City of Brampton May 29,…

City of Brampton

May 29, 2019

The Honourable Doug Ford
Premier of Ontario
Legislative Building
Queen's Park
Toronto ON M7A 1A1

The Honourable Steve Clark
Minister of Municipal Affairs and Housing
17th Floor, 777 Bay St.
Toronto ON M5G 2E5

Re: Bill 108, More Homes, More Choice Act, 2019

Dear Premier Ford and Minister Clark:

The City of Brampton appreciates the opportunity to provide comments on Bill 108, More Homes, More Choice Act, 2019. The City supports the need for greater housing affordability in Ontario, and is currently developing its first affordable housing strategy, Housing Brampton, to improve housing choices and affordability for all our residents.

Our initial review and analysis of Bill 108, which unfortunately was introduced following very little consultation with municipalities, suggests that the proposed changes within the legislation are unlikely to achieve its intended outcomes. For example, there is no evidence to suggest development charges (DCs) or parkland dedication requirements have an impact on the price of new housing. At the same, a glaring omission in the legislation is any means by which the savings from Bill 108 to developers would be passed along to prospective homebuyers.

Although the lack of consultation with municipalities prior to the introduction of Bill
108 is disappointing, my most pressing concern is that the 30-day commenting period respecting the ERO postings is simply inadequate. Bill 108 proposes significant changes for land use planning related decision-making processes and reductions in the collection of DCs. We require additional time to analyze and understand the full impact, and to consult with our residents, who will ultimately be directly affected by many of the proposed changes.

Brampton City Council is formally requesting an extension to the consultation period, and that the Province conduct meaningful consultation with municipalities and other stakeholders prior to the Legislation receiving Royal Assent, which I understand is scheduled for as early as June 4, 2019.
In the meantime, included with this letter is the City of Brampton’s detailed report as well as our consolidated recommendations and amendments to Bill 108.

The City’s The City is interested in continuing to engage with the Province as it moves forward to ensure that available housing within GTA and across the Province is affordable.

Sincerely,
Patrick Brown
Mayor

City of Brampton Recommendations/Comments:

Development Charges Act
Bill 108 - (Schedule 3) – the proposed More Homes, More Choice Act: Amendments to the Development Charges Act, 1997 (ERO 019-0017)

City Recommendations:
1. That the DC rate be set at the issuance of the first building permit, in accordance with the changes made in 2016.
2. That the Province delete a mandatory delay of payment of development charges and allow municipalities to continue to use the current DC deferral authority in the Act.
3. That DC deferral agreements be registered on title to the property, and enforceable against future owners.
4. That in the event of a change of use from a use listed under subsection 26.1(2) occurs prior to occupancy, the owner will be required to pay all the development charges incurred for the development immediately, as set out in subsection 26.1(9).
5. That current development charges by-laws and any development charges by-laws passed prior to issuance of the regulations related to CBCs, remain in effect until the later of four years from the date of passing of regulations relating to CBCs, or the expiry of the development charges by-law.
6. That the parkland and community infrastructure provisions remain in effect until such time as current development charges by-laws and any development charges by-laws passed prior to issuance of the regulations related to CBCs have expired, and the Community Benefit Charge Strategy and Community Benefit Charge By-law has been completed.
7. That Subsection 2(4) be amended to add "parks, recreation and libraries” as growth related capital infrastructure.
8. That the authority to add unpaid development charges to the tax roll be amended to add that any amounts so added will have priority lien status.