The Georgian Triangle…

The Georgian Triangle Development Institute, is a private sector non-profit organization which represents the Development Industry within the South Georgian Bay Region. Our members include developers, builders, contractors, suppliers, planners, engineers, real estate firms and related industry businesses within the Georgian Bay area. As an organization, we are supportive of the More Homes, More Choice Act, 2019 (Bill 108) and the Housing Supply Action Plan.

Our members have been key in driving significant components of our regional economy, through the jobs we provide, and the infrastructure, commercial buildings, homes, recreational amenities, and community facilities that we design, build, and manage. There is no person, resident or visitor, of the communities of Meaford, The Blue Mountains, Collingwood, Wasaga Beach, or Clearview whose lives have not been improved by the work of our members. Our membership is equally concerned as our fellow citizens and elected officials with the critically important issues of: attainable, accessible and appropriate housing for all; environmental and economic sustainability; exceptional school facilities; and adequate community infrastructure. However, we are writing this letter in response to the regulatory consultation, because the proposed Community Benefits Charges (CBC) framework will have a profound, often negative, financial impact for our communities and membership.

Our concerns on the proposed community benefits authority under the Planning Act and Development Charges Act relate to how they may result in drastic increases in fees and charges for new housing in Simcoe and Grey Counties. The effect would be to make new housing of all types more expensive unless changes are made that better reflect the lower-density, primarily ground-oriented, housing that represents our region.

Not only would the increased charges be ultimately borne by the home purchaser, the financial obligations will be magnified by the fact that a proportional share of these costs will be paid for through home financing. This will therefore, result in people paying significantly more than just the Community Benefit Charges, but also the amount to service the debt for the lifetime of their home mortgage. Taken across an entire neighbourhood of new homes, this could easily result in millions of dollars being diverted from local economies to servicing the financing of these proposed CBC.

We suggest that refinements be made that address the following:
i. Specifically defined requirements for background reports and studies that will be used to identify eligible and ineligible service items that can be funding through this process. Service standards must be applied for municipal implementation of CBC by-laws and strategies. There must also be a robust framework in place to ensure fairness, accountability and transparency for the new CBC framework;
ii. There should be no CBC for low-rise greenfield development. The CBC framework should only apply to high density development. Growth should pay for growth and municipal revenue streams should be protected via Development Charges and parkland dedication in accordance with section 51.1 of the Planning Act. This would ensure GTDI members can work with our municipal partners to ensure we are building complete communities and providing physical parkland.
iii. Land appraisals for these charges should happen earlier in the process, so that they do not “tax” the extensive infrastructure investments. As currently proposed the appraisal and valuation would occur when the land value is the highest after the development proponent has built and paid for significant infrastructure into the ground.

The GTDI has been supportive of this provincial government’s initiatives to address housing supply challenges. However, we are very concerned that the changes as proposed will result in significant increases to the cost of low-rise housing in our region.

The GTDI looks forward to working with the Ministry and all stakeholders to establish a fair CBC framework.

Sincerely,
Robert Voigt, RPP, MCIP
President, GTDI