John Ballantine Municipal…

John Ballantine
Municipal Finance Policy Branch
College Park 13th floor, 777 Bay St
Toronto, ON M7A 2J3
Taggart Investments Inc. submission on proposed regulations under the More Homes, More Choice Act, 2019 (Bill 108):
ERO 019-1406 - Proposed regulatory matters pertaining to community benefits authority under the Planning Act, the Development Charges Act, and the Building Code Act

Taggart Investments Inc. is supportive of the More Homes, More Choice Act, 2019 (Bill 108) and the Housing Supply Action Plan. Taggart Investments Inc.is a proud member of the Kingston Home Builders’ Association, the Ontario Home Builders’ Association (OHBA) and the Canadian Home Builders’ Association (CHBA). We are the largest developer of residential lots in the Kingston area. Another part of The Taggart Group of Companies, Taggart Construction Ltd., installs all servicing for our subdivisions. A further part of our Group, Tamarack Homes, as well as our partner, CaraCo Homes, builds 80 % of the houses in Kingston. Taggart Investments Inc. is responding to the regulatory consultation as the proposed Community Benefits Charges framework will have a profound financial impact for both Tamarack and CaraCo, as well as other house builders, and ultimately home purchasers or renters in the City of Kingston.

While the Taggart Investments Inc. is supportive of the Housing Supply Action Plan, we have significant concerns regarding the February 28th environmental registry posting on the proposed community benefits authority under the Planning Act and Development Charges Act, which may ultimately result in significant increases in fees and charges for new housing in the city of Kingston. This would make new housing and new rental units in our community much more expensive unless significant changes are made.

We constantly hear the question posed-“Why is housing so expensive in the City of Kingston”. Between increased servicing costs because of new regulations, increased Development Charges and increased land purchases of ‘raw’ land, we simply cannot afford additional charges because of community benefits.

We are recommending the provincial government address a number of specific issues to ensure a fair, balanced and transparent approach for the new Community Benefits Charges authority in support of housing supply and job creation are as follows:

• The CBC regulation must include a detailed ineligible services list for CBCs;
• The proposed cap (15% single tier and a combined 15% between upper and lower tier municipalities] represents a potential significant increase in government-imposed charges for new ownership and rental housing. Currently low-rise and greenfield housing in the City of Kingston contributes a 5% land dedication towards parkland and contributes to growth related infrastructure through development charges. The proposed regulation moves a number of services initially proposed in the CBC back to hard development charges with 100% cost recovery and there are few if any additional services that should be captured in the new CBC regime that would account for the other 10% of potential additional charges that could dramatically reduce housing affordability.
• There should be NO CBC for low-rise greenfield development. Growth should pay for growth and municipal revenue streams should be protected via Development Charges and Kingston can require parkland dedication in accordance with section 51.1 of the Planning Act (A maximum 5% parkland dedication) for low-rise housing. This would ensure Taggart Investments Inc. can work with our municipal partners to ensure we are building complete communities and providing physical parkland in our communities. The CBC framework should only apply to high density development.
• The proposed appraisal / land valuation date for low-rise housing at the building permit stage is flawed and must be amended. As currently proposed the appraisal and valuation would occur when the land value is the highest after the development proponent has built and paid for significant infrastructure into the ground. In essence, the CBC as proposed would tax the capital invested by the developer. Furthermore, as currently proposed the appraisal and valuation would occur AFTER the homes have already been sold, thus there is no certainty or predictability for either businesses or consumers potentially resulting in significant adjustments on closing for purchasers over and above what they paid for the home. The CBC payment should be calculated as the value on the day prior to approval of a development application (site plan control, zoning bylaw amendment, and consent to sever applications or draft plan of subdivision application where there is no site plan application).
• Lastly service standards must be applied for municipal implementation of CBC by-laws and strategies. There must be a robust framework in place to ensure fairness, accountability and transparency for the new CBC framework

Taggart Investments Inc. has been supportive of this provincial government’s initiatives to address the City of Kingston housing supply challenges that are making both home ownership and rental housing unaffordable. However we are very concerned that the regulatory posting as proposed will result in significant increases in government imposed charges for low-rise housing. Taggart Investments Inc. looks forward to working with the Ministry and all stakeholders to establish a fair CBC framework.

Sincerely,

Barry Smith,
Vice-President,
Taggart Investments Inc.

C. Ontario Home Builders’ Association