Thank you for the…

Thank you for the opportunity to comment on the changes proposed through Bill 23, and specifically Schedules 9 and 3. Attached is a report to the Council of the County of Brant that outlines preliminary comments on the proposed changes. These comments are also summarized below, specific to this ERO posting.

The County of Brant supports the position of the Association of Municipalities of Ontario (AMO) requesting provincial assistance to offset additional exemptions, discounts, and phase-ins. The County’s Development Charges Consultants, Watson & Associates estimates the reduction in Development Charge (DC) revenue to be 10% of the overall projected revenue, which based on the 2019 Background Study would be $15.7M over the 5-year study.

It is unknown what the uptake from developers might be to build affordable and attainable housing – this may depend on how the regulations define “affordable” and “attainable” housing. The amount of exempted development will dictate the financial implications on the municipality.

An administrative process will need to be developed to review the rent or sale prices to ensure they remain eligible and collect development charges if this changes.

Discounts on DCs for rental housing will need to be funded by property taxes or user fees. It does not appear that an administrative agreement is required for this, which may lead to possible repurposing of rental units after construction. How is it ensured that the rental housing will remain as such after the discount is applied and the unit is constructed?

The removal of housing as a DC eligible project may impact the viability / timing of these affordable housing projects.

The costs for studies where growth is a factor are significant and necessary to determine servicing needs. This will shift the burden of development-related costs to the tax levy or user fees.

The five-year phase in of the updated DC charge will encourage municipalities to wait the now 10 years before updating the DC background study and by-law. Based on volatility in inflation and construction costs, this may result in underfunding and a resulting larger increase in the next DC charges. The phase in will be funded from the tax levy and user fees.

As a small municipality with high growth, the level of service changes quickly. This amendment will result in basing future needs on the level of servicing available over the past 15 years.

The maximum interest rate is to be set at the average prime rate plus 1%. This matches the County of Brant's current DC interest policy.

The County of Brant is supportive of this initiative to ensure that DC reserves are allocated as detailed in the DC Background Study.