Drewlo Holdings Inc. has…

Drewlo Holdings Inc. has significant concerns with the proposed implementation of a Community Benefits Charge and would offer the following comments:

Ensure a direct connection to growth - We agree that 'growth must pay for growth' and would implore the Province to implement regulations that dictate what can and cannot be collected through the Community Benefits Charge.

We recognize that the needs of each municipality are different. However, are concerned that without explicit "do's and don'ts" municipalities may abuse the charge. For example, the City of London (staff) have already presented that the CBC may be used for the provision of affordable housing. Housing affordability and the provision of affordable housing is a community-wide issue and is in no way connected growth. It is inappropriate to collect for affordable housing through Development Charges or Community Benefits Charges.

In the same way a list of collectable items was added to the Development Charges Act, a list of items for Community Benefits Charges should be added to the Regulations.

Implement 'As-of-right' Zoning - Many municipalities, including the City of London, have implemented Bonusing as a form of extortion. Developers are now left with Official Plan's and Policy documents that have effectively down-zoned the entire planning area.

For example, the London Plan (the Official Plan document for the City of London) stipulates a maximum height of 20 storeys within the Downtown, this height could be further increased to 35 storeys through Bonusing. The removal of Bonusing, without direction from the Province, is the antithesis of the intent of Bill 108. The Province should implement 'as-of-right' zoning, allowing the max height permitted under previous Bonusing to be the new height (in the example above 35 storeys would be the new max height), to ensure height and density are not negatively impacted.

As noted in the attached letter, we also have serious concerns with the calculation of the CBC, including valuation of lands and dispute. We look forward to the opportunity to comment on this through future ERO posting.