Response to Ontario's proposed Bill 23

An open letter to Premier Ford and Minister Clark
Re: Bill 23 – More Homes Built Faster Act, 2022

We are writing to you as leading architects, landscape architects, and urban designers in Ontario.

The More Homes Built Faster Act, introduced on October 25, proposes extensive and significant legislative changes that would, if enacted, radically alter land use planning and city building in Ontario. The stated intention of this proposed legislation is to accelerate the construction of 1.5 million homes over the next 10 years to address our housing crisis.

We firmly believe that this legislation will not achieve its stated intent.

Instead, it will inhibit the construction of affordable housing in our province; dismantle regional planning and urban design considerations; undermine heritage protection, environmental protection, and climate change mitigation; and limit public participation in how we build our communities.

We have summarized our major concerns below:

Bill 23 will reduce the supply of truly affordable housing by reducing the affordable housing requirement in Inclusionary Zoning from 20% to 5%. The required period to maintain affordability is reduced from 99 to 25 years. This will exacerbate generational poverty and extend inequitable access to resources and infrastructure for the people of Ontario.

Bill 23 will encourage urban sprawl and undermine local democracy by effectively dissolving 50 years of regional planning in the Golden Horseshoe. This will certainly lead to a substantial conversion of farmlands, loss of green lands, and suburban sprawl.

Public participation will be limited by removing the requirement for a public meeting for plan of subdivision. The Minister will have new powers to amend Municipal Official Plans at any time, for any reason, without public consultation.

Bill 23 undermines environmental protection by limiting the role of Conservation Agencies to solely that of flooding and erosion hazards. Removed from their oversight will be watershed planning and management, coordinated flood protection, conservation of green lands and biodiversity, which are all core to climate change mitigation.

Bill 23 threatens the Greenbelt. There are 86,500 acres within the GTA currently zoned and ready for development. This is more than enough land available now that can be used to meet government targets. Housing construction needs to start without delay on these lands that are close to transit and urban services, where people already live, work and play.

Yet the government wants to remove 7400 acres of protected green space and farmland in the Greenbelt. Our Greenbelt lands protect the headwaters of the rivers flowing into Lake Ontario, preserve valuable farmland, connect forests and wetland ecosystems that form a continuous arc from the top of the GTA to the Niagara region, and limit suburban sprawl. The Greenbelt belongs to current and future generations of the people of Ontario.

Bill 23 removes design from the municipal approvals process. Exterior design, landscape and streetscape design should be reviewed during Site Plan Control. Design review at the municipal level is considered best practice nationally and internationally.

We must emphasize that design is not a superficial aesthetic overlay. It is fundamental problem-solving, directly related to the quality of the built environment, and to climate change mitigation. The design review process is critical in delivering safe, healthy, affordable, socially and environmentally sustainable communities to the people of Ontario.

We agree that the current system of municipal approvals needs to be streamlined to deliver urgently needed affordable housing. Bill 23 is not the way to do it. It needs to go back to the drawing board.

To effectively address our affordable housing crisis, we strongly urge the Government of Ontario to rethink Bill 23 and invite the Government to a robust and immediate consultation with leaders in our industry. In collaboration with municipal and provincial governments, we can produce the best possible outcomes for the people of Ontario.

Thank you,

Adamson Associates Architects
DTAH
ERA Architects
FORREC
Greenberg Consultants
Janet Rosenberg & Studio
KPMB Architects
MJMA Architecture & Design
Moriyama & Teshima Architects
Perkins&Will
PMA Landscape Architects Ltd.
PUBLIC WORK
Superkül
The Planning Partnership