TAMRMS#: B06
7.1
REQUEST FOR DECISION
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Off-Site Levy Front End Policy
Presented by: Abram Iskander, Off-Site Levy Specialist, Engineering Services
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RECOMMENDED MOTION(S)
recommendation
1. That Standing Committee of the Whole recommend to Council that Council Policy entitled “C-P&E-14 Off-Site Levy Front-Ending Policy” attached to the October 13, 2026 agenda report entitled Off-Site Levy Front End Policy be approved.
2. That Standing Committee of the Whole recommend to Council that Council Policy entitled “C-P&E-09 Off-Site Levy City Front-ending Prioritization Criteria” attached to the October 13, 2026 agenda report entitled Off-Site Levy Front End Policy be rescinded.
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SUMMARY
To facilitate land development, off-site levy infrastructure often needs to be constructed before the City collects associated off-site levies. In these circumstances, the City may choose to front-end infrastructure construction costs. To guide City investment decisions:
• The existing Off-Site Levy Front-End Prioritization Criteria policy (C-P&E-09) focuses on ranking projects to determine priorities, but it does not provide guidance on how and when projects would be funded.
• The proposed new policy focuses on determining when infrastructure investments are needed to support growth, who is best positioned to front-end those investments, and incorporates the City’s ability to afford the projects into decision making.
The proposed C-P&E-14 Off-Site Levy Front-Ending Policy is presented for the Standing Committee of the Whole’s consideration.
ALIGNMENT TO COUNCIL DIRECTION OR MANDATORY STATUTORY PROVISION
On September 16, 2025 Council approved the following agenda report:
AR-25-361
That the following proposed principles for the City’s Off-site Levy (OSL) Front-ending policy to guide consultation with the development community and policy development be endorsed:
1. The City prioritize front-ending OSL infrastructure in areas that align with the MDP.
2. Apply City front-ending limits for OSL infrastructure to reflect the debt servicing ability of the OSL Recovery Fund.
3. Provide a delineation between the types and/or scale of infrastructure the City will consider for front-ending and what the development community is expected to front-end.
On December 3, 2024 Council passed the following motion:
CM-24-018
That by Q2 2026 Administration draft or amend a Council Policy for Council’s approval related to the City’s position on front-ending the costs of development, outlining the circumstances under which the City will consider front-ending costs of development, and that Administration explore solutions to enable and encourage developers to front-end costs of development, including by researching what is done in other municipalities in Alberta, and present recommendations to Council by Q2 2026.
BACKGROUND AND DISCUSSION
Introduction
The existing Off-Site Levy City Front-ending Prioritization Criteria Policy (C-P&E-09) was established in 2015 to prioritize individual off-site levy projects for potential City front-ending using a scoring matrix that ranks individual projects.
Since 2015, the City’s approach to growth planning has evolved. Infrastructure investment decisions are influenced by debt capacity, grant opportunities, market demand, servicing requirements and developer readiness, which can change significantly over time. Ranking projects does not capture these dynamic influences and no longer provides an effective framework for planning growth infrastructure and financial planning.
On September 16, 2025 Council endorsed initial proposed principles to start consultation and policy development. Developers were consulted on the initial principles, and Administration incorporated feedback in developing a policy.
The new policy replaces the project scoring matrix through the development of a 10-year off-site levy project capital plan allowing for more strategic and coordinated investment decisions. An off-site levy project capital plan allows the City to:
• understand and forecast future funding requirements;
• improve long-term financial planning;
• coordinate complimentary levy projects serving the same growth areas to align construction timing and capture potential economies of scale; and
• plan for additional operational requirements to support development growth.
Adopting a 10-year Off-Site Levy Capital Plan will provide transparency and a degree of certainty to the City and developers on infrastructure timing and anticipated funding sources to support land development.
Proposed Policy Concepts:
The key concepts of the proposed policy are as follows:
1. Long Term Planning
• Establishes a 10-year Off-Site Levy Capital Plan as the primary tool for communicating infrastructure priorities, anticipated timing, and if a project is planned to be front-ended by the City or developers.
• Replaces individual project scoring over the next 25 years and focuses on near-term critical infrastructure required to develop existing area structure plans and upcoming areas of growth.
• Aligns front-ending decisions with the long-term growth objectives stated in the Municipal Development Plan and Council Strategic priorities.
• Reduces ad hoc financial analysis and improves long-term investment decisions through integration of the Off-Site Levy Capital Plan into the City’s budget process.
2. Decision Making
• Outlines the considerations and factors the City may use in deciding whether to front-end infrastructure projects. The City will typically focus on large-scale projects with complex design which may be difficult to phase.
• Incorporates City financial planning and debt servicing capacity into the decision-making framework from the Off-Site Levy Recovery Fund Utilization Policy (C-FS-20) and the Debt Management Policy (C-FS-03).
• Considers financial capacity, grants, debt servicing requirements, and market demand when evaluating City infrastructure investments.
3. Transparency
• Identifies the anticipated funding parties for each project in the 10-year Off-site Levy Capital Plan.
• Provides roles and considerations in determining whether the City or developers are best positioned to front-end infrastructure.
• Includes consultation with the development community through the Off-site Levy Working Group to aid in the strategic capital planning process and response to market conditions.
Policy Considerations
In consultation, developers highlighted the importance of maintaining opportunities for dialogue when evaluating front-ending opportunities, as infrastructure can vary in cost, complexity, timing, and number of benefitting parties. Administration determined that an overly prescriptive policy could limit the City’s ability to evaluate unique project circumstances. The proposed policy establishes guiding principles and considerations while allowing the City to evaluate projects based on individual circumstances (i.e., cost-sharing, grant opportunities, market conditions, etc.,).
The 10-year Off-Site Levy Capital Plan is intended to identify anticipated timing, and anticipated funding responsibilities for planning purposes. Inclusion of a project in the 10-year Off-Site Levy Capital Plan does not guarantee that the City will front-end a project. Final investment decisions remain subject to Council budget approval.
Developer Cost Recovery
The City has a cost recovery mechanism for front-ending parties outlined in the Off-site Levy Framework Policy (C-P&E-08) however, Administration has been exploring other alternative cost recovery mechanisms that could encourage developers to take on more front-ending. Administration has held discussions with several Alberta municipalities and developers about alternative mechanisms. Based on these discussions, a levy credit system may be a potential fit in the St. Albert context.
Current Levy Recovery Mechanism:
• Developers offset infrastructure costs against levies owing at the initial stage of development.
• Remaining infrastructure costs are recovered through annual payments from levy revenue collected by the City. Annual payments are difficult to predict as they rely on development across the City.
Levy Credit Potential Alternative:
• Infrastructure construction costs are assigned a levy credit.
• Credits can be applied against off-site levies owed at each subsequent stage of development.
• Credit balance is carried forward until the full amount is recovered.
Levy Credit Considerations:
• Credits provide a predictable cost recovery process since recovery aligns with an individual developer’s pace of development.
• Reduces administrative complexity for cost recoveries.
• The City still requires levy payments to meet annual debt servicing requirements. Administration is reviewing financial impacts of credits and ways to address cash flow requirements.
• A process is needed to address situations where a developer has a remaining credit balance and all their lands are developed.
Administration is completing financial analysis, legal review, and stakeholder consultation. Potential amendments to the Off-Site Levy Framework Policy (C-P&E-08) may be brought forward separately following completion of review and consultation.
STAKEHOLDER COMMUNICATIONS OR ENGAGEMENT
Administration presented to Council on September 16, 2025 initial proposed principles as a starting point to guide consultation with stakeholders and development of the front-end policy. These principles were presented to developers for comment and feedback which was used by Administration in drafting the policy.
Consultation was completed with the City’s Off-Site Levy Working Group, which is comprised of City Administration, developers who are part of the Building Industry & Land Development Association (BILD), as well as non-BILD developers. From October 2025 to August 2026, members were consulted through:
• Written questionnaires and feedback;
• One-on-one interviews;
• Group meetings through the off-site levy working group; and
• Circulation of the final policy for written and verbal feedback.
The developers consulted are generally supportive of the policy. They have an interest in continued discussions on re-evaluating the existing cost recovery mechanism to further support developer front-ending.
Administration held meetings with municipalities across Alberta to discuss front-ending policies and cost recovery mechanisms used to enable developer front-ending. Discussions with other municipalities are being used to evaluate how a levy credit mechanism would work in St. Albert’s context.
IMPACTS OF RECOMMENDATION(S)
Financial:
None at this time. The 10-year off-site levy capital plan will be integrated into the City’s budget process to improve transparency and long-term financial planning.
Compliance & Legal:
None at this time.
Program or Service:
None at this time. The process of developing a 10-year capital plan will follow the existing process of the off-site levy bylaw update.
Organizational:
None at this time.
Risks
Without a long-term plan, there is risk that future infrastructure funding requirements are not fully identified which results in challenges to financial planning, and operational readiness. The proposed policy mitigates financial planning risks by providing greater transparency to Council, Administration, developers and residents on anticipated infrastructure funding requirements to enable growth and development.
ALIGNMENT TO PRIORITIES IN COUNCIL’S STRATEGIC PLAN
Initiative aligned with Strategic Plan:
Long-Term Capital Funding Framework
ALIGNMENT TO LEVELS OF SERVICE DELIVERY
N/A
IMPACTS OF ALTERNATIVES CONSIDERED
If Standing Committee of the Whole does not wish to support the proposed motion, Administration presents the following alternatives for Council’s consideration.
ALTERNATIVE 1: That the Standing Committee of the Whole provides feedback to be incorporated before the proposed Off-Site Levy Front-Ending Policy is presented to Council for approval.
Financial:
None at this time.
Compliance & Legal:
None at this time.
Program or Service:
None at this time.
Organizational:
Administration will incorporate feedback into a revised Off-Site Levy Front-Ending Policy and bring it forward to Council for consideration and adoption.
Risks
None at this time.
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Report Date: October 13, 2026
Author(s): Abram Iskander
Department: Engineering Services
Department Director: Dawny George
Managing Director: Adryan Slaght
Chief Administrative Officer: William Fletcher