WHAT ARE ISSUES RESTRICTING…

WHAT ARE ISSUES RESTRICTING AFFORDABLE OR ENTRY LEVEL “MISSING MIDDLE” HOUSING SUPPLY?

1. Definition ––“Affordable” vs “Attainable” vs “Missing Middle” housing. Need to clearly
define the problem(s) while at the same time considering local or regional perspectives.
For ownership, try using a percentage of a recognizable benchmark like the Average
Assessed Value as determined by MPAC. For rentals, use the Average Market Rent as
determined by CMHC.

2. Local NIMBY - density, height, parking space reductions, traffic volume increases etc.
These planning parameters require Official Plan or Zoning by law amendments, typically
leading to Land Tribunal hearings.

3. Failure of Municipalities to meet PPS - MOH has allowed municipalities to incorporate
a watered down version of the PPS direction into their OP and ZBL’s. PPS says:
“Planning authorities shall provide for an appropriate range and mix of housing
options and densities to meet projected market based and affordable housing
needs of current and future residents of the regional market area by
a) establishing and implementing minimum targets for the provision of housing
which is affordable to low and moderate income households and which aligns
with applicable housing and homelessness plans".

The Province needs to clarify the force and effect of this PPS “inclusionary zoning” directive
and instruct the Tribunal on how to consider cases where local authorities have tired to
implement the PPS to effect low and moderate income housing. Additional
“inclusionary zoning” tools may be needed.

4. Local land costs - increasing as available developable land supply shrinks. Lower cost
land typically has development/infrastructure cost disadvantages which adds to build
costs.

5. Legislative barriers -- limits innovative funding options for Municipal
investments/contributions to support affordable or entry level housing. Limits local
municipal financial support such as land contributions, DC relief, building fee relief etc.

6. Long and protracted process for municipal surplus land declaration
Limits easy supply of surplus municipal land for affordable or entry level
housing projects.

7. Limited use of the Community Planning Permit System (CPPS ). Slow
take up at municipal level due to limited resources and policy shift required.

8. Increasing hard costs Project in The Town of The Blue Mountains has seen hard costs
increase over the planning year of 25%!

9. Ever increasing soft costs many related to the municipal planning process and other
regulatory requirements soft costs can be up to 25% of total capital cost of project. Bill
109 deals with some of this.

10. Down Payment Affordability entry level housing buyer unable to afford the down
payment associated with high cost homes.

General Comment - In TBM we have no problem with homes getting built (2020, 429 units
built, 2021, 394 homes built). The issue is that NONE were affordable or even near that
range! Bill 109 build cost savings initiatives apply equally to market and attainable builds
and in our community may only help “market” builds. Suggestion make Schedule 5
amendments apply to only applications that contain over say 25% affordable or attainable
units. Encouraging or supporting “market” builds will not help the attainability problem.

Consider creating “as of Right” options for “Missing Middle” Housing, simplify the creation of a Community Planning Permit System (CPPS), amend the DC Act to make it easier for Municipalities to contribute DC to specific projects, for Municipalities that have a housing corporation or a Community Improvement Plan providing housing incentives to the private sector, allow all municipalities to benefit from a portion of the proceeds from the Land Transfer Tax, allow Municipalities to create an Affordable Housing Credit Program that leverages off of Municipalities setting affordable or attainable housing targets for all new development proposals. Summary of details below:

1. Municipality must have an inclusionary zoning bylaw or Official Plan requiring development proposals to have a minimum of X% of housing stock in a plan. This then sets an affordable housing minimum for each new development

2. Developers can choose to build in excess of the minimum number of units and can use this excess as a credit for their own future projects or sell these credits to other developers. Municipalities will then certify the surplus units so that only valid surplus units are available for application to other projects. Municipalities could “tax” some of that credit value to fund a local down payment assistance program for first time home buyers.

3. Allow developers to meet their attainable unit min. by either building to that minimum or buying credits form other developers in the area who have surplus credits

4. Municipalities would be the program administrators but not participate in the aftermarket sale of credits other than to certify the units for sale, or to “tax” the credit value for a local down payment assistance program for first time home buyers.