~13- 57. The Municipal Act should be amended to allow municipalities to establish reserve funds for housing purposes. COMMENTS ON RECOMMENDATIONS #53 TO #57: All these recommendations would result, unless supported by senior government financing, in subsidies to affordable housing by local governments. Housing is not a local government responsibility, but a senior government responsibility. CONCLUSION: While the COHO report makes a number of valid observations and provides many ideas for further consideration, there are areas that we feel require further investigation. Many of the recommendations in the COHO report require Fiscal commitments by various levels of government. It can be argued that housing is a federal as much as it would be a provincial responsibility. It is difficult to accept, however, that housing should also become a local (Municipal ) government cost responsibility. There must be commitment at all levels of government to resolve the province's housing problems and not simply further down—loading of responsibilities to the local level. The concept of secondary suites "ag a right" of all homeowners is also of particular concern. There needs to be further investigation into the impact of suites on the housing market in order to ensure that they do not further exacerbate the gap between homeowners and renters. Many of the housing problems in the GVRD and Capital Region District result from residents from every corner of the province converging to these two metropolitan areas. The resulting social problems are the responsibility of all residents in the province or in Canada. It is not justifiable or fair to ask residents of these two regions to subsidize, with their taxes, affordable housing at a rate higher than the residents of smaller communities in, for example, northern B.C. Some of the issues raised by the COHO report reinforce the need for appropriate Regional Planning to address issues of physical growth, economic growth and land supply. Before any further legislation or changes to the Municipal Act, that would have profound impacts on local governments, are introduced, there needs to be clearer definition of the roles of and financial commitments by senior levels of government. 7 / . Ch., M.C.I.P. ner, Director of Planning CF/klr 1D626-4/16