Bill 185

Your Letter *

Dear [recipient name will go here],

I write to you as a concerned citizen from Waterloo Region in response to ERO posting 019-8369 and the proposed Bill 185. I urge you not to enact Bill 185 and the proposed changes to the Provincial Planning Statement (PPS) without modifications to address our unique context in Waterloo Region for land use planning and environmental protection. As they currently stand, the changes your government proposes could cause irreparable harm to our communities and will hinder, not facilitate, the construction of new housing to address the housing crisis.

Unlike most other Ontario cities and communities, Waterloo Region has no Greenbelt protections and no freshwater pipelines to the Great Lakes. We are totally dependent on living within the carrying capacity of our watersheds. We have had to introduce our own policies to protect aquifer recharge zones, farmland, and sensitive ecological areas. Waterloo Region has also developed robust regional planning processes, which ensure collaboration and efficient use of resources and infrastructure across our complex region. The proposed Bill 185 and PPS changes would threaten these protections and planning processes on multiple fronts.

1) The Region of Waterloo is a facilitator －  not an inhibitor－ for urban development.

For over five decades, the Region has fostered collaboration, cooperation, and provided expertise (planning, engineering, hydrology) to all of our lower-tier municipalities to achieve coordinated urban development. This coordination makes our region a facilitator of housing growth that has been both rapid and sustainable. Our Regional Official Plan promises to deliver far more housing by 2031 than Provincial targets require. Schedule 12 of Bill 185 would undermine this regional coordination, putting our efficient use of scarce resources, such as water supply, sewage capacity, and transportation infrastructure, at risk.

2) We are rapidly growing while balancing protecting groundwater, farmland, and ecosystems.

Unlike other GTA upper-tier regions, despite numerous requests and appeals, the Region of Waterloo has been left out of the Provincial Greenbelt. Without Greenbelt protections, we were nevertheless assigned the same significant growth targets as most GTA municipalities.

In order to balance this significant growth and development with our vulnerable and limited groundwater that we are totally dependent on, the Region of Waterloo had to develop our own Greenbelt-like protective measures. These include our visionary Countryside Line boundary policy, our Protected Countryside designation atop the Waterloo Moraine, our Environmentally Sensitive Landscapes (ESLs) protecting watershed ecosystems, and wellhead Source Water Protection Areas. All of these essential Regional protections now stand to be threatened, fractured, compromised, or even eliminated entirely with the removal of Regional Planning Authority.

3) The implications of removing Waterloo Region’s Planning Authority could be dire

The removal of regional planning authority could mean that our region with one of the most vulnerable water supplies in the province ironically could have the least environmental protection. It also threatens the essential coordination of our complex development scenarios putting everything we have achieved and could still achieve for coordinated development in jeopardy. I foresee inconsistencies, erosion of environmental and farmland protections, competition for scarce water resources, and neglect of vital shared infrastructure like water, sewage, and roads, as just some of the likely significant harmful outcomes of removal of regional planning authority.

In sum, removing regional authority won’t speed up the construction of more housing. Instead, it will significantly inhibit development, both by raising infrastructure costs as efficiencies are lost, and by endangering our finite water resources that could become an absolute limiting factor for our urban growth.

I implore you to ensure the Region of Waterloo can retain our current successful Planning Authority. Our proven systems and protections are instrumental to meeting our ambitious targets for building affordable and sustainable homes as quickly and efficiently as possible.  If for any reason we do lose planning authority and our Regional environmental protections, the provincial Greenbelt must be extended to adequately protect the Waterloo Moraine and our essential groundwater recharge areas. Alternatively, the Region of Waterloo could retain overall planning coordination and our Regional Official Plan, while planning approval authority could be delegated to lower-tier municipalities to be more independent, provided approvals are in conformity to the overarching Regional Plan.

In conclusion, our policies, systems, and environmental protections in Waterloo Region are not just “red tape”. Our regional planning processes have in fact been carefully designed and have proven extremely effective at helping Waterloo Region to facilitate sustainable development where needed. These processes should be seen as facilitators, not barriers to building much needed homes.

Please remedy Bill 185 to ensure that it does not remove or damage our regional system and these essential policies for our environmental protections and rapid growth that we rely on here in our cities, townships, and Region of Waterloo.

Sincerely,
[your name will go here]
[your email address will go here] [your location will go here]