Responding to Bill 108, More…

Responding to Bill 108, More Homes, More Choice: Ontario's Housing Action Plan, Amendments to the Development Charges Act

May 30, 2019

I am writing on behalf of seven Toronto area Canadian Federation of University Women (CFUW) clubs representing over 1000 women who live across the GTA and beyond.
CFUW is a voluntary, self funded, non-partisan women’s advocacy organization with over 100 clubs across Canada, including over 50 in Ontario. CFUW Ontario has policy in place that supports housing for all, recognizing that a range of nonmarket and market housing is essential to meet all housing needs and recognizing that housing development and redevelopment should be sustainable, well planned, and ensure livable communities for all.

We are extremely disappointed in the proposed changes to the Development Charges Act in Bill 108 which will reduce the cost to developers at the expense of the municipality and residents, should services that make communities more liveable be scaled down. Parks, recreational facilities, libraries and childcare centres improve the quality of life in our neighbourhoods which is essential as density increases.

The current tools available to municipalities, including Section 37, known as Community Benefits, are used to fund community projects and services across Toronto. Childcare is an example of a “soft service” that benefits from community development funds. The new legislation would combine and cap all community-related development charges including Section 42 funds for parks and other essential infrastructure, such as water and sewers. The proposed reduction of minimum parkland dedication requirements would mean less green space, perhaps moving from playing fields to parkettes in some instances. Although capping makes costs more predictable for developers at the onset, the municipalities will lose the authority to negotiate throughout the process.

Negatively impacted will be subsidies for rental housing and shelters, essential to promoting inclusive, mixed income neighbourhoods where all benefit from local community services.

In summary, under the proposed amendments to the Development Charges Act the developers will benefit by paying less, the municipalities and residents will pay more, and municipalities will lose the ability to negotiate with developers to ensure infrastructure needs are met and best practice standards in community development are upheld. In looking at the affordability issue, there is no guarantee that reduced costs to the developers will be passed on to renters and home buyers through increasing affordability.

Finally, we are extremely concerned about the lack of time for study and consultation of the proposed changes and that decisions are being made in the absence of information on proposed regulations, which inform the details of their impact.

Respectfully submitted.

Sheila Lacroix sislacroix@yahoo.ca
CFUW Leaside – East York, on behalf of the following:
CFUW Aurora Newmarket: Lynn Bird klbird@hotmail.com
CFUW Etobicoke - Maure Kentner maure.kentner@gmail.com
CFUW Leaside – East York: Jane Withers jhwithers28@gmail.com
CFUW North Toronto Helen Penfold penfoldhm@rogers.com
CFUW Scarborough Doreen Dickson g.dickson@sympatico.ca
UWC North York: Janet Gordon janetg8094@gmail.com
UWC Toronto Susan Freeman susgula@sympatico.ca