The following comments…

The following comments reflect concerns over the overall effects of the package of changes proposed by the Ford government. They will lead to higher property taxes, greater uncertainty in parkland provision and less of it to serve higher density communities when it is needed more than ever, and inequitable social outcomes. The comments are organized into the following categories.

Certainty
There is certainty now in the 5% parkland provision requirement. This statement masks the Ford government’s true intent—to reduce parkland provision.

Equity
The proposed halving of open space provision will condemn urban Ontarians to a lower standard of open space provision in the higher density areas where open space is most needed. Where is the justice in this approach?
To exempt affordable housing from parkland dedication requirements again undervalues open space as a contributor to individual and community health. This approach will also disadvantage less well-off residents, which is discriminatory. Why not recoup the loss of open space by averaging any exemption across the remaining community?
This loss of greenspace access is all the more distressing given that research around the world confirms the importance of open space and parks to mental and physical health. The Covid-19 pandemic has only reinforced the essential need for access to parkland. The Ford government’s measures will condemn large parts of new urban Ontario to 19th-century conditions of open space.

Proposed Changes Increase Uncertainty
To include encumbered land and most especially private open space as a parkland dedication is almost certain to result in less parkland and higher developer profits. Encumbered land by nature will restrict the range of possible park landscapes and public facilities.
Municipalities wanting to negotiate agreements with private landowners requires a private landowner to want to negotiate or enter into an agreement. Meanwhile, if a development is planned predicated on a lower public open space allotment and an agreement with a private landowner, the failure of negotiations will result in a lower open space provision (and more houses for the developer) or the need to completely redesign the subdivision—adding to costs that will inevitably be passed to the homebuyers the Ford government claims to help.

Parkland Reserve
The requirement that municipalities spend 60 per cent of their reserve annually would seem to be an impossibility given municipal budgeting and capital planning requirements. Moreover, even if they could, the reduced parkland/cash-in-lieu requirements combined with the lower reserves the 60 percent policy would leave every year would eventually see virtually no reserve left. Maybe that’s the intent.

Development Charges
The sliding reduction in development charges from 20 percent to 5 percent over a four-year period will burden municipalities and its residents (including those who are to supposedly benefit from the Ford government’s actions) with a long-term legacy of higher taxes and/or reduced services. Any one-off benefit to new homeowners will be gradually be eaten away through higher property taxes, higher long-term home operating costs (due to the elimination of any green standards), lowest-common denominator community design, and a deteriorating social and physical fabric of communities—a decline local governments will be powerless to stem because of a lack of financial resources. This is the future that future generations of Ontarians will face.
Unless past capital costs are calculated in terms of constant dollars, the 15-year requirement will under-estimate the true dollar requirement even more than the 10-year average. This appears to be another case of downloading or shifting responsibility to the local level without a commensurate share of revenue from the province.

Affordability
An 80 percent level of current housing resale prices as a benchmark for affordability clearly puts affordability out of reach for most Ontarians seeking their first home.
Attainable housing needs to be defined, as does its relationship to affordable housing.

Regulatory Impact
The analysis of regulatory impact is incredibly spurious given its catastrophic consequences for municipal finances and property owners, including—ironically—those that will purchase homes under the Ford government’s program.