Key Criticisms of Bill 108 (More Homes, More Choice Act): A Closer Look at the Pushback
In 2019, the Government of Ontario introduced Bill 108, also known as the More Homes, More Choice Act. The stated goal was clear: make it easier and faster to build housing across the province. With housing prices soaring and availability declining in many urban and suburban markets, the act promised streamlined approvals, reduced red tape, and more incentive for developers to build.
On paper, this sounds like a welcome shift—particularly to investors, homebuyers, and real estate professionals who understand the pressures of a tight housing supply. But despite its title, the bill has faced significant criticism from a wide range of stakeholders, including municipalities, environmental groups, planners, and housing advocates. Many argue that the bill does not effectively address affordability, and worse, that it sacrifices long-term sustainability and local accountability in pursuit of short-term growth.
Let’s break down the key criticisms of Bill 108 and what they could mean for the future of Ontario’s housing market.
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1. Undermining Local Planning Authority
One of the most vocal criticisms of Bill 108 is that it significantly weakens the ability of municipalities to manage development in their communities.
Prior to Bill 108, the Ontario Municipal Board (OMB)—a body often accused of favouring developers—had been replaced with the Local Planning Appeal Tribunal (LPAT), which limited the scope of appeals and gave more weight to municipal decisions. Bill 108 effectively rolled back many of those reforms, reinstating broader appeal rights and bringing back de novo hearings (which essentially allow planning decisions to be re-evaluated from scratch).
Municipal leaders argue this creates a major imbalance of power. Local councils, who are elected to represent the will of their residents and manage growth responsibly, now have less ability to enforce their planning frameworks.
From a housing and mortgage industry perspective, this shift may lead to faster development approvals, which could theoretically increase supply. But it also raises concerns about uneven growth, inadequate infrastructure planning, and overburdened local services—factors that can influence neighborhood desirability, property values, and long-term investment potential.
2. Erosion of Environmental Protections
Another major concern tied to Bill 108 is its impact on environmental oversight. The legislation made changes to the Conservation Authorities Act, reducing the role of conservation authorities to focus narrowly on flood risks, while removing their broader ability to comment on development applications related to ecological protection, biodiversity, or climate resilience.
In addition, amendments to the Endangered Species Act introduced what critics call a “pay-to-destroy” model. Developers could now pay into a fund instead of mitigating direct harm to endangered habitats—a shift that conservationists say prioritizes convenience over sustainability.
For real estate investors, developers, and homebuyers, these environmental rollbacks might look like regulatory streamlining. However, ignoring long-term ecological consequences can backfire. Flooding, erosion, and loss of green space can impact insurance rates, mortgage approval zones, and the long-term livability of a region. What’s good for the bottom line today may create hidden liabilities tomorrow.
3. Reduced Funding for Community Infrastructure
Bill 108 also made sweeping changes to how municipalities collect money from developers to fund infrastructure like parks, libraries, transit, and affordable housing.
The legislation replaced Section 37 (which allowed municipalities to negotiate community benefits in exchange for greater density) with a new, capped "community benefits charge." Additionally, it imposed tighter limits on development charges—fees that help municipalities pay for the cost of growth.
Critics argue this will leave cities with less funding to build the very infrastructure needed to support new residents. While more homes may be built faster, there is concern that they will arrive in neighborhoods without adequate green space, school capacity, or transit access.
This dynamic matters to anyone in the housing market. A condo in a poorly serviced neighborhood may technically be “affordable,” but if it’s disconnected from transit or under-served by schools and recreation, its real-world value to buyers and investors drops. Quality of life, not just unit count, is key to maintaining vibrant, livable cities—and long-term property value.
4. No Guarantees on Affordability
Despite its branding, Bill 108 has been criticized for failing to include concrete mechanisms to ensure that the “more homes” it promotes will actually be affordable.
The legislation does not require a percentage of new development to be set aside for affordable housing. Nor does it define what “affordable” means in practical terms. Instead, the approach focuses on increasing supply in the hopes that affordability will follow.
However, many housing experts argue that simply adding more market-rate housing won’t address the needs of lower- or middle-income Ontarians—especially in high-demand cities like Toronto or Mississauga, where land values and speculation remain intense. Without targeted affordability requirements or incentives for non-profit and cooperative housing, critics say the bill will simply accelerate the construction of luxury condos and high-end rentals.
From a mortgage or real estate investment standpoint, this could create a skewed market: more units, yes—but potentially fewer buyers or renters who can afford them. The long-term health of Ontario’s housing ecosystem depends not just on volume, but on diversity and attainability.
5. Marginalizing Community Input
Another key point of contention is that Bill 108 reduces the role that ordinary residents can play in shaping their communities.
Under the new rules, timelines for development approvals were shortened, meaning municipalities have less time to consult with residents before decisions are made. At the same time, appeals are once again open to developers through the LPAT, giving them a fast-track path to override local opposition.
Community groups and resident associations fear that their voices are being drowned out by lobbying and legal pressure from the development sector. The complexity of the LPAT process also makes it difficult for average citizens to effectively participate without legal support.
For homeowners, this introduces an element of unpredictability. A well-established neighborhood could suddenly see mid-rise or high-rise buildings approved nearby, with minimal warning or consultation. This can affect quality of life, traffic, school crowding, and property values—all concerns that factor heavily into mortgage decisions and real estate investment strategies.
Final Thoughts: The Trade-Off Between Speed and Sustainability
At its core, the More Homes, More Choice Act reflects a broader tension playing out in housing markets across Canada: how do we build faster without cutting corners?
Supporters of Bill 108 argue that the province is in a housing crisis, and bold action is needed to meet demand. They’re not wrong. But critics counter that the bill’s approach leans too far toward deregulation, eroding safeguards that exist for good reason.
For those in the mortgage and real estate space, Bill 108 presents both opportunities and risks. On one hand, it may accelerate housing supply and create more development options. On the other, it introduces volatility—both in how neighborhoods evolve and how cities fund growth.
Smart investors, homebuyers, and professionals will need to pay close attention not just to where housing is being built, but how. The quality, inclusiveness, and sustainability of Ontario’s housing growth will define its long-term success more than speed alone.
