October 27, 2023 Subject:…

October 27, 2023

Subject: Consultations on Affordable Homes and Good Jobs Act 2023, Bill 134
ERO Posting 019-7669

Ruchi Parkash,

I want to express our comments and concerns about Bill 134, Affordable Homes and Good Jobs Act and housing affordability in the Town of Saugeen Shores.

Our municipality generally supports this amendment; however, we have noted multiple issues that we would like the Province to consider before implementing this Act.

1) Importance of Affordable Residential Units Bulletin in order to provide an informed response.

At this time, the Province has not provided an Affordable Residential Units bulletin that has yet to be shared or may not be shared until the Act is in effect. This bulletin information is critical in providing an informed response and in determining the potential implications this bulletin will have on Saugeen Shores.

We ask that the Province provide this bulletin to municipalities prior to the Act taking effect to fully understand the impacts on our communities.

2) The housing market’s complexity will have a greater effect on housing affordability and supply.

Housing affordability and supply is complex. Several factors can affect supply and prices -- because they are largely market driven – and the industry is incentivized to maximize profits. Bill 134 does not provide clarity on whether savings from the discounted mandate are recouped directly by developers or passed onto future homeowners.

3) The Province needs to frequently monitor and update the Bulletin.

Because of the complex housing market, the Province needs to frequently update the bulletin to reflect current market conditions. If it is not monitored and updated, municipalities could anticipate unforeseen impacts on development and financing due to significant development opportunities.

4) Forecasted eligible housing would exclude many housing types and low- income residents from affording such units.

The forecasted affordable ownership eligible for exemption would exclude many housing types and may include bachelor/ studio or one-bedroom apartments. Thus, the forecasted affordable rent and ownership as per the proposed definitions in Bill 134 are still out of reach for many of our low-income population from affording any of the above housing types.

5) The Development charge exemption in the site planning process creates additional levels of red tape and confusion.

Legislation requires developers to confirm their intent to build affordable housing. However, the criteria outlined in this Act do not allow municipal staff to confirm whether the proposed affordable units are affordable until the end of the development process. Thus, staff would be required to charge the developer applicable development charges and provide a refund once the developer can demonstrate it has met those criteria.

This does not remove barriers from the planning process; instead, it adds additional processes, time and money spent.

6) Enforcing 25+ year agreements for future buyers Is cumbersome.

As per the Development Charges Act, a residential unit intended to be affordable for a period of 25 years or more is exempt from development charges and the local municipality shall enter into an agreement to ensure criteria is met. This would require the agreement to be registered on title so future buyers are aware of financial terms and conditions. If compliance is no longer met, the new owner may be required to reimburse the municipality for Development Charges. This would consume substantial administrative resources that could be better spent on initiatives to build more homes.

7) Administrative burden of enforcement on rental agreements and compliance.

In order to determine rental unit’s affordability compliance, rental agreements would need to be obtained for each individual unit to ensure it meets the bulletin criteria. This will create a significant administrative burden on already depleted staff that are trying keep up with the Province’s ongoing initiatives while trying to focus on local planning barriers.

8) Lack of information regarding attainable housing.

In addition to affordable residential units, Bill 23, More Homes Built Faster Act. also identified attainable units as exempt from development charges. We ask the Province to consult with municipalities to clarify what types of development would qualify as attainable housing as this is not addressed in the newly proposed Bill.

We commend the Province for their attention to such a pressing issue and welcome the opportunity to discuss the above comments and concerns as it relates to affordable housing and Bill 134.

We look forward to working with you.

Sincerely,

Luke Charbonneau
Mayor
Town of Saugeen Shores