The Federation of North…

The Federation of North Toronto Residents’ Associations (FoNTRA), representing 30+ residents’ associations with thousands of members in the North Toronto area, strongly objects to:

1) The proposed deferral of development charges for any types of developments.

Development charges provide municipalities with the necessary funding to ensure that facilities and infrastructure such as transit, roads, water and sewers, police and fire facilities, etc. keep pace with development and are constructed in a timely manner.

Delaying payment of those charges for many types of developments is effectively an unsecured loan from municipalities to developers, which is not sound fiscal management.

As a result, municipalities may have to ‘front-end’ the cost of new required infrastructure and transit construction as they wait for development charges to be paid over longer periods.

Under the concept of ‘Growth pays for Growth’, proposed legislative changes to development charges should be not only ‘revenue neutral’, but also ‘cashflow neutral’.

2) The establishment of development charges at an earlier stage – at site plan or zoning approval application rather than at building permit application.

Our experience with development in Toronto Midtown is for long delays between a site plan or zoning approval application and the actual request for a building permit. There are frequent instances in our area of delays of even 5 to 7 years.
Development charges established during the site plan or zoning approval application to fund necessary municipal infrastructure upgrades or community facilities, can become outdated by the time the developer applies for a building permit, thanks to rising construction costs. This could result in significant financial impacts to municipalities.

3) The provision for municipalities to charge interest on ‘deferred’ and “frozen’ development charges.

We would object to municipalities acting, in effect, as financial institutions by having to collect and negotiate interest on development charges, a task made even more difficult with the frequent changes in the of ownership of developments. Again, this is not fiscally sound management.

Respectfully submitted,