May 28, 2019 John Ballantine…

May 28, 2019

John Ballantine, Manager
Municipal Finance Policy Branch
Municipal Affairs and Housing
13th Floor, 777 Bay Street
Toronto, ON M5G 2E5

Re: Ontario Parks Association’s Response to Bill 108

Dear Mr. Ballantine,

The Ontario Parks Association (OPA) is a not for profit organization, established in 1936, that works to advocate for our parks and open spaces across the Province of Ontario. We are Protecting Tomorrow Today® through our advocacy and training. Further, parks professionals in the municipal sector are a significant component of the membership base we represent. Based on our mandate, the OPA is formally providing a response to Bill 108 – More Homes, More Choice to advocate for parks, park users and park stewards.

The Ontario Parks Association requests the Province of Ontario delay the passing of Bill 108 so that it can be revised in a manner that will mitigate the negative impacts this Bill will have on the supply and management of our shared municipal parks and trails. Development must pay for growth. A comprehensive and open public consultation is needed at this time prior to further consideration of the Bill.

The OPA recognizes and appreciates the government’s goals associated with improving the housing stock in the province per Bill 108. However, Ontario’s community parks and trails are under significant threat due to the changes proposed in the Bill. The public realm is a direct expression of how we live and what we care for. With the proposed Bill 108 changes, the need to build pleasant, livable, green, ecologically responsible and healthy communities has been placed in the cross hairs. Specifically the proposed Community Benefits Charge that removes the Development Charges (DC) Soft Service funding and the Alternative Parkland Dedication Rate. These changes will have significant financial impact on municipalities and the overall well-being of Ontario citizens. Municipalities will receive less funds from the development industry to address the park and open space improvements required for a healthy community. Local taxpayers will need to pay for any gaps in funding. Changes to the legislation are needed, that ensures Housing and Parks equal A Place People WANT to Grow!

The proposed Bill 108 changes to exempt, cap, and in some cases eliminate parkland dedication, specifically the cash-in-lieu of parkland, has not been adequately considered in terms of the direct negative impact this will have on communities and the residents living in these urban areas. The associated Alternative Parkland Dedication Rates are an important tool in areas where high density development is proposed. Higher density generates a greater demand for parkland. For small parcels of land, where onsite parkland dedication is not feasible, cash-in-lieu must be a standard developer obligation.

This is counter to the reality that increases in growth and density generate a greater demand for parkland. The use of alternative parkland dedication rates to address the need for more parkland and investment in parks improvements is being revoked. In Bill 108, parkland dedication rates will remain a maximum of 5% for residential development and 2% for commercial/industrial lands. Without the ability to set alternative rates for intensification projects these changes will directly affect a municipality’s ability to invest in parks and parkland in urban areas.

The legislation for this Bill must ensure the balance between citizen access to quality public parkland and housing needs. Both are essential to well-being. Actions specifically being requested by the OPA of the Province are:

1) Maintain municipal autonomy in being able to choose the type of community Council/residents want by maintaining the alternative parkland dedication rate.

2) Enable municipalities to continue to secure lands for park purposes and funds to improve those lands for park purposes by allowing the Parkland Dedication By-law and proposed Community Benefit Charge (CBC) By-law to apply to the same lands.

3) Speed up housing by not having municipalities and developers arguing over the charge in the CBC By-law by making it unappealable.

4) Make regulations associated with Bill 108 available prior to Bill 108 coming into force so that Cities can fully understand and be able to analyze the impact of the proposed Bill changes comprehensively and ensure a comprehensive and transparent consultation process that the OPA be included in.

5) Ensure municipalities are not left in limbo with no means to fund park improvements until a CBC By-law is enacted by clarifying how the transition from using DC By-laws to the CBC By-law will roll out.

The OPA is gravely concerned that the impacts from this vaguely-written bill are not well understood and that there will be significant impacts to how communities in Ontario are built; with less green space, fewer parks and trails, and no streetscape improvements to help make our public spaces and safe and liveable. Help protect our parks, protect our communities, and protect our future. Ensure development pays for growth.

To address the issues, the Ontario Parks Association requests the Province of Ontario delay the passing of Bill 108 so that it can be revised in a manner that will mitigate the negative impacts this Bill will have on the supply and management of our shared municipal parks and trails.

Yours truly,

Craig Shanks
President, Ontario Parks Association
Board of Directors