I appreciate the intent to…

I appreciate the intent to offer greater certainty as to costs for developers. It strikes me as fair to not change the costs before the developer has a chance to begin their project. I hope the attempt will be productive in reducing costs to all.

Please work with the municipalities to identify a) an acceptable alternate funding formula instead of the current suite of development charges and b) an appropriate phase-in time and then communicate the plan to the public before passing the legislation.

In terms of details, I ask that the Bill be modified as follows:

Regarding proposed change 3 4.1 (2) and (3): Improve the definition of an “affordable unit” by clarifying the “average market” against which it is being compared. I also continue to have concerns about defining an affordable unit based on market rent as opposed to occupants’ incomes.

Regarding proposed change 3 4.1 (4): Please fully define and then review the advisability of exempting ‘attainable housing’ from development charges, community benefit charges and parkland dedication requirements. If the government remains committed to this idea, please share the logic with local governments and the public before passing the legislation.

Please eliminate the possibility of parkland dedication credits for Privately Owned Publicly accessible Park Spaces. These lands are typically
• provided to occupants anyway via zoning regulations for minimum landscaped (amenity) area and to make the property attractive to occupant;
• too small to offer a full range of needed recreational uses, thus a full-size park is still needed; and
• less publicly accessible.