Scope of types of…

Scope of types of development subject to development charges deferral

• The regulations provide for the deferral of Development Charges (DC) payments for non-residential development. It does not address the administrative aspects related to these deferrals and what tools municipalities will have to ensure that DC payments are able to be collected over an extended period of time. Consideration should be given related to how these charges are collected in the event of default or if a particular property changes ownership after it is constructed.

• The regulations should spell out the collection process and indicate that a municipality will have the ability to collect unpaid payments, by adding any amounts owing to property taxes (first priority).

• City staff feel that it is unclear the intent and likelihood that development charges deferral until occupancy for Industrial-Commercial-Institutional (ICI) type uses could actually create an incentive to advance the establishment of such uses.

• The potential ability to defer development charges up to 20 years for affordable housing projects is positive. Clarity on what may constitute affordable housing would be helpful.

• City staff would like clarification regarding what milestones or leverage does a municipality have to collect with post-occupancy development charges?

Period of time for which the development charge freeze would be in place

• Additional clarity is needed regarding the freezing of DC rates and whether it is at the time of application or approval for site plans and zoning applications.

Interest rate during deferral and freeze of development charges

• The City agrees with the proposed regulation to allow municipalities to charge interest for deferred or frozen payments and the ability for a municipality to set its own prescribed rate for this purpose.

Additional dwelling units

• Additional language should be added to the regulation to further define and provide clarity related to the prescribed classes and ancillary structures that applies to this exemption.