Thank you for the…

Thank you for the opportunity to provide comments on Bill 108 through the Environmental Registry. Saugeen Shores Planning Committee discussed these comments at a recent meeting.
Earlier this year the Province received our comments on increasing Ontario’s Housing Supply. We have attached our previous comments for your information.
Generally, it is the Town’s that many of the changes are designed to address impacts in the Greater Toronto Area, but that the impacts from those changes will be felt throughout Ontario, in both large and small communities.
From our perspective, Bill 108 would not stimulate the construction of new housing. The actual impacts may be savings to builders and developers at the expense of desirable community services (such as parkland). We do not see the ties to ensure supply is increased or housing prices lowered to be more affordable.
If the goal is to provide more housing at more affordable prices, changes to the Planning and Development Charges regimes that have a greater impact are outlined in our comments from January of this year (as attached).
Planning Act
As outlined, the proposed changes would potentially affect how and how much municipalities identify and supply parkland to serve communities. The concern from the Town’s perspective is that the ability to acquire parkland in an amount sufficient to meets the needs of the community may be restricted or capped. This is particularly impactful because higher density developments, which predictably house more people and, therefore, may demand more parkland services, may be limited to an amount of parkland less than permitted currently. The Town supports looking at means to comprehensively address community needs, but stresses that municipalities’ abilities to determine and fund parkland needs are best left for municipalities to determine without interference.
There is also an apparent higher level of administration required which could be costly, and which appears not to be eligible for compensation except through direct property taxation. The need to manage appraisers, coordination of multiple appraisals throughout a community, cost for appraisal, additional auditing, etc. adds to problems which take away from the goal of building communities which serve their residents. We do not support processes which create non-value-added work. This increases the cost of development applications which would be seen in the increase of fees, thereby not saving money on these applications and potentially affecting all development applications.
Moreover, the need to prepare a community benefits strategy is not defined and may result in additional studies and costs. This issue may be mitigated if the regulations stipulate how the strategy is to be prepared or if it can be coupled with the Development Charges review process or some other requirement already more-or-less in place. More information is needed on how this change would be better than the existing act provisions.
Development Charges Act
Waste Diversion targets are set by separate legislation and there is already work towards the implementation of such programs. Small municipalities are the least affected, but it is encouraging to see a financing source to expand services. Development Charges, however, does not allow for new programs, and for these types of programs, that need to be reviewed and incorporated.
Secondary dwelling units still put pressure on municipalities to provide services. If all secondary units are to be exempt from DC’s, municipalities are left to fund shortfalls in infrastructure funding. We recommend the existing provisions remain and allow municipalities to determine how best to facilitate and charge for services for secondary dwelling units.
We agree that Development Charges may have a more tangible effect on the creation and construction of rental housing and industrial development. However, municipalities should be able to identify and create systems to incentivize the types of developments that meet local needs. By allowing installments, municipalities have to cash flow through other means, potentially. By having to administer and track payments, municipalities have to devote resources to doing so taking away from other services. The Province should review their programs to include financing opportunities to support cash flow in municipalities who participate in these programs.
Local Planning Appeal Tribunal Act
Generally, the proposed mean a return to the old OMB style of hearings. These changes take away a municipality’s local autonomy and potentially allow developers to seek an over-ride to local decisions which are the result of local discussion and deliberation. A return to this system also may allow developers to withhold evidence or generate new evidence that was not available to local municipalities.

We look forward to further dialogue with whomever appropriate, so we can expand upon these thoughts and provide a more detailed plan to address housing supply.

Regards,

Jay Pausner, MCIP, RPP
Supervisor, Development Services
jay.pausner@saugeenshores.ca
519-832-2008 x.120