A Flawed Foundation means a Flawed Plan
On November 10, 2022 the FoNTRA Board sent a Letter of Objection to the Standing Committee on Committee on Heritage, Infrastructure and Cultural Policy with copies to our local MPPs and councillors.
Bill 23 is omnibus legislation that seeks to make significant changes to municipal planning legislation throughout the province. Many residents, community and environmental organizations have begun to raise their concerns in a variety of public forum.
We encourage our readers to review the full text of our letter and to pass it along to their friends and neighbours.
An abbreviated version of the letter is provided below and highlights the ten reasons for concern with the new legislation.
All residents and interested parties are encouraged to use all or parts of open letter to assist in their advocacy efforts. Please reference the FoNTRA open letter and provide a link to our website.
Abbreviated version of our letter
Dear Members of the Standing Committee,
We are writing to you with our submission in response to Bill 23, the More Homes Built Faster Act, which was introduced on Tuesday, October 25th, 2022.
We agree that there is a housing supply and affordability issue in Ontario and support the broad goal that new housing should be built and be available across a spectrum of incomes and needs. The focus of all orders of government should be on liveable communities where all residents can thrive and grow.
1. Flawed Foundation Means Flawed Plan
The report focuses solely on supply not demand. The federal and provincial governments could reduce the demand for housing in the overheated GTA by influencing the location of jobs. Conspicuously, the Bill avoids dealing with affordability, again focusing only on production of new housing.
2. Infrastructure
Infrastructure: Roads, transit, sewers, fire stations, and libraries in new neighbourhoods are funded through development charges levied by municipalities – charges which Bill 23 proposes to restrict. It reduces costs to developers, but leaves municipalities no option other than to raise property taxes for all, to pay for the required infrastructure to support the growth.
3. Parks and Greenspace
The province proposes to cut in half the amount of parkland that developers are required to allocate to support new developments. Growth in our major cities is increasingly concentrated in vertical condo projects with inadequate outdoor amenity space.
4. Climate Change
The province is now stripping away our ability to enforce the innovative environmental standards which were designed to reduce greenhouse gas emissions from new builds.
5. Conservation
Changes to how wetlands are evaluated and protected will leave many of our favourite greenspaces at risk. The province is also limiting the role of conservation authorities in their much needed specialized role in watershed management and land use planning.
6. Architecture & Site Plan
The existing review process can refine and improve the design and servicing of new buildings to reflect the planning context and history of the street, to create inviting neighbourhoods. The province is removing that ability with Bill 23.
7. Cultural Heritage Protection
Right now, municipalities have 60 days to prevent the demolition of buildings with potential heritage value. The new provincial rules provide little time for effective City Council action. This is turning back the page on nearly 50 years of cultural heritage protection in Ontario.
8. Affordable Housing
The proposed legislation would curtail municipal tools to fund new affordable housing projects with revenue from development charges, which would reduce the amount of money municipalities can invest in new purpose-built affordable housing.
9. Tenant Protection
Although the details aren’t yet clear, Bill 23 seeks to limit the municipality’s ability to create rental replacement by-laws to prevent “renovictions”.
10. Public Engagement and Appeals
The review period for development applications is so shortened that time for public consultation will be restricted. The province will eliminate third party appeals (mainly by residents) at land use tribunals. These measures are vindictive and represent an unacceptable diminution of citizens’ rights.
Summary
The proposed legislation lacks the kind of background information and public engagement process that would permit a thorough analysis of the data, and discussion of its merits. The proposed legislation is focussed on land acquisition and intensification without consideration of infrastructure, schools, parklands and green spaces.
We respectfully request that the Bill be withdrawn to allow for a proper consultation and analysis that addresses the ten important items that are highlighted above. We need to find the balance between affordability, liveability, and sustainability to meet our housing needs.
Photo credit: Josh Evnin from Chicago, IL, USA, CC BY-SA 2.0, via Wikimedia Commons