CCKT’s formal commentary to the Provincial Government re: Bill 66

Jan 21, 2019

January 20, 2019

Mr. Ken Petersen
Provincial Planning Policy Branch
Ministry of Municipal Affairs and Housing
777 Bay St., 13th Floor
Toronto, ON M5G 2E5

Dear Mr. Petersen:

RE: ERO #013-4293 Bill 66: Restoring Ontario’s Competitiveness Act, 2018

Concerned Citizens of King Township (CCKT) is a well-established citizens’ group which has been active in King Township for 48 years. CCKT represents approximately 160 households. CCKT advocates for sound progressive planning, well-planned thriving communities, preservation and enhancement of natural heritage systems, protection of waterways and prime farmland, and engagement of citizens in public consultation.

CCKT is deeply concerned about proposed Bill 66, particularly Schedule 10 which undermines the progressive, forward-looking provincial planning regime of Ontario including the Clean Water Protection Act, Oak Ridges Moraine Conservation Act, Greenbelt Act, Lake Simcoe Protection Act and the Great Lakes Protection Act.

CCKT completely endorses the submission of Ontario Greenbelt Alliance of which we are a member group, and submits the following additional comments.

Bill 66 Undermines Sound Planning in Ontario

Ontario has come a long way over the past 50 years, particularly in the realm of regional, environmental and land use planning. In a province with one of the fastest-growing mega urban areas in North America, it is critical for sound, forward-looking planning to be in place. Living in the Toronto GTA one comes to understand this well.

The recently tabled provincial Bill 66, Restoring Ontario’s Competitiveness Act serves to undermine and unravel some of the most progressive and respected regional planning in the world. The Oak Ridges Moraine Conservation Plan, Lake Simcoe Protection Plan, Greenbelt Plan and Places to Grow Act all address key priorities in the Greater Golden Horseshoe Area of south central Ontario, home to almost 10 million people. Prime farmland is protected, sensitive waterways and natural features are preserved and enhanced, and urban growth is concentrated in designated areas to make efficient use of infrastructure and bring sound organization to land uses. Provincial parties and governments of all political stripes have contributed to these forward-looking plans.

The Greenbelt Plan which was approved in 2005 covers the largest area of any similar greenbelt plan anywhere in the world. This visionary provincial plan, which seeks to protect and preserve prime agricultural land in a country with a limited supply of arable land, plus protect precious watercourses and other valuable natural features, has been decades in the making.

Schedule 10 in Bill 66 provides for municipal governments to pass “Open for Business Planning By-laws” which provide exemptions to policies in major provincial legislation including the Greenbelt Act, the Oak Ridges Moraine Act, the Clean Water Act and regional and municipal official plans. Policies giving protection to viable prime farmland, drinking water sources and to sensitive environments on the Oak Ridges Moraine could be by-passed or compromised in favour of a large proposed development outside of settlement area boundaries and urban boundaries.

Sound planning through provincial plans and municipal official plans provides consistency, predictability, effective use of infrastructure and serves to sustain viable agricultural land and healthy eco-systems throughout Ontario. Currently there is an abundant land supply in the GTA and Greater Golden Horseshoe to 2041 and beyond with much of the infrastructure already in place, land which is already designated for both housing and employment purposes.

Important to note, “Open for Business Planning By-laws” can be passed with no prior public notice given and no requirement for public consultation. In addition, there is no right of appeal. In our view this does not represent a wise and fair planning process. Consultation with citizens and many stakeholders is an integral part of healthy due process. The right of appeal is also a fundamental principle in planning.

It is critical for Ontario to build and enhance the visionary planning regime and provincial plans established over the past five decades, and not open them up to the vested interests of many large corporations or individual municipalities. Consistency, stability and sustainability are all part of sound planning and are needed with a long term vision
to preserve a healthy, safe environment and valuable prime farmland across all of Ontario, and to address projected population growth and climate change.

We appeal to the provincial government of Ontario to remove Schedule 10 from Bill 66 and to contribute to the legacy of sound, progressive planning in Ontario that will benefit generations to come – a lasting legacy of abundant well-integrated agricultural land, improved source water protection, and the protection and enhancement of natural heritage systems throughout Ontario.

Recommendations:

  1. Remove Schedule 10 from Bill 66.
    2. Maintain and build upon the sound, progressive provincial planning of the past 50 years which has lead to increased consistency and provincial benefits in planning.
    3. Maintain the application of all regulations in the Clean Water Protection Act, Oak Ridges Moraine Conservation Act, Greenbelt Act, Places to Grow Act, Lake Simcoe Protection Act, and the Great Lakes Protection Act.
    4. Maintain meaningful public consultation in all planning processes and the right to appeal planning applications.

Thank you for your consideration of our submission.

Sincerely, J. Bruce Craig
Chair, Concerned Citizens of King Township

  1. Hon. Rod Phillips, Minister of the Environment, Conservation and Parks
    cc. Hon. Steve Clark, Minister of Municipal Affairs and Housing
    cc. Hon Todd A. Smith, Minister of Economic Development, Job Creation and Trade