- These steps do not follow…

- These steps do not follow the recommendations of the the Housing Affordability Task Force Report, which recommended the establishment of an “Ontario Housing Delivery Fund” to incentivize municipalities to build more homes (p24).

- The Niagara Region has calculated that it will lose over $37million in the first 5 years of this legislation, significantly negatively affecting its capacity to provide affordable housing. Where will the difference of this come from? Steve Clark claims that shortfall for the city of Toronto will be covered... but from where? The taxpayers will pay for the shortfall and the developers will pocket the funds.

- there is no reason to think that any home builder or developer will pass the savings in reduced development fees on to home buyers. They will instead charge the market rate to home buyers and pocket the difference. There is no evidence or measures being put in place to ensure the developer will pass the savings along to the buyer. The recent Barrie condo scandal proves this to be the case. Developers are in the business of making money, not charity. Premier Ford himself called the price increase imposed on these buyers "unfair." https://www.simcoe.com/news-story/10522731-ontario-premier-doug-ford-sa…

- The Task Force also recommended that “the province should consider partial grants to subsidize municipalities that waive development charges for affordable housing and for purpose-built rental.”(p24) This legislation fails to do this.

- Reducing Development Charges will make a bad situation worse as DCs do not currently cover the costs of developments. This is something that the Housing Affordability Task Force acknowledges when it writes, “most municipalities report that development charges are still not enough to fully cover the costs of building new infrastructure and retrofitting existing infrastructure in neighborhoods that are intensifying.” (p22)

- Where will the shortfall for the DC charges come from? Steve Clark claims that shortfall for the city of Toronto will be covered... but from where? If it is coming from the provincial coffers, then it is coming from taxpayers. This means the taxpayers are further subsidizing for the developers best interest and profit.

- in sum, reducing and eliminating Development Charges without replacing that funding will only bring revenue uncertainty to municipalities and their residents, as it passes costs from developers to taxpayers (or, takes money from residents and gives it to developers).
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