To Whom It May Concern, The…

To Whom It May Concern,

The City of Brampton has several comments and questions in relation to the Environmental
Registry of Ontario posting 019-6172 - Proposed Planning Act and Development Charges Act,
1997 Changes: Providing Greater Cost Certainty for Municipal Development-related Charges.
The City of Brampton (hereinafter referred to as ‘the City’) is supportive of efforts by the Province
to address the housing affordability crisis. The City has reviewed the draft legislation and offer the
following comments to assist the province. Through our assessment of the proposed changes to
the Planning Act and Development Charges Act it is clear that the financial burden of financing
growth related infrastructure and studies is proposed to be shifted from proponents of
development to the tax base by increasing property taxes or reducing services to make up the
elimination of revenue sources. This will ultimately make housing less affordable for existing
residents. Additionally, in the absence of provisions to replace the loss in DC revenues, the
proposal will erode the ability of municipalities to pay for growth-related infrastructure.

The proposed changes erode the affordability of existing homes and undermines the long-established
principle that growth should pay for itself. Without a new revenue stream to offset
these foregone DC payments the legislation will hamper the ability of municipalities to fund and
deliver growth-related infrastructure. More specifically,
The significance of this revenue reduction cannot be overstated, as there are no provisions
though provincial-municipal revenue sharing, or new revenue raising tools, to make up for
the loss. Instead, DC revenue shortfalls will have to be funded through increases in
property taxes or reduction in services.
With the likelihood of additional municipal property taxes being needed to cover DC
shortfalls, municipal councils may need to delay the delivery of growth-related
infrastructure. Such delays would not be in the interests of either municipalities or the
development industry and would be contrary to the government’s efforts to spur housing
construction.
The DC reductions may undermine municipal-developer infrastructure cost sharing
agreements that facilitate infrastructure in high growth areas of the province. These complex agreements facilitate infrastructure using DC credits or reimbursement through
future DC revenue. They often require the municipality to have DC revenue on hand before
issuing reimbursements. In such cases, DC revenue shortfall arising from Bill 23 would
delay repayment, to the financial detriment of developers who are parties to such
agreements.

In summary, the Government’s efforts to promote the construction of new affordable, rental, and
non-profit housing through targeted DC incentives will to an extent be supported by the proposed
changes to the DC Act. However, in the absence of provisions to replace the loss in DC revenues,
the initiative will erode the ability of municipalities to pay for growth-related infrastructure.
Additionally, further changes to the Planning Act to reduce parkland requirements will place
significant downward pressure on the amount of parkland dedication provided to municipalities
and without a corresponding increase in revenue, the proposed changes will result in a drop in
service provision and fewer amenities, particularly for newly developed communities without a
corresponding increase in other revenue streams. This would shift the financial burden of growth
from developers to taxpayers, feeding into Ontario’s affordability crisis.

Sincerely,

Steve Ganesh, RPP, MCIP
Commissioner (A),
Planning, Building & Growth Management

Nash Damer
Treasurer,
Corporate Support Services

Rick Conard
Commissioner (A),
Corporate Support Services

Bill Boyes
Commissioner (A),
Community Services