GR Update – May 9, Growth Funding Tools (“GFTs”)

We are sure most of you have been notified of the City of Toronto’s latest proposed increases to Growth Funding Tools (“GFTs”). GFT’s include Development Charges, Parkland Dedication or Cash-in-lieu, and the new Community Benefits Charges (replacing s.37). The City intends to introduce these proposals at City Committees in May with a view to seeking Council’s approval in June.  Going back many years, NAIOP has opposed efforts at expanding the scope of DCs and we are pleased to report that office above the ground floor and industrial uses remain exempt. However, the proposed increases to GFTs will impact a number of our members who have mixed-use communities under development.  We are full proponents that growth should pay for growth, and this is what these municipal financing tools are meant to address. However, these increases also fall on the coattails of Inclusionary Zoning which is requiring new home buyers of market units to subsidize affordable housing in some areas of the City. Unfortunately, the cost of housing will rise and the City’s competitiveness will be negatively affected.  

Just to highlight a few key impacts: 

  • After introducing the proposed GFT’s, government fees and taxes (including LTT and HST) account for approximately 39% of the cost of a new home (source: BILD).  
  • The City’s proposals will exert 15% inflationary pressure on new housing units (source: BILD).  
  • Inclusionary Zoning impacts are yet to be determined. However, the subsidy could exceed approximately $65,000 per market unit. 
  • The City will be more focused on securing actual land for parkland from development sites instead of cash-in-lieu payments.
  • Since the CBC Strategy is new, the real estate industry has concerns about a range of implementation issues in the transition from the s.37 regime. 

What is the ask? BILD and REALPAC are in regular discussions with the City of Toronto raising industry concerns with the proposed changes and seeking clarity on transition issues. If you are members of those groups, we encourage you to engage with our colleagues at those organizations to see how you can best assist their efforts.  

If you would like to discuss this further, do not hesitate to contact Leona Savoie, Dorsay, at, or Noah Gordon, Menkes, at

For ease of reference we have included hyperlink’s below to all of the draft rates/policies

Development Charges (DC)
DC Background Study –
DC By-law –
Fact Sheet –

Community Benefits Charge (CBC)
CBC Strategy –
CBC By-law –
CBC Fact Sheet –

Alternative Parkland Dedication Rate
Parkland Strategy 2022 Refresh –
Alternative Parkland Dedication Rate Official Plan Amendment –….pdf
Alternative Parkland Dedication Rate By-law –
Alternative Parkland Dedication Rate By-law – Alternative Parkland Dedication Rate Fact Sheet –

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