Comment
The government's efforts to incentivize home-building is to be applauded; however, it seems like there are many aspects that need more thought.
The idea of growth pays for growth should inform DC’s and with many exceptions and exemptions for various conditions, it will be very hard for municipalities to recover these growth-related costs. For instance, if a city determines it will cost $100M to service a new development, how are they to set the DC rate per unit, when the composition of affordable, rental, or non-profit housing is unknown? If anything, the estimates will have to be made very conservatively, which could actually make some homes more expensive.
Similarly, the requirement to have municipalities spend 60% of their reserve funds seems naive. The principle of having parks and services built faster is appropriate, but this blanket approach doesn’t allow for context. Maybe those funds need to be saved up for a few years to build a new piece of infrastructure. Municipalities, just like developers, have to stay flexible with the economic environment and the pace of community development- requiring reserve funds to be spent quickly could lead to worse outcomes, poor infrastructure, or misguided servicing.
The discounts for purpose-built rentals should only apply to larger 2 or 3 bedroom units. Whether a developer chooses to build condos or rentals is very market-dependant and having a blanket policy could mean the balance of buildings is more rental instead of condos, reducing the opportunity for home ownership. An unintended consequence.
Additionally, the discount for affordable homes should be set at a different target than 80%. 80% is still not affordable for many, and I’d guess the % that DC’s make up of the total cost to build is close to 80% already. This would certainly incentivize developers to build 80% affordable, but it should go further. We already asked developers to provide affordable housing without discounting DC’s - why not make a graduated rate. If developer builds housing at 60% of market rent/ price they get full exemption of DC’s. If they build at 80% they pay half of the DC rate.
Will municipalities still be able to limit # of bedrooms on a single-family site that can now house up to 3 units?
One important point that is slightly outside the purpose of building more homes faster is the importance of building mixed-use developments. All the economic signals make it easier for developers to only build housing to the detriment of all who will live there. Could we use this legislation to incentivize mixed-use buildings? Whether through discounts on DC’s, reductions in parkland dedication etc? Businesses can become public spaces or important amenities in a community and can enrich a community.
Submitted November 5, 2022 7:48 AM
Comment on
Proposed Planning Act and Development Charges Act, 1997 Changes: Providing Greater Cost Certainty for Municipal Development-related Charges
ERO number
019-6172
Comment ID
62321
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Comment status