ERO# 019-6172 Proposed…

ERO# 019-6172 Proposed Planning Act and Development Charges Act

Parkland

Changes to the parkland dedication rate, which reduce the current rate of one hectare for each 300
dwelling units to 1 hectare for 600 units and the changing of cash in lieu payments from the rate for 1 hectare for 500 units to I hectare for 1000 units will deprive residents of the greenspace they need for physical and mental health.

As we saw during COVID, parks and conservation areas were overrun with people, desperate to find some comfort in the outdoors. We need more park space not less, especially as density increases in our urban areas.

Allowing developers to identify land, including encumbered land (e.g., land with underground transit tunnels or other infrastructure) and privately owned public spaces that would count towards any municipal parkland dedication requirements is pure folly. Saying disputes can be taken to the OLT is not realistic as municipalities don’t have money to waste on costly OLT cases which means the developers will be able to claim any piece of green or hard landscaped area is “public parkland”. I have already seen a development application that claimed the Entranceway to the development was public parkland. Ridiculous.

Development Charges (DCs)

As you know, municipalities across the Province have been sounding the a alarm on development charges reductions including eliminating things like some studies and services from being paid for through DCs.

Our municipalities need DCs to pay for development-related infrastructure. It doesn’t matter what kind of housing is being built, the same infrastructure and services are required.

Removing this obligation from developers will foist the burden on existing homeowners through increased municipal taxes. I am not in favour of this at all but if the government goes through with it, I am entirely happy with the proposal that will list the resulting increased property tax cost as a Provincial surcharge on municipal tax bills.

The Provincial government claims, DCs reductions will save new homeowners money. This is a joke because there is nothing in the legislation that requires developers to apply the savings to the costs of new homes. All this will do is fill developers’ pockets at the cost of emptying those of existing homeowners and depriving municipalities of the funds they need to provide infrastructure and services to their citizens.

I have also heard the claim that municipalities can apply to federal funding to make up for infrastructure shortfalls. Why should the Canadian taxpayers at large pick up the tab for your government giving developers a break on fees they should be paying? Growth should pay for growth.

If you want efficient growth that doesn’t cost as much to support with infrastructure and services then you would be concentrating on building within existing urban boundaries where infrastructure and services already exist, not on areas where you have forced municipal boundary expansions, former Greenbelt lands and Conservation Areas that you plan to sell off.

Requiring municipalities to allocate or spend at least 60 per cent of their development charges reserve balance for water, wastewater and roads at the start of each year makes no sense. Municipalities have to plan for the long term and the unexpected. They know best how to manage their budgets and plans for infrastructure renewal and maintenance without interference from the Province.

This line is also extremely troubling: “Regulation-making authority would be provided to prescribe additional priority services, for which this would apply, in the future.” Municipalities need the authority to manage their own financial and capital assets according to their own needs and priorities.

Rental Housing, Affordable Housing, Gentle Density, Attainable Housing

It doesn’t matter what kind of housing is built, people still need clean drinking water, sanitary sewers, parkland, and community amenities. Reducing development charges on these types of housing/developments does not provide the municipality with the money it needs to provide that infrastructure, and those services and amenities. And again, there is nothing in the bill that guarantees the developers’ reduction in fees would lower the cost of the units for new homeowners/tenants.

The kind of neighbourhoods you would be creating with these plans defies good urban planning, creating unlivable areas that offer residents none of the placemaking/parkland/amenities that make a great neighbourhood — the very things that are critical when you are packing more people into smaller areas.

Encourage The Supply of Affordable Housing

You need to revisit your definition of “Affordable Housing” of being no greater than 80% of the average purchase price for ownership of 80% of the cost of the average rental. 80% of the current market price for homes or rentals is still way above what is truly affordable which should be no more than 30% of one’s income. And putting a 25-year limit on the units remaining affordable just create another crisis a quarter century from now. Why should units incentivized and built to be affordable ever lose that status?