It is noted on the top of…

It is noted on the top of Page 18 for the technical briefing:

- A development receives either the frozen DC rate or a lower DC if the rates have been reduced during the freeze period.

Our legal counsel has advised that in the first reading of proposed Bill 17, this is related to Sec. 26.2 (5.2) which proposes the frozen rate plus interest is compared to the current DC rate and whichever is lower applies.

This could be taken one step further. Many rates became even lower than during the site plan process, due to the 20% discounts. The proposed legislation should ensure that the lowest DC rate at any time during the site plan process applies, rather than the rate appliable at the time of application. This applies to many projects currently underway, where the site plan was initially submitted a few years ago.

If the Province makes this change, it would also help to avoid many DC appeal processes, which will be inevitable and can only be done after the DC is paid. These appeals will occur because there were lower rates later in the site plan process. If a proposed development substantially changed from the first site plan submission, there is good reason the lower rate should apply, but the City will not see it the same way. As such, if the Province makes this change through Bill 17, it will not only lower the cost of housing, but will avoid lengthy and costly DC appeals, which could delay housing starts.

Respectfully,

Mark McConville, MCIP, RPP, M.Sc.Pl.
Director of Planning
Frontdoor Developments