Please accept the attached…

Please accept the attached from the Greater Ottawa Home Builders’ Association (GOHBA) and its members as a submission to the government’s request for feedback on Changes to the definition of an “Affordable Residential Unit” in the Development Charges Act, 1997 for the purpose of municipal development-related charge discounts and exemptions.

We have submitted the same comments, seperately, for ERO #019-7669 and 23-MMAH017.

Extract of Comments:

Based on our members’ experience and expertise across Ottawa’s housing market, GOHBA does not anticipate that the definition of an Affordable Residential Unit as proposed provides sufficient incentive for new home builders to move forward with housing projects at the deep level of affordability as envisioned by the ministry.

We caution the Ontario Government to set realistic expectations for what this exemption can achieve for generating market-driven, deeply affordable housing supply.

Based on our preliminary assessment and review of the proposed definition, informed by up-to-date data, we are providing the proposed insights and recommendations below to improve upon the proposed definition.

• Update the Affordable Housing Bulletin semi-annually using current and regularly updated data.

• Modify the parameters of the Affordable Residential Unit definition for rental.

If the Ministry is committed to providing a sufficient incentive for private sector developers, we would propose, in identifying the income-based affordable rent applicable to a residential unit:

o Change the threshold used for gross annual incomes for renter households from the 60th percentile to the 75th percentile; or,

o Use median income for the identified municipality, rather than gross annual income for renter households. Incomes vary dramatically across the province. A “one-size fits all” regulation will not yield the results intended by the province.

• Focus development-related charge exemptions for ownership on the appropriate housing types.

If the Ministry is committed to providing a sufficient incentive for private sector developers, we would propose:

o Increase the annual accommodation costs threshold to a minimum of 40%, up from 30% as proposed; and

o Limit the development-related charge exemptions for Affordable Housing Units in the ownership stream to a maximum of 2 bedrooms, while offering a broad-based exemption through the forthcoming Attainable Housing Unit definition.

Thank you for the opportunity to provide comments on the government’s proposals.

We are pleased to answer questions or provide further information as requested.

Sincerely,

Jason Burggraaf
Executive Director