Parks and Recreation Ontario…

Parks and Recreation Ontario (PRO) is a provincial association representing 6,500 members in municipalities across the province. PRO’s members provide facilities and services to more than 85% of Ontarians in communities from Windsor to Ottawa to Thunder Bay.

PRO is pleased to provide this submission to the Government of Ontario in response to the ERO postings related to Bill 108 -More Homes, More Choice Act (ERO 019-0183 and 019-0184).

PRO collaborated with municipalities across the province on this submission through a working group and a province-wide survey of its members. PRO circulated the key considerations and recommendations in this submission to its municipal members. Overwhelmingly, they agreed that there are significant concerns in the legislation and regulation related to the provision of recreation facilities and parks. They also supported the recommendations for extensive consultation with municipal recreation and parks stakeholders, the need for additional clarity on the transitional regulations, and more time to transition to the new Community Benefit Charges (CBC) framework.

Through its membership, PRO is ideally placed to provide advice to the Province on the implementation of the More Homes, More Choice Act to ensure that all municipalities benefit from vital community facilities and parks both today and in the future.

PRO has combined its feedback on the two regulatory postings as the issues are closely related. PRO is making three recommendations that will ensure that the new legislative and regulatory framework supports the development of complete communities.

1. A provincially set cap for a CBC requires flexibility to ensure revenue neutrality across the province is achieved.

Recommendation: That the province work with municipalities to develop a flexible community benefits approach that is calibrated to ensure it achieves revenue neutrality and responds to funding needs for municipalities today and into the future.

2. Municipalities require transition provisions to secure in-progress applications funded through the current legislation.

Recommendation: That a transition for in-progress planning applications be created so that municipalities can continue to receive the land and contributions for parkland or recreation facilities that were contemplated when the applications were received. Changes should only apply to complete applications submitted after proclamation. And specifically, that a transition provision be included related to Section 42 of the Planning Act.

3. January 1, 2021 is not enough time for many municipalities to have a CBC Strategy in place, especially if the regulation(s) is not finalized until the fall of 2019.

Recommendation: That the Province change the CBC transition date to January 1, 2022 to provide more time for municipalities to transition.

Conclusion
PRO appreciates the opportunity to address specific concerns related to proposed regulations under Bill 108, the More Homes, More Choice Act. PRO has focused its comments on strengthening the proposed regulations to support the provision of vital community recreation infrastructure and parks. There continues to be an overriding concern from stakeholders that there is an erosion of deference to municipal planning and heritage decisions, along with potentially significant financial implications in the provision of recreation facilities and parks.

PRO looks forward to working with the Province to ensure that the perspective of municipal recreation and parks is included in the consultations on these regulations and the development of the CBC Regulation.

Please refer to the entire attached submission for more information.