Reducing and eliminating…

Reducing and eliminating development charges is a form of magical thinking – as if all the developer has to do is build houses and water, waste water, electricity and roads will magically appear.

To put the cost of supporting a speculative venture on existing taxpayers, who are already struggling under a regressive property tax system, is wrong. Why should the developer be the one for whom the profit from a project is built in, while the existing taxpayer’s role is to be built in as the unwilling subsidizer of the developer’s profit.

It’s self-evident that growth should pay for growth. Presently, it doesn’t. These changes are a step in the wrong direction.

This is what AMO states: "Preliminary analysis of the Bill indicates the transfer of up to $1 billion a year in costs from private sector developers to property taxpayers without any likelihood of improved housing affordability. Similarly, the bill’s provisions designed to reduce environmental protection will benefit developers in the short term, with costs to the public and homeowners that cannot be calculated."

For that reason, I oppose removing development charges or any part thereof from any type of housing. Development fees pay for vital municipal services with important public health benefits, including upgrades for climate resiliency infrastructure such as flood protection, transportation infrastructure, public realm improvements, and other amenities and services needed to meet the needs of a growing population. Significant impacts can be expected if the current pool of funding to pay for these services is reduced. Growth will no longer pay for growth, at the expense of healthy, resilient and equitable evolution of our communities.

I adopt the following statement from the submission by the Municipal Finance Officers Association, who describe the proposed changes to DCs as:
"• _Counterproductive: Less funding for DCs will increase competition for projects from other demands on property taxes and municipal revenue streams. Municipalities may not have the funds needed to put the infrastructure in place that is necessary for development to occur in a timely way.
"• _Inefficient: We are not aware of any evidence that shows reductions in DCs are being passed directly to homebuyers through reductions in housing prices. Further, it is the demand for real estate that sets the price point that the market will bear. Setting lower prices may simply lead to bidding wars as we have seen over the past few years, countering the Province’s goals of more affordable housing.
"• _Ineffective: Pushing the cost for infrastructure onto taxpayers and ratepayers means higher property taxes and utility rates, creating a disincentive for residents to support new housing.
"• _Expensive: Reducing DCs does not decrease the cost of growth-related infrastructure, rather it transfers the cost to existing homeowners. Significant increases in the whole cost of housing will be unaffordable for many. "

The changes will limit the tools available to municipalities to support homeless and underhoused people and families, some of the most vulnerable people in our communities. Do not remove “housing services” from the list of services that can be funded through development charges. This change will have a negative impact on the ability of municipalities to deliver affordable housing, result in immediate funding gaps, and negatively impact developments already underway.

As a rural resident, I am concerned about the impact of the proposed changes on rural areas that may face the imposition of development they do not want. Not only will this bring housing into areas with infrastructure (septics, well water) that may not be able to support it, there is also an increased likelihood of fragmentation. This disrupts rural communities, with increased traffic impeding the safe movement of farm equipment, and new residents having unreasonable expectations about farming.

I adopt the following statements from the submission by the Ontario Federation of Agriculture, which opposes the proposed changes that would shift the financial burden of paying for growth-related capital costs from developers to property taxpayers.

"The proposal to extend the historical service level for eligible capital costs (excluding transit) as
part of development charge bylaws from 10-years to 15-years is particularly concerning. This
change directly undermines the intended use of development charges which is to help
municipalities recover increased capital costs associated with growth. The demand for most
municipal services rises each year. Setting development charges based on the average service
for the past 15 years will underestimate the cost to service new properties today and into the
future. As a result, development charges will be insufficient to cover the cost to service growth
and property taxes will need to rise to cover the funding deficit. If growth is to pay for growth, the
timeline to base historical service levels should be shortened not lengthened.

"Excluding the cost of development charge background studies from being recoverable through
development charges means that local property taxpayers will be forced to foot the bill. This is
particularly concerning in small, rural municipalities that have fewer taxpayers to split the cost.

"New residential units do contribute to growth related capital expenditures. Therefore, the proposals to exempt attainable housing from development charge and community benefit charges, discounting rental unit development charges and a five-year phase-in period for all development charges will put additional strain on municipal budgets and local taxpayers.

"Additional strain on municipal budgets and the subsequent pressure to increase property taxes is of great concern to the farm community. In the last province wide assessment MPAC provided, farmland values increased at a disproportionate rate and farmers in many municipalities across the province are paying a record high percentage of the municipal tax levy. "

I believe the communities we develop into the future should support healthy and active living – complete communities, and the services needed to support such communities are parks, recreation facilities, libraries and other services that enable residents and businesses to thrive

I particularly oppose changes that would reduce parkland dedication, or exempt affordable housing from parkland dedication requirements. Higher density development must not come at the expense of reduced greenspace – in fact access to natural areas is more important in low income neigbourhoods with confined living spaces than in areas where residents have easy access to their own or nearby outdoor areas .

I adopt these statements from the submission put forward by the Ontario Public Health Association:

"Reduction of parkland requirements and parkland dedication fees will significantly reduce access to local greenspace. This will have negative impacts from a climate resiliency and health perspective, increasing health risks by impacting people’s access to cool outdoor spaces during heat events and disproportionately impacting equity-deserving groups, especially for people most vulnerable who have limited access to parkland and with the least resources to adapt. In addition, a decrease in the amount of parkland represents a decrease in the amount of impervious services, putting direct and immediate strain on municipal stormwater management infrastructure, increasing flood risks and increasing exposure to climate- related health hazards.

"Additionally, these lands provide access to greenspace and recreational opportunities for the public. Access to greenspace play an important role to address chronic diseases such cardiovascular disease and diabetes, improves mental health, and helps reduce environmental exposures which impact health, such as extreme heat and air pollution. Reducing parkland dedication also places pressure in intensifying communities where reduced private greenspace and living spaces will put greater pressure on accessing outdoor and recreational amenities within one’s neighbourhood.

"From a health equity perspective, OPHA is extremely concerned with proposed changes that will exempt certain types of development, in particular affordable housing from the parkland dedication requirement. There is mounting evidence of the health and equity benefits of access to nature, including parkland for all populations, and in particular, for children and youth and for people living with inequities. As noted in the report Green City: Why Nature Matters to Health – An Evidence Review, frequent access to nearby green space is important, especially for children, and nearby green space may provide added benefit in low-income neighbourhoods.i

"OPHA respectfully disagrees with the statement on the ERO 019-6172 webpage that these changes to the Planning Act will “provide for more parks quickly”. By reducing the maximum amount of land to be conveyed to the municipality for park or other recreational purposes from the current rate of one hectare for each 300 dwelling units, to one hectare for each 600 dwelling units, the proposed changes will result in less parks provided rather than more parks.

"OPHA does not support the ability for developers to identify encumbered lands (e.g., land with underground transit tunnels or other infrastructure) to serve as parkland. Subsurface infrastructure or other easements on the property can significantly hinder the amenities that can be provided by the municipality and the ultimate usability and desirability of the land for parks purposes. For example, trees and certain structures that create a desirable park space require both depth and height. If either are taken away by an encumbrance on title, then the park is compromised."

Finally - affordable housing should be defined based on household income, not market cost.