Comments from Town of Halton…

Comments from Town of Halton Hills Planning Staff:

1. Proposed changes would establish an upper limit on the number of units that would be required to be set aside as affordable, set at 5% of the total number of units (or 5% of the total gross floor area of the total residential units, not including common areas).

Town staff are supportive of specified targets for Inclusionary Zoning in Protected Major Transit Station Areas. However, the cap at 5% is not overly ambitious, and consideration should be given to a higher target as this regulation is drafted.

2. Establish a maximum period of twenty-five (25) years over which the affordable housing units would be required to remain affordable.

Town staff support defined tenure agreements for affordable housing. However, the Province should promote longer tenure in affordable housing projects in MTSAs, helping to ensure long-term viability of affordable units, closer to public transit. A 40-year agreement period, as presented by Habitat for Humanity to the Standing Committee on Heritage, Infrastructure and Cultural Policy, secures a lasting presence in these intensified communities.

3. Amendments would also prescribe the approach to determining the lowest price/rent that can be required for inclusionary zoning units, set at 80% of the average resale purchase price of ownerships units or 80% of the average market rent (AMR) for rental units.

Staff are generally supportive of metrics for identifying affordability in the regulation. However, the metrics being proposed here are a departure from the recently updated Provincial Policy Statement and Growth Plan, where 30% of household income to determine affordability in ownership and rent was still being considered. This helped account for ‘regional market areas’ where average resale and average market rent values are high, and not a good measure of affordability.

Further consultation is required on how average resale and average market rent are being determined. Locally, the average resale price and average rent are very high, and the calculated 80% of average resale or market rent would still be unaffordable for many low to middle income earners.

Determination of what constitutes affordable rent and ownership should come directly from the Assessment Report required under Section 2 of the regulation. This would help ensure any determination of affordability reflects local conditions.