Thank you for providing…

   Thank you for providing the Township of Springwater with the opportunity to provide comment with respect to the proposed new legislation known as ‘Bill 204’. The purpose of this letter is to express comments and concerns on behalf of staff and Township of Springwater Council.

  Comment No. 1

  The definition of “affordability” can vary from municipality to municipality depending upon employment and housing demands. Therefore it is difficult to provide a consistent definition or dollar figure for what is considered “affordable” in a community.

  An accepted approach to provide comprehensive, consistent and relevant data for each municipalities to determine the cost should be confirmed.

  Comment No. 2

  When affordable housing needs conflict with development pressures of the area there may be instances where significant growth is occurring where affordable housing would not be best situated due to lack of public transportation and access of community/local services.

  Proposed legislation and/or regulations need to consider the municipality’s ability to provide complimentary services such as public transportation to ensure that additional expense associated automobile dependence does not detract from affordability.

   Comment No. 3 & 4

  As part of the affordability initiative set out by the Province it is encouraged that a municipality provide for development incentives (i.e. such as waiving development charges or reduction in taxes collected) as part of an affordable housing strategy. However, those funds that would normally be set aside for works such as road and infrastructure improvements would have to be found elsewhere within a municipal budget. The municipality may not have the financial capability to facilitate the same. Furthermore, consideration must also be given for cost implications related to staff time and resources associated with the implementation of inclusionary zoning including long term tracking of affordable units.

  Flexibility is needed to ensure that the implementation of inclusionary zoning, including development incentives remains at the discretion of the municipality to avoid undue financial burden. Providing additional funding to lower tier municipalities to offset costs associated with implementation of development incentives may be a reasonable solution mitigate financial burden.

  Comment No. 5

  It may be difficult to maintain the ‘affordable’ status or nature of units in developing areas given private ownership and potential resale in varying market conditions. Furthermore, it is unclear as to how affordable rental prices would be monitored/recorded and who would be responsible for the tracking/costs associated with this new process.

  The proposed legislation requires owners of inclusionary zoning units to enter into agreements with the municipality, which may be registered against the land and can be enforced against subsequent owners to keep the unit affordable. However, it is unclear as to the legal ability to enforce said agreement against a homeowner who sells the property in contravention of the agreement and is no longer the legal owner or how penalties are to be determined.

  In closing, on behalf of the Township of Springwater, thank you for the opportunity to provide the above noted comments in considering proposed Bill 204. If you have any questions or seek further clarification regarding the information provided in this letter, please feel free to call or email the undersigned.

[Original Comment ID: 194547]