Over the years on this blog, we have spoken about at least two ways to think about development pro formas. In the purest academic sense, you could say that pro formas are a way to determine the value of development land. You start with your forecasted revenues, deduct all of your expected costs, and then at the end you're left with some amount of money that can be spent on land. Said differently, land becomes the "residual claimant" in your financial model.

This is an important exercise, but in practice, pro formas sometimes (oftentimes?) need to be worked in the opposite direction. Meaning, the land price is what it is, development charges just increased, and now you're trying to figure out a way to make the math work. In this direction, you could say that you're undergoing a "cost-plus exercise." The costs are the costs and now you're trying to figure out some justifiable revenue figure that will make everything work.

If you do this latter exercise for a new rental apartment in Toronto today, you will end up with a rental rate that is likely hovering somewhere around $5 per square foot. This is a broad generalization and every site is of course different, but for the purposes of this post, let's assume it's $5. What that means is that a 500 square foot one-bedroom apartment will rent for $2,500 per month and a 1,000 square foot three-bedroom will rent for $5,000 per month.

A lot of people like to look at rental rates and say, "oh my, greedy developers are charging too much." But the reality is that this is what the cost-plus exercise is telling developers. There isn't the option of just charging less because there's only so much you can do about costs.

In fact, because development happens on the margin, some degree of optimism is often required to make new projects feasible. What I mean by this is that $5 psf may be what you need to make the project feasible, but there may be zero market comps in your submarket to actually support it. So in order to move forward, you just have to believe that in the future this will be the market rent.

This is harder to do in Toronto today because rents are not growing, they are declining. I personally believe that will quickly reverse once new housing completions fall off a cliff, but it doesn't change the fact that it's harder to underwrite rental growth in this kind of market environment. And because it's harder to underwrite rental growth, it's harder to make projects work.

The other consideration is that pushing rental rates higher is naturally going to slow down absorption. The Law of Demand tells us that as the price of something increases, the quantity demanded decreases. So you take on more risk in multiple ways when you push rates. As a developer, I'd rather be in a position where I could underwrite lower rents and feel more confident about leasing up the building quickly.

One way this could obviously be done is to lower costs. So as an exercise, I opened up one of our rental pro formas and removed just two cost items: development charges and parkland dedication. The result, in this particular instance, is that we could lower our average rent by almost $300 per month and still have a more or less equally feasible project. That's meaningful.

A cynic would say that developers will still charge the higher rent, but again, I would argue this isn't necessarily true, especially in this market. A cheaper cost structure means that more sites / projects become feasible and that developers should now face lower market risk. I'll take that. I'll take a full building with minimal vacancy and lower turnover.

Cover photo by taufiq triadi on Unsplash

I am of the strong opinion that, as a general rule, development charges should aim to capture the costs and impacts directly attributable to new development. This is why I prefer the term "impact fee" as opposed to "development charge." The latter makes it seem like a generic catch-all tax. But that's not the intent. The intent is that "growth pays for growth." At the highest level, this makes sense and sounds good. So with all the talk of lowering/eliminating DCs to help with housing affordability, I think a lot of people are rightly wondering: Is this actually feasible? What fees are actually needed to fund growth-related infrastructure? Let's talk about this today.

For reference, here are the development charge rates effective June 2024 in the City of Toronto.

Non-rental housing:

Rental housing:

In other words, if you were building 3-bedroom family-sized condominiums, the development charge would be $80,690 per home. And if you were building 3-bedroom family-sized rentals, the development charge would be $45,280 per home. But keep in mind that in addition to the above development charges, there are also other charges like the Community Benefit Contribution (Section 37), Parkland Dedication, Education Charges, Development Application Fees, HST, and so on.

Growing development charge reserve funds

Looking at just DCs, Ontario municipalities collected about $17.5 billion in development charge revenue over the last five years (according to the Missing Middle Initiative). But importantly, these same municipalities only spent $11.8 billion. The rest is sitting in DC reserve funds. Why is that? Well, part of this could be explained by timing. DCs are typically collected when a developer is issued their first building permit. But the costs associated with growth-related infrastructure may not happen at exactly the same time.

Except that these reserves have been growing. From 2010 to 2022, DC reserve funds across Ontario have increased from $2.6 billion to $10.7 billion (again, according to the Missing Middle Initiative). This is a 316% increase over 13 years. And in the case of Toronto — Ontario's largest city — reserves have grown 891% over the same period. This suggests that these charges aren't accurately tuned to actual impacts, because, in theory, these reserves should trend toward zero over long periods of time, as growth-related infrastructure costs are incurred.

Nexus between development charges and the impacts of new development

Let's get a little more specific. Over the last five years, DCs generated about $450 million for social services across Ontario. This includes things like long-term care, affordable housing, day cares, and public health; all of which are important and good things. But can all of these things be considered growth-related impacts? In other words, is it fair to say that because new housing got built, we now need more long-term care homes? I don't think so. Long-term care homes are certainly needed, but I don't think it's fair for new home buyers and renters to shoulder this cost.

Who is paying for the renaming of Dundas Square?

Let's consider another example. Back in 2014, Toronto City Council decided that Dundas Square should be renamed. I personally don't think this was at all necessary, but it got approved and the cost to do so was estimated at $335,000. At the time, it was also decided that this would be paid for through Section 37 funds as opposed to "taxpayer money." Section 37 of the Planning Act used to function in practice as "let's make a deal." It was a way for cities to extract money from developers in exchange for allowing more density. This has since been replaced by the Community Benefits Charge framework, but the intent is the same:

Section 37 of the Planning Act authorizes the City to adopt a community benefits charge (CBC) by-law and collect CBCs to pay for the capital costs of facilities, services and matters that are required to serve development and redevelopment. CBC funding will help support complete communities across Toronto.

In funding it in this way, the City of Toronto took a position. It basically said, "renaming Dundas Square is important to the city. We must do it. But we don't want all Torontonians to pay for it. We only want new home buyers and renters to pay for it." Because that's the effective outcome of using funds charged only to new developments. Is that fair? Once again, I don't think so. Because it's not reasonable to say that because new housing got built, it's now imperative that we rename Dundas Square. The two are unrelated matters.

By and large, this is the issue that many take with development charges. It doesn't appear to be "growth just paying for growth." It's growth paying for a lot of stuff. And it has a direct impact on housing affordability. In tomorrow's post, we'll expand on this last point and talk about what lowering/eliminating DCs could mean for apartment rents.

Back in 2022, Altus Group did a municipal benchmarking study where they looked at approval timelines, development charges, and a host of other factors that could be impacting housing affordability in Canadian cities. I blogged about it then and spoke specifically about its benchmarking of approval timelines. But I revisited it this morning after seeing Mike Moffatt tweet about it and I came across the below chart.

Also, approval timelines are less of a concern today. There are lots of zoned sites that are ready to go, but can't because of the market. Instead, what the below charge does is compare municipal charges on a per square foot basis for low-rise and high-rise housing. What's interesting is that in most cases, but in all cases in Ontario and BC, the charges are higher for high-rise housing.

Example: If you bought an 800 sf condominium in Toronto and the fees were based on the numbers in this report, you'd be paying $125 psf x 800 sf = $100,000 in municipal charges alone. Once again, I am of the opinion that our industry should find a way to transparently itemize these charges so that people/purchasers can see where their money is going.

Now, part of this has to do with higher land values for higher-density housing and municipal fees that are calculated based on appraised land value. But it's also driven by suite sizes becoming smaller (to make the end price more affordable for buyers and renters).

Here in Toronto, it doesn't matter if you're building an 800 sf two-bedroom or an 8,000 sf two-bedroom apartment, the development charge fee would be the same. And so it is perhaps not surprising that as suite sizes have come down and charges have gone up, so too did the costs on a per square foot basis.

But it raises an important and obvious question: Is this what we want? I mean, aren't we trying to encourage more infill housing in places where people don't need to drive and we can leverage existing services? Yes, that's what we are saying. Unfortunately, our charges suggest the opposite.

If you'd like to download a copy of the report, you can do that over here. Please keep in mind that this is data from 2022 and there have been changes since then. In many cases the fees are now higher, but in some cases, like in the City of Vaughan, the fees are now lower.

Cover photo by Scott Webb on Unsplash