Commentaire
To: Standing Committee on Heritage, Infrastructure and Cultural Policy
Re. Serious Concerns about Bill 23 in relation to impact on food security
Date: 4 December, 2022
False Dichotomy
In Bill 23 the Ontario government is proposing to address a crisis in housing by stripping
away measures that place any constraints on uncontrolled urban development and
protect our non-renewable land resources—including farmland, wetlands, greenspaces
and foodlands. This destroys, in one omnibus bill, the balance formed through a
decades-long negotiation over sound policy.
The predictable, long-lasting consequences of this open assault rest on a falsehood:
that we have to choose between protecting the land and building housing. Groups
across Ontario, including groups focused on food and farming, have long presented
reasonable, evidence-based options that demonstrate how we can both provide
needed, affordable housing and conserve lands that are essential to build sustainable
communities across the province.
In fact, many of the principles underlying the relevant existing policy structure and
regulations (e.g the Provincial Policy Statement, Growth Plan) have worked toward the
essential balance between housing and conservation—a balance that we must find in
order to build sustainable communities.
Communities have presented better solutions for More Housing, Faster
We in our communities have the knowledge of how to build housing and protect
farmland and the environment. Our local leaders have spoken about the type of
inclusive neighbourhoods that use both intensification and inclusionary zoning targets
to build with balance in our communities.
A shortage of land isn’t the cause of the problem. Land is available to meet projected
targets inside municipal boundaries. Local, grassroots, informed organizations have
identified strategies to build more houses, faster in our communities, in a way that
supports our communities—with livable neighbourhoods for all, meaning greenspace
and agriculture spaces maintained in urban, suburban and rural neighbourhoods.
The shortage is in political will. Bill 23 places unnecessary constraints on useful tools
like inclusionary zoning, purposefully removing solutions that have been tested in
communities throughout Turtle Island—where most communities have found benefits
are achieved in the 10-15% range, not the 5% this Bill enforces. This Bill has to centre
the solutions that maintain multiple benefits to our communities.
Food Security Requires Affordable Housing
When housing is not affordable, families must move further away to find housing they
can afford, often in low-density communities with inadequate, expensive transit
infrastructure required to be built, that is not sustainable as density is required for
affordable transit. This escalates urban sprawl, paves over more natural spaces and
foodlands and increases carbon emissions. Urban sprawl solutions also means getting
to food is harder to achieve.
Bill 23 makes housing less affordable by:
Removing rental replacement requirements;
Reducing municipalities’ capacity to pay for affordable housing through development
costs;
Allowing developers to create less affordable housing, by lowering limits on inclusionary
zoning (to only 5%) and using a market-based definition of “affordable” housing
Bill 23 also guts green building standards, which instead need to be enhanced to
include food production. Housing and food security must be planned for together.
Food Security Requires Access to Land
Individuals and Families are increasingly needing to choose between rising costs of
housing and rising costs of food. The continued rising cost of food shines a light on the
urgent need for both affordable housing and to protect all foodlands and farmlands as
key components of our current and future food security.
Disruptions to long food supply-chains, increased transportation expenses, crop failure
in other parts of the world, and the need to limit our use of carbon-based fuels, require
us to increase our food security by deepening our access to sustainably-produced,
locally-grown food.
Relying heavily on urban sprawl as a solution, instead of densification, whittles too much
of the already small share of land devoted to local agriculture.
In an urban context, Bill 23 means developers will be required to provide less
greenspace—meaning fewer opportunities for urban food production and food forests,
all part of building community food resilience, with food of choice.
Food security requires Conservation
Throughout Ontario, when we say Bill 23 has a negative impact on the environment, on
lands, on waters - we are identifying a negative impact on food security and on food
sovereignty.
Food is grown, harvested, and processed in our communities, from the land, the waters,
the forests—with our continued food security resting on us doing this in a sustainable
manner.
Despite daily acknowledgements that Ontario rests on Indigenous lands, under treaty or
unceded, the Indigenous principles of conservation of lands, and of sustainability for
seven generations forward, are not part of this Bill.
Allowing “offsets” for wetlands and woodlands through developer fees will be an
ecological disaster that will stretch into our farmlands, impacting the ability of our farms
to provide ecosystem services over the long term. In the face of a rapidly changing
climate and uncertain seasonal weather patterns, the disruption of complex wetland
systems can have massive impacts on above- and below-ground waterways, and the
production potential of adjacent agricultural lands.
Bill 23 also eliminates the ability of conservation authorities to protect watersheds and
greenspaces, by eliminating their ability to holistically manage watershed resources.
Many of the duties of Conservation Authorities are being dumped into the laps of
municipalities—without the resources and expertise to effectively carry out those
responsibilities.
Food Security Requires Farmland Protection
Permanently protecting agricultural land in the province is crucial—once it’s lost to
development, it is gone forever. Disruptions to long food supply-chains, increased
transportation expenses, crop failure in other parts of the world, and the need to limit
our use of carbon-based fuels, require us to increase our food security by deepening
our access to sustainably-produced, locally-grown food.
While this legislation pays lip service to the need for farmland protection, Bill 23 will
instead:
accelerate farmland grabbing, placing more non-renewable farmland under the control
of speculators and developers;
re-zone thousands of acres of prime farmland to allow for development;
increase land prices—something that new and young farmers can not afford—and
increase the cost of producing food locally;
eliminate agricultural systems mapping and impact assessments, critical tools for
evidence-based decision-making (https://ontariofarmlandtrust.ca/2022/11/10/bill-23/);
increase fragmentation of rural and agricultural areas, placing further strain on rural
communities;
attack meagre regional planning efforts to control urban sprawl, and dramatically alter
the long-term planning framework, the Provincial Policy Statement;
increase uncertainty over planning and conservation efforts, from the farm level to the
municipality, and will do irreversible harm to the ability of our regions to produce good
food over coming generations;
eliminate the growth plan density requirements;
remove key infrastructure planning elements of the growth plan;
allow settlement area expansions (Growth Plan, Planning Act changes);
separate development approvals (municipal) from infrastructure planning (upper tier)
(Planning Act changes)
prevent public and conservation authorities from appealing sprawl proposals to the
Ontario Lands Tribunal (Proposed Amendments to the Ontario Land Tribunal Act, 2021)
facilitate developer appeals of official plans by eliminating a 2-year timeout (Planning
Act amendments)
allow developers to reduce payments for new infrastructure costs of sprawl
(Development charge changes)
Food Security Requires a Sustainable and Responsible Approach
With Bill 23 the provincial government is taking an unbalanced, radical approach that
will produce harm—an approach that seems to be singularly driven by the developer
lobby’s profit-driven priorities - there is NO other beneficiary. Rather than increasing
enforcement to make up for the multi million dollar revenue shortfall in development
fees, this legislation reduces those fees for developers—without acknowledging that the
shortfall left in municipal budgets is most often made up for by cutting community and
social services, already insufficient to make up the serious gap on income security
policies, also set at the provincial government.
Similarly, many changes in Bill 23 take responsibilities away from Conservation
Authorities and hand them to municipal governments, who often have no experience or
resources to carry out these duties.
The downloading of responsibilities to municipalities without the attendant budget; the
promotion of housing construction without the associated municipal revenues required
to service those neighbourhoods; the wholesale removal of regulations that hinder
some home building, but which are required to prevent negative outcomes from
construction elsewhere: this is an approach to governance that does not attempt to look
for balance.
While Ontario has not found this perfect balance to date, what we have developed is an
approach that introduces change in a manner that recognizes the need for balance. For
one bill to tilt policy and slash regulation in so obviously one-sided a manner is
undemocratic and unaccountable to people living in Ontario, policy experts, and our
lower-tier governments.
Food Security Requires Food Sovereignty
Bill 23 erodes our food sovereignty, our food security, our democratic processes.
It must be pulled now, and re-started with guiding principles that balance the long-term
mutually-supportive needs for housing, ecological services and farmland protection,
and adopt an inclusive, collaborative approach that targets livable neighbourhoods,
farmland protection, food security and participatory governance.
Soumis le 4 décembre 2022 10:44 PM
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