June 11, 2025 The Honourable…

June 11, 2025
The Honourable Rob Flack
Minister of Municipal Affairs and Housing

Subject: Concerns Regarding Provisions in Bill 17 – Timing of Development Charge Payments

Dear Minister Flack,

On behalf of Municipality of Tweed I am writing to express our concerns regarding certain provisions of Bill 17, specifically those related to the timing of development charge payments.

Bill 17 proposes that development charges be due upon the granting of occupancy for a development project. While we recognize the Province’s intent to support housing development and streamline processes, this particular change presents significant financial and operational challenges for small and mid-sized municipalities.

By deferring development charge payments until occupancy, municipalities are effectively required to advance the cost of infrastructure, capital projects, and municipal services—including roads, water, wastewater, and emergency services—without the necessary funding in place. This shift in financial responsibility introduces substantial cash flow pressures and could delay or compromise our ability to deliver essential services in a timely and sustainable manner.

The proposed approach does not appear to take into account the financial realities of communities with populations under 50,000. Smaller municipalities with limited tax bases cannot reasonably absorb the risk and financial strain of unpaid development charges while simultaneously being expected to support new growth and provide quality municipal amenities.

We also wish to express our disappointment that Bill 17 received Royal Assent while the public consultation period was still open. This undermines the consultative process and leaves municipalities and other stakeholders questioning whether their feedback is genuinely being considered in the legislative process. We strongly believe that meaningful public engagement should be completed before legislation is finalized.

We respectfully request that the Province consider a more flexible and equitable framework—such as a tiered or percentage-based system tied to development progress or construction value. This would help ensure municipalities receive funding in phases aligned with project advancement, rather than waiting until occupancy, when many of the infrastructure investments will have already been completed.

We urge the Province to re-evaluate these provisions and engage meaningfully with municipalities—particularly those under the 50,000 population threshold—to develop an approach that supports both housing goals and municipal financial health.

Thank you for your attention to this matter. We look forward to continued dialogue and collaboration with the Province to ensure the implementation of Bill 17 reflects the diverse capacities and realities of Ontario’s municipalities.

Sincerely,

Jamie DeMarsh
Deputy Mayor
Municipality of Tweed