The County of Bruce is…

The County of Bruce is generally supportive of the change to the definitions included in Bill 134 to introduce an income-based test for affordable rent and purchase price; and increasing the threshold for the market test of affordable rent and purchase price and utilizing the lesser of the two measures.

The approach to define income-based affordable rent or purchase price is an approach that has been widely utilized by both Bruce County Human Services and Planning & Development in reviewing and supporting applications for affordable housing. It is an approach largely accepted and understood by both the public and private sectors.

The change to the definitions for affordable residential units proposed by Bill 134 provides:
• Provincial consistency on affordability;
• Clear benchmarks for developers to understand what price points are preferred in the
development of affordable housing;
• Consistent stable demographic, evidence-based data thresholds;
• Reduces local administrative and policy burden in determining exemption eligibility; and
• Integrates between Housing and Homelessness Planning and Planning/Development reducing
siloed approaches.

It is acknowledged that this the approach is generally consistent with the 2020 Provincial Policy Statement and considers both income based and market-price approaches to derive an affordable housing definition for both rental ownership housing units.

The County does note that there is not a clear definition of “applicable local municipality”. The County has experience working with the PPS Housing Tables that utilize upper-tier County boundaries for defining incomes and affordable housing prices and rent. Clarity on the definition of "applicable local municipality" is important, as well as the continued annual publication of bulletins and housing tables by the provinces to support the implementation of the definitions of affordable housing for the purpose of implementing exemptions under the Development Charges Act.

It is also key to consider the basis and quality of data utilized to establishing average market rents. Often, the County finds the average market rent to be lower than rents that commonly are advertised or available throughout the County. Looking at the approach and inputs to ensure the average market rents are truly reflective of the current market and is reflective of the variety of unit types is important to incentivize the forms of housing needed most to meet community need.

The County of Bruce sees the approach to exempt affordable housing from paying development charges proposed in Bill 134 as consistent with the approach that the County is considering with our own proposed Development Charges By-law being considered in 2023. While there is consistency in approach and this exemption aligns with the County’s housing goals, it continues to be noted that these exemptions, along with others proposed through Bill 23 continue to provide further financial burdens on the County and our member municipalities to fund these exemptions. The County of Bruce continues to encourage the province to find ways to make upper-tier and local municipalities whole financially and support these levels of government by providing funding for infrastructure projects that support the development of housing locally.

Thank you for the opportunity to provide comment and input into the changes proposed through Bill 134.

Sincerely,

Claire Dodds
Commissioner of Community Development, MCIP, RPP
County of Bruce
cldodds@brucecounty.on.ca