By permission, the VPNA's letter is reproduced below.
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November 14, 2022
Victoria Park Neighbourhood Association Development CommitteeDear Mayor and Council,
We are writing to you as members of the Victoria Park Neighbourhood Association Development Committee (VPNADC) to express our deep concern about Ontario’s newly tabled Bill 23, “More Homes Built Faster”. If passed as-is, we fear this Bill will have enormous negative effects on the future affordability, liveability, and sustainability of cities in particular and the province as a whole. As past and newly elected Councillors for the City of Kitchener, if you are familiar with the process and content of Bill 23, we anticipate you share our concern and will take action on this bill.
Despite the impacts of Bill 23 falling squarely on municipalities, the Bill was released immediately after the recent Municipal Election and is being rushed through readings with inexplicably tight timelines for response. This restricts the ability of newly elected Municipal councils to respond, since most have not yet had time to self-organize, meet and begin municipal governance. The timeline similarly undermines opportunities for public and expert review, scrutiny and oversight. The proposed legislation is in the form of an omnibus bill of 175 pages, amending 10 acts, being delivered in closure and with limited public consultation. This does not support a transparent and democratic process.
As many of you know, the VPNADC’s purpose is to promote sustainable and livable development that is affordable, includes adequate green space, is built with climate change in mind, and includes citizens in the process. Here is a brief summary of our concerns with Bill 23, seen through that lens:
- The ostensible benefits of the Bill include bylaw changes promoting more non-single-family homes and increased density near transit, but the measures are weak and will actually only create 50,000 of a needed 1.5 million such housing units.
- Bill 23 wipes out multiple measures used by municipalities to enable development while protecting social and environmental concerns, including eliminating the requirement for rental unit replacement when old buildings are replaced, destroying inherent protections for tenants against rent increases. While Kitchener does not yet have such measures in place, it precludes us from addressing our significant and increasing homelessness issues by implementing rental replacement in the future.
- Bill 23 proposes numerous changes to the Development Charges Act and Planning Act that, if passed, will significantly impact how municipal governments recover the costs associated with growth and pay for essential infrastructure such as roads, sewers, and parkland to accommodate new residents. Contrary to the widely accepted concept that growth should pay for growth, this Bill would upend this practice and require municipalities to spend or allocate 60% of their reserve funds each year, ultimately shifting the financial burden of growth-related infrastructure onto existing taxpayers.
- The proposed changes to municipal development charges, parkland dedication levies, and community benefits charges may also contradict the goal of building more housing in the long-term. Unless fully offset by funding to support growth-related projects, reductions in these fees may prevent municipalities from being able to accommodate additional growth, and particularly make it more difficult for them to fund affordable housing.
- Critical and hard won municipal green standards already existing in some cities will be gutted, and cities such as Kitchener who are looking at adopting such standards to address climate change and meet their commitments to 50x30 and TransformWR Climate Action Strategy will be prevented from doing so.
- The remaining powers of the Conservation Authorities will be decimated creating massive risks of flooding, rampant sprawl, destruction of precious farmland, wetlands and natural habitats. These are critical to secure livable futures and are things that the municipalities of Waterloo Region worked hard to protect, in both past and current Regional Official Plans.
- Sale of sensitive and previously protected conservation lands will be handed over to municipal government with NO requirement or ability to consult with the Conservation Authority. This is difficult to comprehend in its scope of reversal of forward-thinking sustainable policy, previously put in place to protect this increasingly precious land. It will also add to the planning burden of Kitchener City Staff, since this responsibility will be directly downloaded onto them.
- Coordinated regional planning will be destroyed in favour of uncoordinated lower tier planning, promoting disorganized, expensive sprawl. Urban boundary decisions, recently made by democratic municipal process after deliberation, citizen and expert input, stand to be overturned, with provincial authorities unilaterally imposing opposing mandates. In Waterloo Region, this will undermine the effective, collaborative approach that has benefited our cities and rural municipalities.
- Contrary to provincial government claims for Bill 23, the resulting rampant sprawl is not the solution to the current crises of housing shortages, affordability and the combined climate and health crisis. Sprawl produces a smaller number of larger, less affordable, isolated and car-dependent housing units than planned, walkable development within existing urban boundaries served by public transit that the City of Kitchener is working so hard to create. This move away from complete, 15-minute communities will escalate dangerous greenhouse gas emissions, deadly air pollution, multiple human health harms, and hugely escalate the costs borne by municipalities and taxpayers.
In summary, the changes proposed in this Bill seek to: redefine the scope of municipal planning; reduce democratic norms for both public participation in planning and legal recourse through the Ontario Land Tribunal; offer weak support for affordable housing; and seek to prevent the pursuit of green development standards at a time when we need to address the climate crisis by building complete, compact, and low-carbon communities. Given this, we appeal to you as Councillors to act: call on the Minister of Municipal Affairs and Housing to either withdraw Bill 23 and its aligned initiatives or ensure a lengthy period of public engagement. Time is short - written submissions to the Standing Committee are only being accepted until 7pm November 17th, and can be submitted with your concerns here: https://www.ola.org/en/apply-committees).
Sincerely yours,
Peggy Nickels
Peggy Nickels, for
Victoria Park Neighbourhood Association Development Committee
cc Hon. Doug Ford, Premier of Ontario
Hon. Steve Clark, Minister of Municipal Affairs and Housing
Members of the Victoria Park Neighbourhood Association
Members of the Victoria Park Neighbourhood Association Development Committee
Further Resources:
“Ontario’s Housing Bill is Actually a Trojan Horse for Environmentally Catastrophic Rural Sprawl” Environmental Defence Press Release, including detailed analysis of the many issues with Bill 23: https://environmentaldefence.ca/2022/10/31/ontarios-housing-bill-is-actually-a-trojan-horse-for-environmentally-catastrophic-rural-sprawl/
“Ontario Must Withdraw Bill 23 and Shift to Sustainable Planning” Ontario Headwaters Institute https://act.newmode.net/action/ontario-headwaters-institute/ontario-must-withdraw-bill-23-and-shift-sustainable-planning
“4 ways the PC government's new housing bill could override city powers” CBC News, October 29th https://www.cbc.ca/news/canada/ottawa/ontario-housing-bill-override-city-powers-1.6633897
“Ford housing bill a ‘devastating attack’ on renters: NDP” CBC News, Nov 2nd https://www.cbc.ca/news/canada/toronto/ford-rental-bylaw-changes-1.6637865
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