housing, even those
with less than 10 units, need to be well integrated within already established neighbourhoods. The site
planning process is meant to secure the attention to design needed to achieve these ends.
The amendments to the site planning process in Bill 23 will not deliver high quality development that delivers excellence in design when municipalities are not in a position to ensure it. I am concerned about a planning strategy that puts aside a process for high quality urban living at the site and neighbourhood level without including an alternative means for its delivery.
I am concerned that the proposed amendments eliminate exterior design and building materiality
matters from the site planning process which are critical to building great communities. These elements frame, define and contribute to the character of the public realm. The scale, type and quality of materials, and design articulation greatly influence the quality of the experience for the public and residential neighbours including the beauty and microclimate of the public realm.
The review of exterior sustainable design features allows municipalities to require Green Standards
and achieve important climate mitigation and adaptation site details so critical for the future of our
neighbourhoods.The Bill also limits the ability of municipalities to secure sustainable design features related to the 'appearance' of the streetscape unless the appearance impacts matters of health, safety, accessibility or the protection of adjoining lands.
My concern is that if passed, this amendment would weaken design excellence and in so doing
contribute to a reduction in the overall quality of life, as well as the health and safety of users, and the
sustainability of our shared environment.
Bill 23 is also proposing changes to how much parkland will be provided, and how parkland is provided
for new development especially with intensification. The proposed amendments affect location and
configuration of parkland dedication, stripping these matters from municipal responsibility, leaving
important land use decisions to private interests that may not always be aligned with public interest or
community needs. Parkland rates are being reduced while density is being increased. Restrictive
timeframes for cash-in-lieu of parkland funds expenditure are proposed which would limit municipal
negotiation and park planning horizons. When new development is being planned, municipalities will
have to purchase parkland separately. This would reduce a municipality’s ability to secure parkland per
development. Taken together, I am concerned these proposed changes adversely affect the quantity
and quality of parkland dedication and community green space both locally and regionally.
During the recent COVID-19 pandemic, the value of our shared public realm of parks, streets and open
spaces to the physical and mental health of individuals and communities has been experienced and
proven. Affordable housing should not come at the expense of our shared public and civic spaces.
I ask that further investigation of parkland provision be undertaken to ensure that sufficient and
appropriate healthy green spaces that support both increased population as well as the natural and
cultural environment be considered and incorporated into any Affordable Housing strategy to ensure
that all neighbourhoods gain the maximum benefit for a protected park land base and cash
improvements for the future. We need to continue to make long-term plans for much needed outdoor
amenities for our diverse and growing population.
Proposed Bill 23 amends the Conservation Authorities Act by reducing Conservation Authorities’ (CA)
role and responsibilities in safeguarding the natural environment and also the funding that supports
them. I am committed to stewardship of the environment, considers that the
proposed changes work against Ontario’s essential environmentally responsible legislative framework
in place since 1954’s Hurricane Hazel devastated homes and landscapes. The Conservation Authorities’
role in protecting wetlands, forests, riverways and shorelines, preserving natural areas, habitats and
groundwater systems, and supporting environmental stability and resiliency cannot be underestimated
in an era already experiencing the impacts of climate change.
I, in the interest of protecting the environment, have a serious issue with the Bill’s reduction to
the CA’s role and responsibilities. The amendment has far-reaching consequences not only for
potential damages to natural environment systems with the attendant impacts on surrounding lands,
but also, to the community's expectations for wise management of landscape and environmental
resources that the CA’s provide. I am concerned that there is no other body organized and
capable of this task to protect the public interest in reducing risk and ensuring the health of the natural
environment. I urge the Minister to reconsider this aspect of the Bill.

The public interest is the basis for the work done within our profession. While I applaud the
Province’s efforts to address the current housing crisis, our members remain concerned Bill 23, as
currently proposed, will have consequences which threaten the important matters of health, safety,
and well-being of our communities, our environment, and our future.
I recognize that a successful housing strategy with affordability at its root contributes to Ontario’s economic health and boosts its competitiveness in attracting business and a highly skilled labour force. As a steward of the environment, I also appreciate the importance of protecting the land, resources, community, and its diverse peoples as important to our economic future. It is our hope that amendments to the legislative framework meant to bolster our housing needs will be balanced with the fulsome regard for all the needs of our complex society.