Weston Consulting is the…

Weston Consulting is the planning consultant for the Bowmanville North (Soper Springs) Landowners Group, a group that consists of several landowners with holdings in the Soper Springs Secondary Plan Area:

Estates of Soper Creek Corp., Jayzee Properties Inc., and Sharno Holdings Inc. which totals 109.68 ha

The above landowners consist of approximately 61% of the total landholdings within the Bowmanville Soper Springs Secondary Plan Area. At this time, we are submitting this correspondence on behalf of the above landowners, which expresses opposition to the adoption of the proposed regulations associated with the new Community Benefit Charge (CBC).

It is our understanding that pursuant to June 2019 and the introduction of Bill 108, the new CBC was created to allow municipalities to impose a charge to pay for capital costs of facilities, services or matters due to development and redevelopment. The adjustment of eligibility of services to parks and other services and facilities items creates an overall increase as further described below. The movement of services from the collection from Development Charges (DC) to CBC creates a cause for concern within the local development community and specifically those owners above, whom we represent.

We understand that the introduction of the CBC and its intention, in the form of the regulations presented for comment and review, would bring about changes to DCs. As the CBC introduces the removal of 10% statutory deduction for soft services and causes some services to no longer be eligible for DC recovery, this will result in an increase to DCs for most municipalities, including Clarington.

At this time, neither Bill 108 nor the regulation proposal, provides for a methodology or imposes any explicit rules on the calculation of the CBC, which give cause for some concern as to the application of the methodology and the impact it may have in certain municipalities.

At this time there is a lack of clarity around the preferred methodology of the intended CBC calculations. In the absence of said methodology, it is appropriate to have avid stakeholder participation, through additional reviews and evaluations, as well as supplementary guidance from industry experts.

According to analysis completed by professionals in the development industry that we and the owners are aware of, it is our understanding that based on preliminary calculations, the expected increase to development fees and levies within Clarington for low-density and high-density development, is significant and is disproportionately impactful to low rise built form typologies in comparison with higher density built form typologies.

Based on some information and analysis by others, we are aware of impacts for a single detached unit could be an increase in development fees between $20,000 and $30,000 per unit, which has a great impact on overall development costs and the development of lands in Clarington and in our opinion, impacts affordability considerations generally in relation to the housing market.

These inconsistencies and significant potential increases in costs to the delivery of a full range of housing to the market give great cause for concern as the inequity between low density and high-density housing types impact market areas where predominate forms of housing are lower density as is the case in Clarington.

The initial change to the CBC was to have the intended revisions be neutral to costs and/or revenues and to not generate a significant additional cost burden on the development community. The above concerns represent a departure from revenue neutrality, in order to keep services funded from development projects.

In addition, the owners have concerns with regards to the percentage cap associated with land value as well as the time at which land value is to be assessed for valuation purposes.

At this time, we express on behalf of the above noted owners, opposition to the CBC regulations in the form presented and recommend that the Province consult with industry professionals, the development community, and homebuilders associations to have the proposed regulations modified and adjusted to better address the concerns herein and those from other industry representatives.

If you have any questions or comments, please do not hesitate to contact Ryan Guetter at 905-738-8080 ext. 241 or Paul Tobia at ext. 290.

Yours Truly,
Weston Consulting