Response to Public…

Response to Public Consultation Regarding Bill 108: More Homes, More Choices Act in the Housing Supply Action Plan, Schedule 12, Amendments to the Planning Act

May 31, 2019

One of the areas of focus of the Status of Women and Human Rights Committee of the University Women’s Club of North York (UWCNY) is advocating for the construction of Affordable Rental Housing in Ontario, in particular in the GTA.

The University Women’s Club of North York is an organization of more than 200 women living in Toronto. It is affiliated with the Canadian Federation of University Women (CFUW), a national non-partisan organization with over 100 clubs in all provinces of Canada, including over 50 in Ontario, that has consultative status with the United Nations. It is a member of CFUW Ontario Council representing women across Ontario, from small rural communities, to the larger cities and suburbs, to the many clubs in the Toronto area.

While we applaud some of the Provincial Government’s initiatives as introduced in the More Homes, More Choice Act in the Housing Supply Action Plan, Bill 108 in, not only bringing new housing online faster but also, in providing more housing options by “focusing the discretionary use of inclusionary zoning to protected major transit station areas”, we feel that inclusionary zoning needs to apply to ALL areas within the City of Toronto in need of affordable housing, not just in areas near transit hubs.

All three levels of government, federal, provincial and municipal, currently pay their fair share to create/maintain affordable housing. Perhaps it is time that developers share in the funding of inclusionary affordable housing, in particular affordable rental housing.

Although the UWCNY advocated for lowered development charges in its submission in January 2019 in response to the Increasing the Housing Supply in Ontario Survey, we have serious concerns regarding the proposed new framework for collecting and distributing the development charges to be levied by way of the creation of a new “community benefits charge” which combines three separate tools planners and cities now have, to secure cash for community benefits (such as libraries, community centres, child-care centres, etc.) as well as, the imposing of an unspecified cap on the amalgamated charges. We feel that both changes could greatly impact the “livability” of a particular development. As well, it puts cities to considerable unfunded expense if the development charges do not substantially cover these costs. In addition, the proposed requirement under the new legislation that 60 per cent of whatever is in the community benefits fund be spent or allocated in each calendar year, would serious impact more expensive projects which would have positive impact on many communities. It can take years to accumulate the necessary funds to finance these projects. Toronto’s 10-year soft service plan which was approved by Council could be one of the casualties of this new requirement.

In theory the changes as outlined in Bill 108 seem progressive; however, it is the execution of those changes (rules and regulations) that must be carefully crafted in order to have the overall desired positive effect, in particular, the creation of Affordable Rental Housing with both supportive infrastructure and services to support new buildings and soft services that benefit the community. We ask that the Government take its time to study the possible impact of these changes and create rules and regulations that support a positive outcome before passing Bill 108. After all, as the saying goes “The devil is in the details.”

Janet Gordon
President,
University Women's Club North York