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Implementing the One-Stream Preliminary Review Program for Building Permit Applicants

FoNTRA supports the recommendations of this report to improve the Preliminary Review Program, and specifically Recommendation 4 that:

  • City Council request the Chief Planner and Executive Director, City Planning, in consultation with the Chief Building Official and Executive Director, Toronto Building, to review application requirements for the Committee of Adjustment to consider requiring a preliminary zoning review to verify the minor variances and remove the option of a zoning waiver.

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Mandatory Pre-Application Consultation Amendments

Pre-application consultation is encouraged and supported as a component of the Province’s land use planning system, and its use is clearly necessary given the reduced statutory review timelines introduced by Bill 108, the More Homes, More Choices Act, 2019.

FoNTRA strongly supports mandatory pre-application consultation as this will help make the application approval process more efficient for all involved.  At present, the “complete application” requirements mean that applicants must compile enormous amounts of detailed information, and then the process must be repeated when the application is better focused on City objectives. This wastes time for all involved except the consultants who get more work as a result.

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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.

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Updating legislation for Mount Pleasant Group of Cemeteries

We are writing to express our strong support for the proposed legislation (Bill 74, Mount Pleasant Public Cemeteries Act, 2021), introduced by Jessica Bell, MPP, that will update and modernize the Mount Pleasant Group of Cemeteries Charter, which dates from 1871.The legislation is in desperate need of modernization to bring it up to today’s standards of accountability and transparency. This new bill will repatriate the Mount Pleasant Group of Cemeteries back to the people of Ontario, safeguarding what the public originally created.

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Home Speculation and Home Flipping Tax Proposal

This is to express our strong support in principle for Councillor Colle’s motion. House prices in Toronto are escalating rapidly month after month, year after year, making housing unaffordable for most Torontonians. These out of control housing prices are fueled by real estate speculators and house flippers (“investors”) who are buying multiple properties other than their primary residence. The Ontario Government is uniquely able to stop out-of-control housing prices by re-imposing a Land Speculation Tax to stop speculators from unfairly driving up the cost of housing in Toronto to unprecedented levels.

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Actions to Reaffirm Toronto’s Tree Canopy Target

This is to express our strong support for IEC’s recommendation that City Council reaffirm Toronto’s target of 40 percent tree canopy cover by 2050 to align with the City of Toronto’s TransformTO Net Zero Strategy. However we strongly feel that mere reaffirmation of the 40 percent tree canopy target is inadequate and ineffective. We have to:

(1) actually protect the private trees that are of protected size;
(2) strengthen the Tree Protection By-laws,
(3) increase enforcement of the existing (and hopefully enhanced) Tree Protection Bylaws
(4) Increase replacement planting when trees are to be removed.
and
(5) maintain and enhance the existing protection for soft landscaping in the Zoning Bylaws

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Critical Steps for Net Zero by 2040

This is to express our strong support for this report and its recommendations. We do however question whether the City has a mechanism in place to ensure that its policies are in sync with respect to the City’s approved Climate goals.  We believe this continues to be an issue. For example elsewhere on City Council’s agenda:

PH29.2 Changing Lanes: The City of Toronto’s Review of Laneway Suites – Monitoring Program and Zoning By-law Amendments – Final Report
The proposed reduction of the soft landscaping requirement in the Laneway Suites by-law is contrary to the Climate imperative to maintain or enhance protection for soft landscaping in the Zoning Bylaws.

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TLAB Virtual Business Meeting, December 10, 2021

We offer the following comments and suggestions regarding the above noted items:

34.2 Public Guide Revisions 

We view the Public Guide as an important contribution to public education especially as it relates to self-represented parties and/or parties appearing for the first time at TLAB.

The Public Guide Revisions include both revised material and several new sections including Adjournment Requests, Motions, Affidavits and Recovering Hearing Costs.

We would like to provide feedback on several of the new areas covered in the Public Guide Revisions.

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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.

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Review of Mediation and Settlement on Planning Process 

This is to express our strong support for Councillor Gord Perks’ request for a review and report back on the negotiation process for development applications which have been appealed to the Ontario Land Tribunal (OLT). Residents Associations are frequently involved in these OLT appeals and have found the process to be inconsistent and not transparent.

We request that the review involve consultation with residents and resident associations, especially those who are “frequent travellers” at the OLT and are familiar with these issues.

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Recommended Parking Requirements for New Development 

This is to provide our comments on the above noted report. While we are in general support of the report’s direction, supporting flexibility in the application of parking standards, we do not support the complete elimination of minimum parking standards.

This review of the parking standards in the city-wide Zoning By-law 569-2013 was guided by the principle that parking standards should allow only the maximum amount of automobile parking reasonably required for a given use, and minimums should be avoided except where necessary to ensure equitable access. The review proposes that new developments would still have to provide adequate parking onsite, and not assume residents will be able to park on street.

As the report shows, car ownership rates of apartment dwellers vary greatly depending on household income. More important, they vary greatly depending on location. No minimums may work downtown, but when you travel away from the downtown core, where distances to destinations are longer, we would expect a real shortage of buildings/units with parking spaces, which will have a social impact as well.

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Ready, Set, Midtown: Zoning Review Status Report

FoNTRA is in general support of the recommendations for the Midtown Zoning Review and specifically, that:

  • the Chief Planner consider feedback obtained to-date from the public and key stakeholders in a preparation of the draft Zoning By-law and to undertake further consultation.
  • the City Planning Division to report back in the second quarter of 2022 with a recommended Zoning By-law.

We support the statement that “the Secondary Plan provides a framework for establishing a complete community in Midtown that supports overall quality of life for people of all ages, abilities, and incomes. This will be achieved through improved access to a range of mobility options, community service facilities, local stores, services and employment, housing including affordable housing, an attractive and vibrant public realm and publicly accessible parks, open spaces and recreational facilities.”

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Committee of Adjustment Status Update

This is to express our interest in the information provided in the above noted report, and to remind staff of the reasons why the review was initiated.

This report provides an update to Planning and Housing Committee, and City Council direction, further to a City Planning report titled Update on Committee of Adjustment Virtual Public Hearings, dated April 6, 2021. An independent consultant is being retained to review the End-to-End Review of the Development Review Process Final Report, dated August 15, 2019, as it applies to the Committee of Adjustment, as well as additional matters associated with virtual Committee of Adjustment public hearings.

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Neighbourhood Change and Intensification Bulletin

This is to express our interest and support for the information provided in the above noted report. Our one comment is that the number of case studies is quite small and is likely insufficient to be sufficiently representative of the communities in the massive land area designated in the Official Plan as Neighbourhoods. We would encourage City Planning to undertake more case studies to reflect the diversity of Neighbourhoods which would support the planning analysis required for the “Multiplexes” initiative.

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Palmerston multiplex

Expanding Housing Options in Neighbourhoods

The overall EHON strategy is to permit increased density in the Neighbourhoods.  We support this strategy in principle based on the idea of encouraging development across the city rather than allowing over-development in certain parts of the city, such as the Yonge-Eglinton Centre.  However, it is critical that the strategy be create complete communities, not just residential growth. This initiative should not be about adding multiplexes but doing it in the context of building complete communities based on good transit access as well as community services, employment, cultural opportunities and shopping, etc. The study areas chosen should take these principles as a comprehensive framework. The best opportunities for this type of intensification are in the low density suburbs.

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The City of Toronto’s Review of Laneway Suites

FoNTRA members have participated in City Planning’s consultations to date and have submitted comments on earlier versions.

We remain concerned about two proposed changes that relax the current regulations: the increased permitted height; and the blanket exemption for walkways. The stated reason driving these changes is the frequency of variance requests at Committees of Adjustment. In our opinion such changes should not be based on Committee of Adjustment decisions without evaluating their reasons, if any, and without evaluating the impacts on abutting neighbours.

Proposed Increase in permitted height from 6m to 6.3m

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TLAB Panel Training and Education Session

This is to provide our comments and suggestions with respect to the above noted agenda item, which will be held In Camera, as permitted by the TLAB’s Procedural By-law 1-2017.

FoNTRA commends the TLAB in its efforts to promote and enhance public understanding and education regarding its mandate and role in the City’s Land Use Planning system. These efforts include Public Business Meetings, annual reporting to the Planning and Housing Committee, and publication of the Public Guide, and website. We recall for example a Public Business Meeting held in Scarborough on February 10, 2017 which was well attended by stakeholders, including RAs. The Meeting included presentation materials by Klaus Lehman, Zoning Section, City Planning, which were made publicly available, and which continue to be referred to by RAs.

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Enhancing post-permit compliance

RE: MM37.21 Measures to Enhance Compliance After the Permit Process – by Councillor Ana Bailão, seconded by Councillor Frances Nunziata (Ward All)

Dear Mayor John Tory and Members of City Council,

We are writing in strong support of the above noted Member’s Motion to review options for strengthening the City’s enforcement of illegal construction after occupancy, or where a change of use of the property has occurred.

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Laneway suites

Proposed Laneway Suites Zoning By-law Amendments

This is to provide our comments on the draft Laneway Suites By-law Amendments as indicated in the Notice of Public Meeting published in the Toronto Star on November 3, 2021. 

FoNTRA reps recently met with Graig Uens and Caroline Samuels on October 22, and we also participated in the Community Engagement meeting held on October 27. At the latter meeting Graig advised that any further comments should be submitted as soon as possible as this Item is scheduled to be heard at the Planning and Housing Committee meeting on November 25, 2021. We therefore were very surprised to see upon examination of the Notice of Public Meeting published in the Toronto Star indicates that some of the draft Bylaw Amendments are new or different compared with what was presented to FoNTRA and to the Community Consultation meeting. These matters are complex and these changes should have been presented at the consultations to ensure the public has a clear understanding of the implications and an opportunity to ask questions, rather than just seeing them in the draft bylaw.

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Inclusionary Zoning OP Amendment

This is to express the strong support of the Federation of North Toronto Residents Associations (FoNTRA) for the proposed Inclusionary Zoning (IZ) policy.

The proposed policy lays the foundation for IZ in Toronto. It supports individuals and families in our city who earn too much to be eligible for social housing, but not enough to afford market rents and prices.  City Planning claims that the proposed framework balances the need to create more inclusive and equitable communities, provides certainty about expectations for affordable housing, and ensures the City continues to support overall housing supply. City Planning commits to monitor implementation of the new policy, and review and report back within three years.

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