To: Hon. Doug Ford, Premier …

To: Hon. Doug Ford, Premier
Hon. Steve Clark, Minister of Municipal Affairs and Housing
Hon. Michael Parsa, Associate Minister of Housing

December 6, 2022

RE: Bill 23 More Homes Built Faster Act

The Municipality of North Perth appreciates that housing is a top priority for the Province and shares the desire for more homes, especially affordable homes. However, following a high-level review of the proposed legislation, the Municipality of North Perth believes that Bill 23 will do little to accomplish this goal.

Firstly, we appreciate the opportunity to provide comments on this matter, but find it important to acknowledge that staff and Council of the Municipality require more than 30 days to digest and respond to a complex piece of legislation affecting nine existing Acts.

North Perth was disappointed to learn that Bill 23 received Royal Assent on November 28, 2022, despite the Province extending the comment period to December 9th. The Municipality feels that this further proves that although municipalities are the most informed on local housing issues, the Province does not view them as a strategic partner in solution finding and action.
As outlined below, the Municipality of North Perth has several concerns to date with the legislation.

The bill, as it is currently written, would eliminate the charges that developers currently pay toward housing. This will eliminate hundreds of millions of dollars that municipalities rely on for housing programs and dramatically reduce municipal affordable housing efforts.

Development Charges (DC) are designed to help municipalities pay for a portion of the capital infrastructure required to support new growth, to ensure that existing taxpayers are not required to subsidize costs of the infrastructure or services needed to support new residents and businesses. Without a new revenue stream to offset DC payments, the legislation hampers the ability of municipalities to fund and deliver growth-related infrastructure. The changes to the Development Charges Act fundamentally impacts municipalities’ ability to ensure growth pays for growth.

The changes to the various Acts have significant financial impacts on Ontario’s municipalities along with their respective taxpayers. It is anticipated that these changes will put additional pressure on property taxes and water and wastewater rates. Property taxes and user fees are crafted to fund projects and programs that communities need, however adding more costs to existing property owners will increase their costs and could negatively impact their ability to keep their current housing affordable. Provincial legislation should not unduly burden homeowners and renters to guarantee the long-term success of solving the housing crisis.

Municipalities are extremely limited in the ways that they can collect revenue, relying on transfers from other levels of government to mitigate property tax rate increases, fund critical infrastructure and balance annual budgets. Municipalities already face an infrastructure funding gap that requires additional financial investments, resources and supports. Planning for increasing additional dwelling units will place more strain on water and wastewater systems which will require upgrading to increase capacity. This will require additional financial resources to manage, at a time when municipalities are already facing increased budgetary pressures due to inflationary costs, increased citizen expectations and the transfer of responsibilities from the Province. Without additional funding or resources from the Province to offset these costs, municipalities will have little option but to put these costs back on the taxpayer.

The amendment that all DC by-laws passed after January 1, 2022 (previously June 1, 2022) must be phased-in for the first five years that the by-law is in force will have an overall negative consequence to the goal of building more housing. The phase-in will delay necessary infrastructure projects to unlock growth while also providing incentives for development projects to be delayed until a new by-law is enacted.

Growth-related infrastructure often centres on the infrastructure itself, but a critical piece towards infrastructure is the land required to build. Land represents a significant cost for some municipalities in the purchase of property to provide services to new residents. This is a cost required due to growth and should be funded by new development. Studies, such as Official Plans are required to establish when, where and how a municipality will grow. These growth-related studies should remain funded by growth. Master Plans and environmental assessments are essential to understand the servicing needs development will place on hard infrastructure, again necessary studies to inform the servicing required to establish the supply of lands for development. This would restrict the supply of serviced land and would contradict the province’s intent to create additional housing units.

Parkland dedication levies exist to ensure that municipal park systems grow alongside other community developments. Increasing the supply and mix of housing is an important goal that we all share; however, sufficient access to parks and greenspace cannot be overlooked as we try to create meaningful alternatives to single-family dwellings. Municipalities already face challenges with the supply of adequate parkland due to the rising cost of land and current limitations under the Planning Act relative to municipal parkland standards.
Upper-tier and single-tier municipalities across the province utilize DCs to help fund the construction of new affordable housing units with the goal of providing affordable housing to those in need. The removal of housing services and limiting the tools available to municipalities to support homeless and underhoused people and families will reduce municipality participation in creating affordable housing units, putting further burden on municipal taxpayers.

In order for the Province to successfully achieve the goal of building 1.5 million homes within the next ten years, municipalities must be viewed as strategic partners. As the frontline level of government, municipalities are also eager to resolve the housing crisis and are the most informed on what is needed to create complete communities that the people of Ontario want and expect.
Please consider revisions to the regulations in Bill 23 for more meaningful review and consultation with stakeholders and input from municipalities, and conduct thorough analysis of both short and long-term impacts. To ensure informed implementation of this proposal, alternatives to improve the legislation to effectively create more attainable housing for Ontario need to be considered.

Sincerely,

Todd Kasenberg, Mayor
Municipality of North Perth
330 Wallace Ave. N Listowel, ON N4W 1L3
toddkasenberg@northperth.ca

CC:
MPP Matthew Rae
Environmental Registry of Ontario
All Ontario Municipalities