AMO’s Submission to Consultations Related to Bill 23 & The More Homes Built Faster Plan 2022-12-09 RPT

Submission Overview

Document Title: AMO’s Submission to Consultations Related to Bill 23 & The More Homes Built Faster PlanSubmission Date: December 9, 2022Involved Ministries:

  • Ministry of Municipal Affairs and Housing

  • Ministry of Citizenship and Multiculturalism

  • Ministry of Natural Resources and Forestry

  • Ministry of the Attorney GeneralConsultation References:

  • ERO 019-6196

  • ERO 019-6172

  • ERO 019-6141

  • ERO 019-6163

  • ERO 019-6197

  • 22-MMAH017

  • 22-MAG011

  • ERO 019-6173

  • 22-MMAH018

Preamble & Introduction

PreambleAssociation of Municipalities of Ontario (AMO):

  • A prominent non-profit and non-partisan association representing the interests of municipal governments throughout Ontario, focusing on the collective challenges faced by municipalities and advocating for effective governmental policies and interventions.

  • Housing Advocacy:

    • AMO has a long history of involvement in addressing housing and homelessness, recognizing the importance of municipal governments in fostering a sustainable housing market.

    • The association acknowledges the critical shared challenges of housing affordability and supply impacting communities across Ontario, advocating for actionable strategies to mitigate these issues.

Introduction

  • AMO expresses gratitude for the opportunity to share insights on consultations regarding Bill 23, indicating the association's commitment to working collaboratively with the government.

  • Concerns raised in this submission include:

    • The potential undue cost burden transferred to property taxpayers from developers, raising questions about fiscal responsibility and equity.

    • Significant risks that may arise from potential undermining of local planning processes and overall community livability, emphasizing the necessity for balance between development and quality of life.

    • Increased environmental and public health risks resulting from expedited processes that may overlook vital sustainability measures.

    • The need for ensuring feasibility and reasonableness of housing pledges based on comprehensive historical data and trends in housing supply and demand.

Proposed Changes to the Ontario Heritage Act

Streamlining Approvals

  • AMO supports initiatives aimed at expediting housing construction while simultaneously ensuring municipal livability remains intact. However, there are notable concerns:

    • The introduction of two-year time limits on non-designated building listings could inadvertently lead to more designations and subsequent appeals, creating delays in development.

    • AMO proposes mutual-consent clauses intended to extend listing periods where necessary, safeguarding historical assets while facilitating housing construction.

Development Charges and Financial Implications

  • Development charges are essential for municipalities to manage the financial burden of growth-related infrastructure requirements, including roads, sewers, and public facilities.

  • With the Housing Supply Action Plan aiming to deliver 1.5 million homes by 2031, preliminary estimations suggest a potential significant loss in development charge revenue, approximated at ~$10 billion over the next decade.

  • AMO advocates for a pause in the implementation of new policies until a thorough evaluation is conducted to understand their implications on municipal finances and housing supply.

Legislative Changes Affecting Conservation Authorities

Changes to Conservation Authorities

  • The amendments introduced by Bill 23 shift new responsibilities to municipalities concerning the management of natural hazards, potentially undermining the essential roles of conservation authorities.

  • There are significant concerns over the implications of weakened environmental protections, such as wetlands, and the potential for unregulated development leading to ecological harm.

  • Recommendations:

    • AMO urges a reversal of these changes to enable efficient municipal-conservation authority agreements and collaborative environmental stewardship.

    • It also recommends reconvening the Conservation Authority Working Group to gather input on the regulatory modifications suggested by the Bill.

Planning Act Changes

Addressing Housing Needs

  • Bill 23 proposes crucial changes aimed at addressing housing supply, allowing up to three residential units per lot in designated areas, which AMO supports in principle.

  • However, AMO calls for careful deliberation about "as-of-right" zoning to prevent developing in vulnerable flood-prone areas, emphasizing the need for sustainable urban planning practices.

Regional/County Planning

  • The proposed changes could disrupt local planning strategies and service coordination, which are vital for the effective delivery of services to residents.

  • AMO recommends reinstating the growth management responsibilities to upper-tier municipalities, thus ensuring a coordinated approach to regional development and service provision.

Development Approvals Process

Impact of Changes on Public Involvement

  • The elimination of public meetings for subdivisions, along with the allowance for exemptions for smaller projects, risks limiting essential public engagement in the planning process.

  • The trend towards fast-tracked approvals may neglect necessary oversight by municipal bodies, leading to adverse outcomes for community interests.

  • AMO emphasizes the importance of referring implementation plans to the Housing Supply Action Plan Implementation Team for comprehensive assessment prior to execution.

Green Standards

  • There remains considerable concern that Bill 23 may undermine municipalities' authority to enforce sustainable design standards, which are critical for promoting environmental sustainability.

  • AMO seeks definitive clarification on retaining site plan control to enforce sustainability measures within new developments to ensure a greener future.

Additional Residential Units & Municipal Rental Bylaws

Support for Additional Dwelling Units

  • AMO strongly endorses the allowance for three additional units in serviced areas, which is aimed at alleviating housing demand and addressing the broader housing crisis.

  • The association advocates for a locally-driven rental strategy, ensuring local governments maintain authority without undue ministerial interference to preserve existing rental units and cater to community needs effectively.

Proposed Changes to the Ontario Land Tribunal Act

Prioritizing Housing Appeals

  • The changes proposed seek to expedite hearings for housing applications; however, the actual impact of such measures remains unclear.

  • AMO underscores the necessity of ensuring balanced public input during these hearings and suggests establishing preventive measures through local processes to safeguard community interests.

Inclusionary Zoning Changes

  • AMO strongly opposes any constraints on municipal discretion regarding the development of inclusionary zoning by-laws, arguing that flexibility is necessary to address diverse local housing requirements and foster broader implementation of inclusionary practices.

Rent-to-Own and Conclusion

Support for Rent-to-Own Programs

  • AMO expresses support for establishing rent-to-own initiatives that align with affordable housing objectives, ensuring these programs do not divert resources away from supporting other affordable housing efforts.

  • The association strongly advocates against the duplication of federal efforts in this area while taking into account local needs and conditions.

Conclusion

  • AMO extends its gratitude for the opportunity to present these comments on behalf of Ontario's municipal governments, emphasizing the importance of collaborative approaches towards enhancing housing supply and affordability within the province.