Bill 23 Submission, More Homes Built Fast Act

November 17, 2022

The Friends of the Golden Horseshoe is a group who have a vision for healthy and prosperous communities throughout the region. We are writing to express strong disappointment and fundamental disagreement with a variety of elements of Bill 23 as set out in this letter and detailed attachment and are of the view the Government should withdraw the Bill and engage in further with consultation with municipalities, conservation authorities and the public.

Bill 23 is the latest in a long line of assaults on planning in Ontario under the Ford administrations. It continues a disturbing pattern of restricting citizens democratic rights, overriding municipal authorities, attacking Conservation Authorities, gutting generations of environmentally enlightened legislation and eliminating consideration of legitimate community building considerations such as urban design, provision of parkland, green standards and heritage — all in the name of addressing housing demand in ways unsupported by any legitimate justification. It is a massive omni-bus bill accompanied by a package of regressive policy and regulatory changes – all with incredibly short, overlapping consultation periods.

Shortly after the release of Bill 23, the Government compounded this onslaught with the proposal to removal 7,400 acres from the Greenbelt and Oak Ridges Moraine. This was a blatant contradiction of repeated explicit promises from the Premier and Minister of Municipal Affairs and Housing. This was accompanied by the Minister’s autocratic overrides of municipal official plans in Hamilton and Halton – enacted by duly elected councils – converting thousands more hectares of farmland to urban sprawl.

This destruction of greenspace and farmland is proposed despite the fact there are upwards of 75,000 acres of land already approved for urban expansion, and tens of thousands more recently approved. The Government’s own Housing Task Force stated that, “a shortage of land isn’t the cause of the problem.”

No reasonable person is questioning the need for additional housing. It is the harmful measures proposed to achieve it that are problematic. The proposed actions appear to be aimed more at rewarding speculative land purchases by certain development interests and resolving longstanding grudges elements of the development and homebuilding industries have with municipalities and Conservation Authorities than having anything to do with building housing faster. Harming Ontario’s future is no way to address housing needs.

In fact, none of the following elements proposed in Bill 23 would do anything to increase housing supply  in Ontario:

  • Elimination of upper tier planning
  • Elimination of Conservation Authority participation in watershed planning
  • Forced reductions in development charges
  • Cutting developer parkland requirements in half
  • Taking lands out of the Greenbelt (when more than sufficient land already exists in urban areas).

There is no legitimate reason or need to impose these draconian actions. Three in particular are particularly shocking and regressive – none of which are even mentioned in the government Backgrounder on the Bill or in the recent provincial election.

First, in a single line the bill removes the authority of regions in the Golden Horseshoe from having official plans or any oversight of local municipal planning. This reverses 50 years of enlightened regional planning in southern Ontario.

Second, the bill undoes 75 years of history by restricting Conservation Authorities (CAs) from having a mandate to engage in watershed analysis, planning and management. This conflicts directly the Conservation Authorities Act whose purpose, enshrined in the original 1946 Act and which remains today, is: “to further the conservation, restoration, development and management of natural resources in Ontario’s watersheds.”

Third, the bill prohibits any citizen appeals of development applications to the Ontario Land Tribunal. This means only developers can appeal a council decision on their applications, making the Tribunal a developers only forum. This is unfair and furthers this government’s flouting of the public participation principles and rights enshrined in Ontario’s Planning Act.

Bill 23 was introduced October 25, a day after provincewide municipal elections. This timing was inappropriate. It is disrespectful of thousands of municipal councilors and all citizens. Newly elected councils will not have had the ability to digest, receive staff analysis, or consult with their constituents – preventing municipalities from providing informed input on a bill that contains numerous elements that significantly affect their cities and towns.  Given the growing chorus of opposition to numerous elements of Bill 23, the Government should withdraw the bill and consult further with municipalities and the public. The Government should also withdraw the proposal to remove land from the Greenbelt.

There are real housing issues facing the people of Ontario that everyone needs to work together to resolve. Yet, numerous elements of Bill 23 together with removal of Greenbelt lands, overriding of municipal official plans and various other elements of the Bill 23 package do the opposite. They weaken laws and policies Ontario municipalities, conservation authorities and citizens rely on to protect, manage and plan our environment and communities – while enriching and essentially turning over planning of our environment and communities to private sector development interests.

November 2022

For our full submission click on the link below.