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Howland Ave. Toronto - multiplex

EHON Multiplex Study: Draft Official Plan Amendment

The EHON initiatives represent a significant rethinking of the built form and density of Toronto’s neighbourhoods. Neighbourhoods have been central to Toronto’s identity (“The City of Neighbourhoods”) and it is critical that significant changes to planning policies for Neighbourhoods be carefully planned and implemented.

In response to City Planning’s request for comments, we have provided detailed analysis of the draft OPA, including several recommendations (see Attachment 1). In addition, a number of questions have arisen that require clarification and further discussion. We acknowledge that our analysis and comments have benefitted from the advice of Terry Mills (ARRIS Strategy) (see Attachment 2): In addition, we have made several suggestions below, both substantive, and process-wise, as to how to proceed.

Heartwood condos - Queen St. Wood construction mid-rise

Mid-Rise Buildings – Rear Transition issues

We are providing our comments on the draft proposal that has been the subject of recent public consultations. We are concerned about the proposals that appear to be one-sided and do not reflect an evidence based and careful assessment of the Mid-Rise Guidelines developed by Brooke-McIlroy Planning, dated May 2010.

  1. Important stakeholders were not represented in the consultation process to develop the revised Mid-Rise Guidelines.
    • The process appeared to rely on input/guidance from the development industry to generate a final report and recommendations including draft revised performance standards.
    • There was no similar opportunity for input from residents including those living in the immediately abutting lands and other affected areas
    • The public is now being asked to comment on what appears to be a “done deal”.

FoNTRA asks City Planning to ensure that Studies, Plans and Guidelines directed to City building are properly prioritized

FoNTRA’s examination of the Study Work Program updates reveals some concerning trends. The waiting list for studies and plans is long, and getting longer. This trend appears to be especially true for heritage-related studies, including HCD studies/plans, CHRAs, and City-Wide and Area Guidelines. We have compiled the Study Work Program data for these categories by status (Completed, Forecast, Active and Hold) using the updated reports – see attached.

Ontario Legislature

FoNTRA open letter opposing Bill 23

We believe that the foundation of Bill 23 is flawed and if approved it will result in significant adverse impacts on our communities without any guarantees that the needed housing will be built.

The legislation focuses solely on supply (i.e., construction of new houses), not demand. For example,  the federal and provincial governments could reduce the demand for housing in the overheated GTA by influencing the location of jobs.  And conspicuously, the Bill avoids dealing with affordability, again focusing only on production of new housing. The report assumes that affordability is simply a function of supply, i.e. the idea that more supply will bring down the prices, which is unproven.  The experience is that public sector financial and regulatory intervention (ie. subsidy, inclusive zoning) is required in order to achieve affordable housing.

Growth Funding Tools – FoNTRA responses to City reports

FoNTRA responded to the three reports and recommendations from the City staff re: Growth Funding Tools. The recommendations were passed by the Executive Committee with amendments on July 12, and by City Council on July 19. Please refer to our Growth Funding Tools page for background information and links to the agenda items, by-law, reports …

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FoNTRA supports the principle of multiplexes but recommends necessary changes to the zoning by-law to manage the implementation

We are writing on behalf of the Federation of North Toronto Residents Associations to support the staff recommendation for further study of multiplexes. The neighbourhoods of our members include both those with multiplexes, and those where multiplexes are not permitted. While we support the principle of permitting multiplexes in all R-zoned neighbourhoods, eliminating the multiplicity of R zones limiting building types, we believe it makes no sense to pass an OPA without the necessary changes to the zoning by-law, allowing detail as to how multiplex permissions will be implemented.

General Members Meeting – April 19, 2022

  1. Welcome and agenda approval
  2. Land Acknowledgement
  3. FoNTRA organization matters
    • April 13 meeting with Chief Planner
    • Ontario Not for Profit Corporations (ONCA )Act changes
    • Provincial Election
  4. Planning Policy Issues
    • Official Plan (“Our Plan”)
    • MTSAs
    • EHON
    • Growth Funding Tools

General Members Meeting – March 15, 2022

  1. Welcome and agenda approval
  2. Land Acknowledgement
  3. FoNTRA organization matters
    • AGM April 19, 6 p.m.
    • March 16 meeting with Chief Planner
    • Ontario Not for Profit Corporations (ONCA )Act changes
    • Provincial Election
  4. City-wide Policies
    • Official Plan (“Our Plan”)
    • MTSAs
    • EHON/Garden Suites Appeal
    • EHON/Multiplexes

Review of Provincial Housing Affordability Task Force

We support the proposed City of Toronto response to the Ontario Housing Affordability Task Force.  We agree that there is a critical housing problem in Toronto. The affordability problem is worldwide, especially in rapidly growing cities. Too many low-income households cannot afford the rents they pay. And too many new middle-income families are priced out of the market for owner-occupied housing.

Unfortunately, the recommendations of the Ontario Housing Affordability Task Force will do little to reduce the cost of housing, especially for low-income families. It is all very well to say that housing prices will decline if more housing is built, but the economics of housing are not responsive to rhetoric.

FoNTRA comments on Ontario Housing Affordability Task Force Report

Land use planning is intended to serve the public interest in achieving complete communities and requires balancing of competing interests, aiming to serve the best interests for both present and future residents. Housing is for most homeowners not just their home but also their biggest asset, and governments have a responsibility in City land use planning and development to protect the interests of existing residents as well as to provide for the need for more housing.

Finding the right balance is not easy. And the role of municipal government is important, as each municipality has different needs and priorities. The Task Force’s recommended one size fits all throughout the province” proposals simply do not work. The issues in small towns such as Creemore or Owen Sound are not the same as the issues in midtown Toronto.

General Members Meeting – February 15, 2022

  1. Welcome and agenda approval
  2. FoNTRA organization matters
    • 2021 membership update
    • Dec. 10 Meeting with Gregg Lintern
    • Resident Assn/City Planning Spring Forum
    • Membership issues
    • New website update
  3. Planning Policy Issues 
    • Official Plan (Our Plan)
      Emerging issues re complete communities, infill in tower communities, house price unaffordability
      FoNTRA Official Plan working group
    • MTSAs/Protected MTSAs
    • Conversions of Employment Lands
      PHC Jan 12 / City Council Feb 2
    • Mandatory Application Pre-consultation
      PHC Jan 12 / City Council Feb 2
    • Reduced Parking requirements for development
      PHC Nov 25 / City Council approved Dec 14
    • Growth Funding Tools
      Public consultation completed
Palmerston multiplex

Expanding Housing Options in Neighbourhoods – Update Report

FoNTRA supports the Expanding Housing Options in Neighbourhoods (EHON) program in principle. However, neighbourhoods across the City have different characteristics that must be taken into consideration in expanding building types across the City. This cannot be a “one size fits all” initiative.

We believe that an extensive public consultation at a Neighbourhood level is critical.  City wide engagement is essential. There should be a review of the processes used for laneway and garden suites, and lessons learned applied. Specific local area participation must also be included and has not been so far except by some local residents associations. Ward based consultations are too broad.

Stop Out-of-Control Housing Prices

This is to express our strong support for the Motion and Recommendation from Executive Committee to request that the Government of Ontario help to stop out-of-control housing prices by imposing a home speculation and home flipping tax. 

The latter view has been eloquently expressed by Professor Patrick Conlon[1] noting that cities such as Vancouver have “already tried harder than anywhere else in North America to add housing supply in the hopes of lowering home prices and sadly it has not worked…..what’s happening in B.C. is happening elsewhere — whether they are adding housing slowly or quickly. It makes no difference if these cities are constraining supply like San Francisco, California, or letting it rip like Austin, Texas. Everywhere, housing prices are separating from the ability of average wage earners to afford homes.

Expanding Housing Options in Neighbourhoods

FoNTRA supports the careful intensification of neighbourhoods and has been involved in the development of the new policies and regulations for Garden Suites to help ensure that the character of neighbourhoods is protected, and that the impacts on neighbours are acceptable.

We have continued to raise concerns most recently at Planning and Housing Committee including the following1:

  • The proposed Garden Suites Amendments should not apply at this time to lots where multiplex building types are permitted. And appropriate regulations should be developed for garden suites on lots with multiplexes in the multiplex study now underway;
  • Separation distance of the primary building from the ancillary dwelling and where measurements are taken;
  • The need for additional regulations for the conversion of existing ancillary buildings to protect light, view, and privacy of buildings on the lot and neighbours;
  • Communications, monitoring of implementation, and needed supporting processes and information systems.

2022 Capital and Operating Budgets

  1. The importance of Good Planning in the Race to be Better

    We recognize that this year the City continues to face fiscal challenges on a scale that is unprecedented.  We believe that the City should be bold, not shy away from making investments and raising revenue. It is apparent that the way the City, the province, the country, and the world, work have been changed indelibly and permanently as a consequence of the pandemic.  If people can work from anywhere, they will still work from somewhere. Will that somewhere be Toronto?  Or Whitby, or Scottsdale, or Barbados?? The call has been “to build back better”.  This is right. The legacy of the pandemic will be the “race to be better”.  What has Toronto going for it? Its brand?  “Diversity Our Strength”, “You Belong Here”?  Toronto not only has to remain a good place to live for all its (diverse) people, but become a better place. 

Garden Suites

Garden Suites – Final Report

FoNTRA supports the careful intensification of neighbourhoods and has been involved in the development of the new policies and regulations for Garden Suites to help ensure that the character of neighbourhoods is protected, and that the impacts on neighbours are acceptable. We have been pleased to see the wide consultations undertaken. Our Garden Suites Working Group has been actively involved in consultations with staff regarding a wide range of considerations required to carefully insert garden suites in the backyards of homes across the City.

Garden suites are proposed to be permitted in all areas zoned for low density housing. This means that they will be legally “permitted” on lots that cannot accommodate them due to lot width and or depth, and result in buildings that are too small to comply with the Ontario Building Code (OBC), or cannot meet the safe access requirement of the OBC. The alternative approach would be to do detailed neighbourhood studies across the City to make the permissions for each property clear, which would be a lengthy process.

Palmerston multiplex

Multiplexes

The Multiplex study is part of the Expanding Housing Options in Neighbourhoods (EHON) initiative. This study is to support the construction of a range of low-rise housing across the City’s low-rise neighbourhoods. The scope of the study includes multiplexes – buildings with two, three and four units – and low-rise apartment buildings. Member Motion MM9.36 …

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Garden Suites Community Consultation

FoNTRA wishes to submit extensive comments regarding the November 2021 Online Community Consultation for Garden Suites. We request that the draft Permissions, Official Plan Amendment (OPA) and Zoning By-law Amendment (ZBA) be revised accordingly. We thank you for agreeing to an extension until Dec 7, 2021 for our comments.

Garden Suites is a housing initiative affecting the Neighbourhoods designated lands within the FoNTRA boundaries as well as all neighbourhoods city-wide. FoNTRA established a Garden Suites Working Group (GSWG) which has been deeply involved in the review.

FoNTRA recognizes that Garden Suites represent a feasible option for additional housing in neighbourhoods, but we believe that they need to be designed responsibly, in a manner which preserves the green space system that exists in the neighbourhoods, and such that they do not negatively impact on the adjacent neighbours, and the neighbourhood character.