From the Town of Halton…

From the Town of Halton Hills Planning Staff:

Thank you for the opportunity to provide comments on the proposed changes to the Planning Act and Development Charges Act, 1997. Below please find the Town of Halton Hills’ comments on the main changes being proposed.

Development Charges, Gentle Density & Affordable Housing:

Studies related to a Development Charge (DC) Background Study, growth related studies and Asset Management Plans would no longer be recovered through DC funding. DC exemptions for development (including affordable housing units, attainable housing units, non-profit housing etc.), DC discounts; the phasing in of DC rates over 5 years, and reduced DC eligible costs in the DC calculation for the future are all proposed changes through Bill 23.

Staff have significant concerns about these proposals. Despite the intent that the proposed changes will assist with the construction of 1.5 million new homes over the next 10 years, the DC revenue losses to municipalities in order to fund growth related costs would be significant. This will have a counter-productive effect on the delivery of required infrastructure to support new growth. DCs are a major financing source for the Town’s capital projects required to support growth. Municipalities like Halton Hills will not have the financial resources to fund necessary growth-related studies, build community infrastructure (such as libraries, recreation facilities, parks, and trails etc.) which can ultimately impact the delivery of necessary housing and creation of complete communities. This additional financial burden would be exponential, requiring significant tax base increases, ultimately borne by existing residents. Municipalities would be required to choose between funding existing infrastructure (State of Good Repair) vs. funding new growth, potentially causing concerns to public safety.

The Town of Halton Hills already employs a proactive approach to the collection of Development Charges for non-profit and affordable rental housing units. These are established as 20-year DC deferrals for non-profit housing developments and as 20-year DC deferrals without interest for affordable rental housing developments. These initiatives were introduced through the Town’s 2022 DC Background Study and support the many proactive initiatives developed through the Town’s Community Improvement Plan (CIP). Mechanisms such as these reflect the Town’s desire to provide appropriate financial incentives in order to expedite the delivery of assisted and affordable housing.

If Bill 23 proceeds as proposed, the province should provide alternate funding sources/mechanisms for municipalities to fill the funding gap created by forgoing DCs through Bill 23. In addition, Bill 23 should include a periodic reporting measure from the province to the municipalities (e.g. 2-year report card), which evaluates the effectiveness of Bill 23 and the resulting impacts on housing supply and affordability.