Re: Bill 23, More Homes Built Faster Act, 2022
Dear Mr. Ford,
We write to you in deep concern about the intent, contents, and efficacy of Bill 23 that is currently being rushed through the legislature. These are just some of our specific concerns:
Bill 23 weakens the Conservation Authorities. Ontario’s CAs have an enviable record of
preventing flood damage by reserving flood-plain lands from development. They also play a vital role in providing lands for recreation that Ontario’s growing population needs very much.
Bill 23 allows housing construction on flood plains. How will these buildings in the flood plain areas be protected? Will the residents’ and landlords’ properties be insurable? Even if such developments are adequately protected by dikes etc., where will flood waters go? Such land use will impede flood level flows, thus increasing the risk of death and economic loss to upstream residents and businesses.
Bill 23 will allow draining and building on wetlands. Sixty-eight per cent of the original wetland area in southern Ontario had been lost lost by the early 1980s, with an additional 4 per cent destroyed since (Ontario Biodiversity Council, 2010). In the Greater Toronto Area and the agricultural southwest, over 85 per cent of wetlands have already been lost. We must retain remaining wetlands for soil stabilization, flood mitigation, providing vital wildlife habitat,
improving water quality, and providing recreational opportunities. Thus, Bill 23 is bad policy.
Bill 23 enables sale of public conservation lands for development. Many of these properties were placed with the government as a sacred, public trust that must not be betrayed.
Bill 23 will slash large holes in the greenbelt. Controlling sprawl is an essential strategy to lessen the cost of infrastructure, to minimise greenhouse gas emissions, to ensure a local food supply in an era of global uncertainty, and to maintain Ontarians’ quality of life. Much of the Greenbelt swaps proposed involve already protected land. Premier, you have made public commitments not to damage the Greenbelt, but this is a shell-game!
Bill 23 curtails our right as citizens to appeal land use change decisions. Under the Bill, the rights of special interest groups such as developers and land speculators are not encumbered in this
way Thus, the Bill is as fundamentally undemocratic as, say, misusing the “Notwithstanding
clause”.
Bill 23 weakens green building standards in an era of global warming, when ameliorative actions (like constructing green buildings) are desperately needed.
Bill 23 caps resources put to affordable housing at a low level when poverty is increasing in our province. We also desperately need “missing middle” housing within cities that is not encouraged under the Bill.
Bill 23 reduces development fees currently paid by developers, so that taxpayers will have to foot the bill for housing infrastructure, like sewers and access roads. I am sure, as a Conservative, that you understand the need for the user to pay the bills.
Bill 23 removes power from municipalities, allowing cabinet to arbitrarily change approved official plans. As a Conservative, I am sure that you understand the need to avoid top-down heavy-handed government.
Bill 23 encourages unlimited sprawl, and thus makes for more infrastructure expenses, thus increasing tax costs for ordinary folk and for businesses. This policy will also exacerbate climate change.
Professor Dawn Parker of the School of Planning at the University of Waterloo has analysed Bill 23. She concludes that the Bill will increase land prices and will exacerbate unaffordability of housing in Ontario. She estimates that it will not increase housing supply and that it will not help housing affordability
(https://uwaterloo.ca/news/media/q-and-experts-more-homes-built-faster-act-or-bill-23 ).
Likewise, Kevin Eby, a former senior planner with the Region of Waterloo, concluded, on a CBC broadcast today, that only 9% of approved housing lots in the Region are built upon each year. The rest are reserved by developers for future use and for speculative purposes. He also reached the conclusions that there will be a steady increase in the number of detached homes for sale as “baby-boomers” age, and that there is no housing land shortage in the Region. We do not need more sprawling, single family residences in the Region, nor in the GTA.
This legislation is supposedly about building more housing for Ontarians, but its 170 pages+ include an agenda that is fundamentally harmful. The bill is zooming through the approvals process before most people have even heard about it! We ask you, earnestly, to withdraw the legislation and tackle the demand for new homes in a fundamentally more intelligent way.
Bill 23 is UNAFORDABLE!
Copy of a submission to the government
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