February 14, 2023
Hon. Doug Ford I Premier@ontario.ca I doug.fordco@pc.ola.org
c.c. Hon. Steve Clark I Minister of Municipal Affairs and Housing I Steve.Clark@pc.ola.org
c.c. Hon. David Piccini I Minister of the Environment, Conservation and Parks I david.Piccini@pc.ola.org
Dear Premier Ford:
We are community and faith-based organizations and faith leaders deeply concerned by the passage of Bill 23, the More Homes Built Faster Act, 2022. This legislation represents a dire threat to Ontario’s precious green spaces – its wetlands, woodlands and other natural areas. It will accelerate car-dependent sprawl onto rural land. We do not believe the legislation will augment the supply of affordable housing. Indeed, if anything, it will lessen the supply, leaving many Ontarians unable to afford homes and many of those with no housing at all. It will benefit one group: wealthy developers, while having widespread detrimental and irremediable effects on the physical and psychological wellbeing of communities. It removes control from conservation and local authorities, while reducing funds available to municipalities for needed infrastructure.
For the Ontario government to enact and proceed with the measures contemplated by the legislation, in the face of catastrophic climate change and loss of species and their habitats, along with Ontario’s housing crisis, is to take aggressive steps backward at a time when there is no room for missteps. Its implementation will aggravate, not ameliorate social inequity. In our view, this goes beyond the realm of legitimate political choice and raises serious moral questions.
The legislation proposes the removal of 7,400 acres of land from the Greenbelt. While it is claimed that the lands removed will be “replaced” by adding land to the Greenbelt, much of the land that will supposedly be added is already protected. Even if that were not the case, “swapping out” the plots of land targeted for development will destroy the permanence and certainty required for any part of the Greenbelt to function properly.
As is set out in a letter to the government by the organization Environmental Defence:
“By permanently setting aside land for farming and natural heritage, the Greenbelt protects land from the intense speculation and development pressure in Southern Ontario. Without this permanent protection, agricultural land would quickly become completely unaffordable to farmers. Even raising the possibility of removing any land from the Greenbelt will create a speculative rush and intense development pressure on all the lands currently within the Greenbelt.
Currently, there is a vast supply of unused greenfield land already open for development within existing municipal boundaries (350 square kilometers as of 2019) and the current round of Official Plans awaiting approval will add 42,000 additional hectares of non-Greenbelt land to that vast stockpile.”
There are other deeply concerning aspects to the legislation and associated policy proposals, as noted by Environmental Defence, among them, the following:
- Conservation Authorities are prohibited from doing anything to prevent sprawl, a prohibition that is certain to lead to increasing flooding, erosion and the destruction of ecosystems as well as the exposure of vast swaths of Ontario’s most important habitats to degradation, placing Ontarians at real risk.
- The legislation sets the stage for the displacement of low and modest-income Ontarians, who are disproportionately Black and Indigenous, from neighborhoods well-connected to employment and well-serviced by transit and other public amenities and environmental benefits, like parks, schools, and ravines. It does this by authorizing the province to forcibly cancel municipal “rental replacement” policies which guarantee tenants of demolished rental buildings can return to live in the new buildings that take their place.
- It severely constrains the ability of municipal governments to levy development charges – which require developers to help pay for the infrastructure, like roads, cycle paths and sewers. For example, it includes provisions that would prevent municipalities from reserving more than 40 per cent of development charges to build large-scale facilities (like sewage) required to support new homes. The effect would be to either deprive residents of essential services, or else to suddenly increase municipal taxes, in some cases in excess of 80 per cent in a single year.
- The legislation will take the authority to require green buildings from municipalities – undoing many municipal Green Building standards that have already been developed – and undermine the affordability benefits that energy-efficient, climate-resilient buildings provide to owners and tenants. It will severely limit the ability of municipalities to require the inclusion or funding of parks and other public spaces for residents of new development.
By the government’s own admission, the measures included in Bill 23 would deliver only 50,000 of the 1.5 million new homes it says Ontario needs within existing cities and towns. But crucially, for the reasons set out above, the net effect of the legislation will likely be to produce fewer homes, and more expensive ones at that, rather than “more homes…faster”.
We join the many individuals and organizations – municipal, environmental, community, and faith-based; experts in urban and land use planning; farmers; academics; advocates for the unhoused – who cautioned against the passage of Bill 23 and now call for its repeal.
Sincerely,
Danforth Jewish Circle
Interfaith Social Assistance Reform Coalition
ISARC represents: Christian, Jewish, Muslim and other faith communities across Ontario, including the Anglican Diocese of Toronto, the Anglican Diocese of Niagara, the Anglican Provincial Synod of Ontario, the Assembly of Catholic Bishops of Ontario, the Canadian Unitarian Council, Catholic Charities of the Archdiocese of Toronto, Congregation Darchei Noam, the Council of Imams, the Council of Canadian Hindus, the Eastern Synod of the Evangelical Lutheran Church in Canada, Holy Blossom Temple, the Islamic Humanitarian Service, Mennonite Central Committee Ontario, the Presbyterian Church in Canada, The Salvation Army, the Society of St. Vincent de Paul, the Toronto Board of Rabbis, and the United Church of Canada.
The Revd Michael Coren M. Div (Hons.)
Rabbi Shalom Schachter I Member, Toronto Board of Rabbis
Cantor Cheryl Wunch I Congregation Shir Libeynu
Neighbourhood Unitarian Universalist Congregation
Shoresh
Councillor Dianne Saxe, University-Rosedale
Carrie B. Dohe I Bees for Peace
Climate Action for Lifelong Learners
East Toronto Multi-Faith Committee
Rabbi Aaron Levy I Makom: Creative Downtown Judaism
Rev. Daniel Benson I Minister, East End United Regional Ministry I Toronto
Rev. Dr. Cheri DiNovo CM (Order of Canada)
Cynthia Wilkey
Co-Chair, West Don Lands Committee
Elin Goulden I Social Justice & Advocacy Consultant I Anglican Diocese of Toronto
Rev. Stephen Reist
Mardi Tindal I Past Moderator of the United Church of Canada
Rev. Stephen Milton I Lead Minister I Lawrence Park Community Church I Toronto
Rev. Cynthia O’Connell I Glebe Road United Church I Toronto
Rev Gregory Daly (he, him pronouns) I Beach United Church I Toronto
Rev. Dr. David Kim-Cragg I St. Matthew’s United Church I Richmond Hill
The Rev. Dr. Randy Naylor I Minister I Windermere United Church
Animal Alliance of Canada
Peter Haresnape I Pastor I Toronto United Mennonite Church
Rabbi Ilyse Glickman
Rabbi Irit Printz
Rabbi David Seed
Adath Israel Congregation
Rev. Jessica McCrae I Maple Grove United Church I Oakville
Rabbi Stephen Wise
Rabbi Edward Elkin
Toronto Monthly Meeting of the Religious Society of Friends (Quakers)
The Sisterhood of St. John the Divine I St. John’s Convent I Toronto
Green Ummah
Rev. Bob Paterson-Watt I Woodbine Heights Baptist Church
Rev. Michiko Bown-Kai