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August 21, 2019

Dear Madam/Sir,
Please accept this submission as Environment Hamilton’s formal comments on proposed changes to O. Reg. 82/98 under the Development Charges Act related to Schedule 3 of Bill 108 - More Homes, More Choice Act, 2019. We have a number of issues and concerns that we would like to raise regarding these proposed changes.

We share concerns being raised by our own municipality and by the Association of Municipalities of Ontario regarding their worry that new development is already not paying for itself and these proposed provincial changes may well make the situation even worse. Growth must pay for itself! We are also concerned that the changes being proposed appear to be part of a larger effort to facilitate development that, first and foremost, benefits the developer. Now more than ever before, Ontario needs a planning framework that promotes and facilitates the development of compact communities that are climate resilient. This means building complete communities that are transit supportive and that encourage active forms of transportation. It also means that we need planning rules that are focused on the public good. We fear that many of these changes, when considered together, will take us in a direction that is not in the public’s best interests.

With respect to the new Community Benefit Charge, we worry as other stakeholders do, that the new framework will not provide municipalities with adequate support to finance soft services in new and intensifying neighbourhoods. This is a huge concern; quality of life elements become that much more critical as urban areas are intensified. We urge the province to ensure that it is developing and implementing approaches that empower municipalities to create resilient communities with high quality of life. Our understanding of the concept of a ‘Community Benefit Charge’ is that it should provide adequate support for the creation of the amenities and features that make neighbourhoods liveable.

The proposed changes to the development charges framework is also cause for concern. While we support the proposal to provide delays on payments of DCs for nonprofit housing and institutional buildings, we have concerns about offering this same accommodation to industrial and commercial developments. Again, this would generate yet another potential financial burden for municipalities – at a time when, we note, municipalities are facing many provincial cuts that are generating challenges. We support the tool as a means to encourage more affordable housing construction.

We are very supportive of the elimination of development charges for the creation of additional dwelling units under a variety of circumstances. We are eager to see more gentle density/ missing middle development happen in urban areas of Hamilton – for good reason. It makes sense to maximize the use of existing infrastructure and to build up the population base in urban neighbourhoods in order to support local transit services and generally create more liveable, amenity-rich urban neighbourhoods. This approach will also help with providing more much-needed and affordable housing in urban areas of cities like Hamilton.
We thank you for the opportunity to comment on this proposal.

Lynda M. Lukasik, PhD
Executive Director

Environment Hamilton
22 Wilson Street, Suite 4
Hamilton, ON L8R 1C5
TEL: (905) 549-0900