Planning Department

KPMG report - review of Committee of Adjustment

KPMG review of the Committee of Adjustment – some concerns require additional action

The KPMG report states that “concerns have been raised by a number of stakeholders that the process is too complex and inaccessible for many users. Some users have expressed lack of confidence and satisfaction in the process and do not believe the current practice consistently delivers quality decisions. Further, there have also been concerns raised about the public’s ability to effectively participate in the public hearings, both in the traditional in-person model and in the virtual hearing model introduced in 2020.”

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Draper St. heritage houses

City Planning needs 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.

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development pipeline report

Residential planning applications in the pipeline will build 43 percent more than the total need by 2051

FoNTRA found the Development Pipeline report to be a useful and important document. The data it presents provide ample evidence on the astounding imbalance between planning approvals and construction of new housing. But the data are also incomplete, because it says nothing about the provision of affordable housing for households with below-median income.

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City of Toronto Application Centre web page

FoNTRA proposes technology improvements in the AIC, Notification Service and new Reporting in response to Bill 109 Report

FoNTRA praises the efforts of the City Planning Division and other City staff to respond to the challenges posed by Bill 109 and its adverse effects on citizen participation in planning issues in Toronto. The proposed process changes have the potential to effect both an increase in review efficiency and an improvement in information availability. The challenge will be to implement these improvements within the very limited application review time permitted by the Provincial Bill.

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Residential street with mixed housing

2023 Housing Action Plan lacks a staff report and Multi-Tenant Housing report raises many new concerns

FoNTRA says that the 2023 Housing Action Plan proposal lacks a staff report justifying the recommendations, and the Multi-Tenant Housing report raised many concerns when previously considered, which require to be further addressed, such as how will the new regulatory framework be enforced?

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FoNTRA identifies the elements of Bill 23 that are regressive and identify flawed assumptions behind the legislation

FoNTRA states that Bill 23 does many regressive things, but one of the items of most concern is to prohibit any third party (i.e., citizen/resident or community association) appeals of development applications to the Ontario Land Tribunal (OLT). The Bill also proposes increased powers of the OLT to order costs against the party who loses at a hearing, which is intended to inflict substantial costs on parties to chill their participation. These measures are fundamentally undemocratic, vindictive, and represent an unacceptable diminution of citizens’ rights.

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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.

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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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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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Mandatory Pre-Application Consultation Amendments

Making pre-application consultation a mandatory, rather than a voluntary step in the development review process has been identified by internal and external stakeholders, and through jurisdictional review, as a first step in addressing inconsistencies that have implications for application quality, staff productivity, overall time to decision and city-building outcomes.

The report states that jurisdictional research indicates that improvements to the early stages of the development review process, including requiring pre-application consultation, results in the submission of higher-quality applications, increases the number of applications moving from pre-application consultation to actual submission, reduces the overall number of circulations, and helps to establish mutual accountability early on.

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Study Work Program Update

FoNTRA understands the importance of a vital and active planning function to the long-term health of the whole city, including thriving and complete communities. We recommend:

  • That City Council approve additional resources in the 2021 Toronto Budget for City Planning Division’s Study Work Program; and
  • that City Planning Division ensure that Studies, Plans and Guidelines directed to protection of neighbourhood character, i.e. HCD, CHRA, and Neighbourhood Guidelines are prioritized.  

City Planning Division’s activities basically consist of two streams: the Study Work Program, and Development Review. The Study Work Program, which includes such activities as Avenue Studies, Secondary Plans, Zoning By-law Updates, Heritage Conservation District (HCD) Studies, Community Heritage Resource Assessments (CHRA) and neighbourhood-specific Design Guidelines, is critical in order to advance the City’s strategic priorities, and also to strengthen the position of the City in dealing with development applications. It is also vital in dealing with a provincial government that does not respect the authority and jurisdiction of the City.

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City Planning Study Work Program Update

FoNTRA understands the importance of a vital and active planning function to the long-term health of the whole city, including thriving and complete communities. We recommend:

  • That City Council approve additional resources in the 2021 Toronto Budget for City Planning Division’s Study Work Program; and
  • that City Planning Division ensure that Studies, Plans and Guidelines directed to protection of neighbourhood character, i.e. HCD, CHRA, and Neighbourhood Guidelines are prioritized.

City Planning Division’s activities basically consist of two streams: the Study Work Program, and Development Review. The Study Work Program, which includes such activities as Avenue Studies, Secondary Plans, Zoning By-law Updates, Heritage Conservation District (HCD) Studies, Community Heritage Resource Assessments (CHRA) and neighbourhood-specific Design Guidelines, is critical in order to advance the City’s strategic priorities, and also to strengthen the position of the City in dealing with development applications. It is also vital in dealing with a provincial government that does not respect the authority and jurisdiction of the City.

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City Planning Division – Study Work Program

In order to assess part of the Study Work Program we have extracted and collated the Heritage Conservation studies (HCD studies and plans, CHRAs and other studies) by category i.e. 2020 Forecast, Hearings, Active beyond 2020 and On Hold (see attached). For
example two projects from North York, Lawrence Park West HCD and Leaside CHRA, which were authorized in 2014, are shown as “On Hold” (see attachment).

The development of secondary plans that take transportation and other required infrastructure needs into account along with the availability of parkland, schools, social service requirements, heritage studies, Zoning Reviews and neighbourhood-specific Design
Guidelines are critical. It is important to get ahead of the development applications with completed plans, as is being demonstrated in Midtown (OPA 405) and Downtown (OPA406). While the 2020 Staff Recommended Budget includes small staffing and capital funding increase for certain studies, the Division still lacks the resources to develop and update any
but the most critical Secondary plans. Planning for the City’s future – for the population and
jobs growth that is expected – necessarily suffers. And the lack of updated Secondary plans
with clear population targets/densities and development guidelines necessarily means that
too many planning decisions are left to be determined on an ad hoc basis by the Local Planning Appeal Tribunal.

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