Response to Regulatory…

Response to Regulatory Proposal for
Community Benefits Charge and Development Charges
April 20, 2020

Habitat for Humanity’s Ontario affiliates appreciate the opportunity to provide feedback to the Government of Ontario’s regulatory proposals pertaining to the Community Benefits Authority under the Planning Act, the Development Charges Act, and the Building Code Act (ERO 019-1406). Balancing the needs of both municipalities and developers is critically important in order to build and maintain long-term affordability in the housing sector and to create livable communities.

As part of our feedback, please receive the top two (2) recommendations of Habitat for Humanity affiliates in Ontario:

1. With the provincial-federal Investment in Affordable Housing program ending in 2020, we believe it is important the Government of Ontario ensure that equitable, accessible resources are available to develop and maintain affordable housing, including affordable homeownership, in our communities. Habitat affiliates in Ontario appreciate the Province listing “affordable housing” as an option into which municipalities could invest funds from the Community Benefits Charge (CBC), but feel strongly that the CBC should not be used to replace previously dedicated provincial funding streams for affordable housing/homeownership.

2. The Habitat for Humanity affiliates in Ontario strongly urge the Government to exempt not-for-profit affordable housing developers from paying CBCs.

Please also receive the following other recommendations from Habitat affiliates in Ontario affiliates:

3. Currently, Section 37 exempts housing developments under a certain size from paying fees for funding community benefits and infrastructure. The regulatory proposals, as stated, do not include a similar exemption. If the intent of the Government is to facilitate and increase access to affordable housing, then Habitat affiliates in Ontario recommend the inclusion of such an exemption to ensure that developers are able to continue building affordable housing.

4. The regulatory proposal, as currently written, provides neither sufficient clarity nor predictability for housing developers relative to the payment of fees. The current proposal could lead to a significant increase in fees paid and result in significant differences in fee schedules from municipality to municipality. Access to a standardized approach/formula for determining these fees is of critical importance to housing developers, especially in the early stages of planning housing developments as this impacts both the establishment of project costs and setting of house prices. This Government has committed to the removal of red tape and obstacles to affordable housing development. The absence of clear, consistent, guidelines relative to the setting of these fees is a critical obstacle to affordable housing/homeownership.

5. As proposed, the Community Benefits Charge is intended to be a municipality-wide fee. However, land values vary significantly across the Province, especially in urban areas where there may be significant differences in land values, even within a single municipality depending upon its geographic boundaries. The Province should allow municipalities to consider basing the fees on land value, and potentially differentiating between residential and non-residential developments.

6. Habitat affiliates in Ontario recommend the Province mandate that municipalities provide established and uniform notice periods regarding their community consultations prior to finalizing and implementing their bylaws.

7. Given the importance and implications of this regulatory proposal, Habitat affiliates in Ontario strongly urge the Government to include a one-year review period, post-implementation, to determine how the new Community Benefits Charge is impacting communities, to receive feedback from stakeholders and to make changes that balance the interests and produce the best outcomes possible for all parties affected.

Thank you for the opportunity to respond. If you have any questions or require further information, please contact:

NAME: Sarah Reaume
Chair
Government Relations Committee
Ontario Caucus, Habitat for Humanity
…or
Amanda Thambirajah
Director, Government Relations
Ontario Caucus, Habitat for Humanity

CONTACT INFORMATION
c/o 1800 Appleby Line
Burlington, Ontario
L7L 6A1
(905) 637-4446 Ext. 235 (Office)
(519) 402-0887 (Cellular)
sreaume@habitathm.ca or amanda.thambirajah@habitathm.ca