Comment
The Township of Springwater has provided comments in the attached Letter, Report/Appendices.
Provided are key excerpts of comments endorsed by Council for the Township of Springwater.
"Development Pays for Development vs. Public Pays for Development
Proposed changes to the Planning Act and Development Charges Act are expected to result in a reduction in Township revenues needed to support growth related expenditures. The proposed changes would exempt the payment of development
charges for certain projects (attainable housing, additional residential units), parkland dedication fees, Community Benefit Charges and phase development charges for commercial, industrial and institutional projects.
The concept of development pays for development (growth pays for growth) is entrenched within existing planning policy to ensure that services/infrastructure required to support growth is collected through development charges to maintain historical service levels even with the introduction of new development.
Bill 23 proposes Development Charge Exemptions for the following:
- Attainable/Affordable Housing Units
- Additional Residential Dwelling Units
- Inclusionary Zoning Residential projects
- Non-profit housing
- Growth Oriented Background Studies (DC Background Study, Master Servicing Plans etc.)
Exemptions from fees/development charges associated with attainable/affordable/non-profit housing projects will result in a reduction in Township revenues for the provision of growth-related services that will inadvertently be absorbed by the taxpayer.
Furthermore, due to the mandatory five-year phase in of the collection of development charges, municipal projects (infrastructure, facilities etc.) that are currently funded through development charges will be subject to a shortfall in revenues and the gap in funding may need to be recovered through alternative funding streams (issuance of debt, grants and/or subsidies from upper levels of government, increase in property taxes on existing residents, etc.).
Studies such as Master Servicing Plans, Development Charge Background Studies, Growth Management Studies that are needed to facilitate growth/development would need to be absorbed by the tax base as these studies are proposed to be exempt from development charges moving forward, which is not consistent with the concept of development pays for development.
Examples of significant Township of Springwater projects needed to support growth include the proposed Craig Road connection or the highly anticipated Multi-purpose Complex, which rely entirely or partially on development charges (Craig Road-100% development charge funded, Multi-purpose Complex-61% development charge funded).
Should Bill 23 receive Royal Assent in its current form, the Township could face a potential loss in Development Charge Revenues of $8.3 million (land costs, studies, non-profit housing and mandatory phase-in gapping for Development Charge funded
projects) needed for the growth-related projects such as the Craig Road extension and the multi-purpose complex. To put this into context, the Township would require a tax increase of 10% each year over the next 5 years to recoup reduced revenues received from developers.
This is in addition to any other funding that may be required to look after the Township’s existing infrastructure, which currently has a replacement value of over $985M. Should the additional property tax increase not be supported over the next five years then the timing of when projects move forward will need to be reconsidered and in some cases be deferred.
Core Infrastructure Upgrades/Provision of Parkland
In order to increase the housing supply the Province is proposing additional permissions for additional residential units and further development charge exemptions as follows:
- Up to three (3) residential units on a lot with municipal services (3 units in primary building or 2 units in primary building and 1 unit in an ancillary building);
- Exemptions from development charges, parkland dedication/cash in-lieu;
- 1 parking space for each unit is required.
Staff agree that alternative options are needed to provide for a variety of housing types and that Additional Residential Units are useful to provide for a more affordable housing option.
The ability for municipalities to provide and pay for infrastructure improvements, parks/recreation and maintain infrastructure to support growth, needs to be considered prior to the enactment of wide-spread policy changes.
Core Infrastructure Upgrades
The Township of Springwater currently owns and operates nine (9) water plants and four (4) municipal sanitary sewer systems, with one (1) additional water and sanitary sewer system to be added in the near future. Each system has set capacity limits arrived at through various approval processes regarding the number of households that can be serviced. Staff expect that expansions/enhancements will be required to core infrastructure to support additional population growth.
Exemptions to development charges for additional residential units are expected to create a further funding gap to pay for required enhancements to core infrastructure. Upgrades to existing infrastructure to support growth will have a significant financial impact on the municipality. The Township utilizes approximately $118,000 worth of road, water, wastewater, bridges, and stormwater assets per existing home to provide
services to each household. The net result of Bill 23 would shift the investment burden from the exempt development (Additional Residential Units) to the existing residents and the other non-exempt new development.
Without development charges, the Township would be forced to either borrow funds and rely on the taxpayer to fund expansions to municipal water and sanitary services needed to support additional growth.
Provision of Parkland
Bill 23 proposes the following changes as it relates to the provision of Park Land:
- 5% conveyance rate only applies to portion of development that does not include affordable and attainable residential units;
- Waive parkland conveyance requirements for affordable and attainable housing;
- Alternative rate of 1 hectare per 300 dwelling units to 1 hectare per 600 dwelling units;
- Landowners provided right to appeal parkland conveyance process and municipal decisions.
The proposed Bill may result in park space that is not sufficient to service higher densities as the need for open space areas tend to increase within areas that consist of higher densities.
In addition, delays in house construction may be expected if appeal rights regarding parkland dedication By-laws are expanded as Ontario Land Tribunal (OLT) proceedings could delay approvals."
Supporting documents
Submitted November 24, 2022 1:56 PM
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
72620
Commenting on behalf of
Comment status