To Whom It May Concern, The…

To Whom It May Concern,

The City of Brampton (hereinafter referred to as ‘the City’) appreciates the opportunity to provide
comment on the Proposed Changes to Ontario Regulation 299/19. The City is supportive of
efforts by the Province to address the housing affordability crisis and enable gentle
intensification in the City’s existing low-density neighbourhoods. Although there may be
locations in the City where the proposed changes are appropriate and provide for rental housing
options in the secondary market for Brampton residents, the inability for the City to evaluate and
consider the context, servicing capacity, delivery of community services for population growth,
and enforcement challenges pose a concern if this is to be enabled “as-of-right" City-wide.
Based on the information provided through this ERO posting, these changes would be
applicable to a large portion of Brampton, as residential uses make up a significant portion of
the City’s lands.

To support the aim of gentle intensification, the City proposes a scoped approach to these
changes that should be left to the discretion of the City’s Comprehensive Zoning By-law.
Additional Residential Units (ARUs) represent an opportunity to fill gaps in the housing supply,
specifically for affordable housing, which should be addressed in the legislation. In many
instances, ARUs are constructed as an investment opportunity that:
- Face issues with absent landlords that fail to take proper care of the properties and/or
-Fail to address the growing issue of affordability in the City.

This can impact the health and well-being of Brampton residents and often leads to additional
enforcement challenges due to complaints from neighbours.

The City has outlined fulsome comments in Appendix 1. Overall, the City agrees with gentle
intensification but in a manner that can be effectively managed and supported with the essential
servicing of hard and soft infrastructure, providing capacity for municipalities to inform design
standards and regulate the design and enforcement of safety standards for these units to
ensure the overall well-being of Brampton residents. The City is concerned with the impact of all
proposed exemptions to Development Charges (DCs), Parkland dedication or cash-in-lieu
outlined through Bill 23 and proposes that these exemptions be left to the discretion of the City.
The exemptions will significantly impact the delivery of necessary servicing to meet the amount
of growth targeted to occur through this Bill, with 113,000 new units by 2031. Although ARUs in
the City currently do not trigger collection of DCs, the need for this funding to deliver servicing
for 58,000 additional units is a major problem that the Province will need to provide financial
resources to address.

As identified, it is important that the City have the authority to determine appropriate locations
that can support 3-units per lot through the Comprehensive Zoning By-law Review process. This
will ensure that enforcement and servicing concerns can be addressed and managed in a
coordinated manner.

The City of Brampton would like to thank the Province for the opportunity to provide feedback
and comments on this posting. Please let us know if you have any further questions.

Sincerely,

Steve Ganesh, MCIP, RPP
Commissioner (A),
Planning, Building & Growth Management
City of Brampton