With respect to the Proposed…

With respect to the Proposed Planning Act and Development Charges Act, 1997 Changes: Providing Greater Cost Certainty for Municipal Development-related Charges, please find my comments below:

The proposed changes to the Parkland Dedication Requirements (reduction and capping of the alternative rate) will result in lower quality parks, reduced standards for parkland provision, and less access to parkland. The proposed caps in Bill 23 would undermine the principle that growth pays for growth and ensuring the development of strong complete communities. Funding shortfalls will be transferred onto the tax base reducing overall affordability in municipalities.

If anything, COVID has demonstrated the need for more accessible, quality parks, however these legislative changes goes against this trend/demand. The province should restore the former rates, or at the very least remove the funding cap.

Allowing developers to identify the lands they intend to convey will result in dedication of small portions of undevelopable lands or remnant parcels that are unsuitable for functional parkland. A developer wants to optimize the amount for land for profit. To give away suitable land would hit their bottom-line, so there is no incentive from a developer perspective. The municipality understands the context and the needs of the entire City/Town and will have to control parkland provision. Not stuck in appeals with a landowner who only sees their piece of land. Residents will be left in sprawling communities with no adequate parkland service levels. It would be important that the Province revert back the ability for landowners to determine park locations and configurations. If not, at a minimum ensure dedications are contiguous, link into the existing parkland network, have public street frontage, visibility, and are in suitable condition.

The proposed change that requires full parkland credit for encumbered parkland (e.g. POPS, strata ownership), will result in less unencumbered parkland in growth areas. Encumbered parkland does not provide the same park service level as a publicly owned and operated park. Municipalities will have less control over the lands and how it is developed, further reducing its ability to meet service level demands. POPS have limited park programming ability, are subject to maintenance and operational restrictions and will not support mature trees (shade). The Province needs to remove 100% credit for encumbered lands or POPS, or at least roll it back to some lesser amount to disincentive developers providing encumbered parkland or POPS over a public park.

I agree that Parkland Dedication Exemptions are needed but it needs to be balanced and identified where appropriate. While reducing municipal requirements for the conveyance of land or CIL of
parkland may offer greater opportunities for developers to create additional affordable housing units, the proposed parkland dedication exemptions will increase the financial burdens on municipalities. Further, the type of parkland in new communities will be far less than older ones and will not have that accessibility that young families can enjoy. In any community it is always parks and open spaces that are the top comments in any city-wide survey. We are clearly moving away from that.

The Minister's letter to the AMO is short-sighted and pro-development. There needs to be consideration given to the type of communities that will actually be built in the next 10-15 years. These changes claim to make housing more affordable to the average citizen but it would seem the discounts and exemptions benefit the developers. There is nothing in the legislation that ensures the potential home-owner benefiting from these breaks or receiving a refund.

Overall, there are major concerns in how the province is moving forward and how future communities will be developed. If we are looking to ensure complete communities this is not it and cannot be supported.