August 20, 2019 Re: The…

August 20, 2019

Re: The Impact of Bill 108 and Proposed Regulations on the Residents of the City of Brampton, An Age-Friendly Community

Dear Minister Clark:

As citizen members of the City of Brampton’s Age-Friendly Advisory Committee, we appreciate the opportunity to provide comments and feedback to the Ministry of Municipal Affairs and Housing relevant to proposed regulations, enacted through Bill 108, as it pertains to the Planning Act, Development Charges Act, and proposed Community Benefit Charges.

Brampton aspires to be a leader in age-friendly community building by providing opportunities to age-in-place. The City’s first ever Age-Friendly Strategy and Action Plan was unanimously endorsed by Council on June 19, 2019, and establishes a course of action for positive transformation to meet the needs of residents of every age and ability. The Plan includes 55 action items and is identified as one of the key initiatives within the 2018-2022 Term of Council Priorities. The Plan addresses both physical factors, such as accessible housing and public spaces, as well as social factors, including service delivery and recreational programs.

Community Benefit Charges (CBCs)

Bill 108 will have significant impact on municipalities and residents alike. It seeks to combine three funding mechanisms used to fund parks, libraries, recreation centres and other community infrastructure into one community benefit charge (CBCs). As currently proposed, the Bill will place a cap on the recovery of growth-related infrastructure costs, whereby municipalities will be forced to choose between delivering parks and providing other community facilities, offloading additional costs to the tax payer, or to reduce service levels.

Essentially, municipalities will be under-funded in either land for community facilities, or revenue to build community facilities, creating gaps in living conditions for many disadvantaged residents. Adequate community and social infrastructure is critical to the development of complete communities and improving quality of life for all residents, especially youth, young families and seniors.

In summary, the City of Brampton’s Age-Friendly Advisory Committee supports the overarching premise of Bill 108 to improve housing affordability across the Province, however, the Legislation and its current proposed regulations would undoubtedly have a significant impact on the ability of Ontario municipalities to invest in community infrastructure that is vital to improving the quality of life, and ultimately the achievement of age-friendly community objectives which have been embraced by the Provincial Government through such initiatives as the Province’s Action Plan for Seniors: Aging with Confidence. Further, and of utmost concern, Bill 108 effectively has the very real potential to critically impede the ability of the City of Brampton to control its development destiny.

We would like to once again thank MMAH for the opportunity to provide feedback on important proposed legislations and hope that the comments and recommendations contained herein will be strongly considered as part of the policy consultation process.