AMO’s Submission to Proposed…

AMO’s Submission to Proposed Changes to the Ontario Heritage Act and its regulations: Bill 23 (Schedule 6) - the Proposed More Homes Built Faster Act, 2022
AMO Submission to the Ministry of Citizenship and Multiculturalism on:
ERO 019-6196

December 9, 2022

 
Preamble
The Association of Municipalities of Ontario (AMO) is a non-profit, non-partisan association that represents municipal governments across Ontario. Together with our members, we address common challenges facing our residents and provide advice to the government about solutions to them. AMO has been actively involved in housing and homelessness advocacy for years, as Ontario’s 444 municipal governments are responsible for building strong, complete communities, of which housing – both home ownership and rentals – is a key component.

Housing affordability and building supply is a challenge all Ontarians share. There is much that can be done collectively by working together to increase housing supply, diversify the mix and increase affordability. Solving the housing crisis will require an all-of-government approach by all three orders of government and the development industry.

Introduction
AMO appreciates the opportunity to provide comments on several consultations related to Bill 23 – More Homes Built Faster Act, 2022. These are in addition to the written submission to Bill 23 AMO provided to the Standing Committee on Heritage, Infrastructure and Cultural Policy.

Despite the Bill’s passage on November 28, municipal governments remain concerned that the legislation:
1. Shifts the cost burden of growth
2. Undermines planning and community livability
3. Exacerbates risks to the environment and human health.

On November 30 AMO was pleased to see the government’s response to AMO’s preliminary analysis of the Bill which indicated a need for a transfer of up to $1 billion a year in costs from private sector developers to property taxpayers without any likelihood of improved housing affordability. Our focus will now shift towards making sure the housing pledges and targets are feasible and reasonable given historical data. To tie funding to unreachable targets and narrowly-defined “housing enabling infrastructure” are details we look forward to discussing more.

In the meantime, AMO is asking the province to work with all of its housing partners to take an integrated approach to environmental, social and economic policy that allows Ontario to take its place ahead of competing jurisdictions.

To that end, AMO respectfully submits comments on various consultations related to Bill 23 and the More Homes Built Faster Plan.
 
Proposed Changes to the Ontario Heritage Act and its Regulations: Bill 23 (Schedule 6) – The Proposed More Homes Built Faster Act, 2022 (ERO 019-6196)
The Ministry of Citizenship and Multiculturalism is proposing changes to heritage considerations to remove barriers that are perceived to be slowing housing construction and making it difficult to protect most of Ontario’s identified heritage properties.

AMO is supportive of measures that streamline provincial and municipal approvals in a way that speeds up development while balancing important liveability considerations. For example, the newtwo-year time limit on listing of non-designated buildings with a five-year limitation on re-listing could have the unintended consequence of creating more reactionary designations, and more appeals to the Ontario Land Tribunal (OLT) on matters of designation.

That is AMO supports the Ontario Professional Planners Institute (OPPI’s) recommendation that mutual-consent clauses be allowed if the property owner agrees to allow for properties to remain on the Register past the two years, or to designate a property not previously listed.

Conclusion
On behalf of municipal governments across Ontario, thank you for your consideration of the comments provided in this submission.