Dear Premier Ford, Comments…

Dear Premier Ford,

Comments to the Ministry of Citizenship and Multiculturalism re: Bill 23

While I support the intention to introduce measure to help with housing costs and supply, I have concerns with a number of the proposed changes in Bill 23. Would the Government consider making amendments to the proposed legislation to ensure that housing development is done in a way that protect the heritage value and environmental quality of Ontario neighbourhoods?

Site Plan Control

Bill 23 proposes to reduce a municipality’s authority to regulate the exterior design of a building. These provisions to review site plans help establish and maintain the heritage and unique qualities of neighbourhoods, which is tied to their identity, their live-work-play appeal and economic attractiveness.
These provisions can also influence their impact upon a community’s natural environment. Bill 23 proposes to remove bird-safe design standards within municipal regulations, which is important as birds species and their habitats are threatened within cities. It would therefore be important to reincorporate a province-wide bird friendly building design standard to encourage greater diversity and health of bird populations in our cities.

Environmental Protection

Bill 23 undermines the checks and balances that conservation authorities provide when assessing development that impact waterways and wetlands. Conservation Authorities play a key role in ensuring that future development will not adversely affect the eco-systems that contribute to our ability to manage climate change, including by reducing the risks of flood events. The Nature-based solutions, including protecting urban or urban adjacent green spaces, have been shown to be effective and cost-effective for helping to mitigate and adapt to climate change, and to promote biodiversity. There is growing recognition of the importance of nature-based solution in Canada but also internationally and Ontario should not lag behind in this regard. Canada’s recently released, and first, ‘National Adaptation Strategy’ notes enhanced biodiversity and nature conservation as one its key themes: https://www.canada.ca/en/services/environment/weather/climatechange/cli…

Parkland Dedication

Bill 23 also proposes to reduce parkland dedication requirements. As an Ontarian who lives in an urban neighbourhood in which increased densities will over time strain our existing parks, reductions in parkland dedication rates for new development will be problematic for future welfare of our residents (both current and new residents).

A United Nations Conference of the Parties on Biodiversity is currently underway in Montreal, which highlights the importance of protecting biodiversity, which is dangerously threatened in Canada and worldwide. The conference notes the importance of biodiversity (including parkland) conservation by reducing land-use change; overexploitation; pollution; climate change risks; and the spread of invasive species.

We need to have an Act which reflects long term thinking about Ottawa (and Ontario) residents access to greenspace, while building healthy and resilient ecosystems.

Please consider these points and revise Bill 23 accordingly.