Opposition to Ontario Bill 39, Better Municipal Governance Act, 2022, giving the Toronto’s John Tory “strong mayor” powers continues to grow. FoNTRA wrote a letter to Mayor John Tory on November 23, 2022 expressing strong objections to what is widely seen as an anti-democratic move by the provincial government. It was followed by another letter on November 28, urging the mayor to call an emergency session of council to discuss the matter; he refused, despite calls from many of his own councillors to do so. On December 6, fifteen of the 25 city councillors sent a joint letter to Premier Doug Ford and Municipal Affairs Minister Steve Clark, urging a halt to the legislation.
The Federation of North Toronto Residents Associations, representing over 30 residents associations in Toronto, submits the following objections on proposed changes to the Greenbelt Plan that would remove or re-designate 15 parcels of land, and add lands in the Paris Galt Moraine area.
Our submission is based on the following points.
1. There is no proven need for this additional land for development.
The government’s Ontario Housing Affordability Task Force stated that: “a shortage of land isn’t the cause of the problem. Land is available, both inside the existing built-up areas and on undeveloped land outside greenbelts.”
On November 10th, 2022 the FoNTRA Board sent a Letter of Objection to the Standing Committee on Committee on Heritage, Infrastructure and Cultural Policy with copies to our local MPPs and councillors.
Bill 23 is omnibus legislation that seeks to make significant changes to municipal planning legislation throughout the province. Many residents, community and environmental organizations have begun to raise their concerns in a variety of public forum.
Fewer meetings held more quickly
While residents are struggling to understand the complexity of Bill 23, the province is moving quickly to fix wheels to their wagon.
All of this haste flies in the face of the best practices of consultation that provide a prescription of fairness required of all public bodies. See the details of these best practices (aka The Gunning Principles) below.
The consultation schedule for Bill 23 was released on October 31st.
More homes built faster, 2022 Act
The Standing Committee on Heritage, Infrastructure and Cultural Policy will meet to consider Bill 23, An Act to amend various statutes, to revoke various regulations and to enact the Supporting Growth and Housing in York and Durham Regions Act, 2022.
Ford and his housing minister previewed the legislation in a Toronto Region Board of Trade event earlier on Tuesday. Ford said in his speech …
“Everyone’s dream is to have a little white picket fence. You know, when they put the key in the door, they know they’re building equity into it, they can do the little tweaks to their house and increase the value of it. That’s our goal.”
It is not yet clear how the proposed legislation will achieve this goal.
The legislation introduces a new concept definition called ‘attainable housing’ that seems to look very much like the old ‘market-based housing.’ This is precisely the outcome that the building industry is hoping for. Toronto has more than 230 cranes in-the-air providing mostly market-based housing … so we can expect more cranes on the horizon.
The Federal Electoral Boundaries Commission for Ontario has proposed a new electoral map for consideration at public hearings this fall. This map introduces changes to Ontario’s federal electoral district boundaries and has been developed through an independent and non-partisan process.
The electoral boundaries for many Toronto ridings will change significantly, in some cases splitting neighbourhoods into two or more different electoral districts. This will potentially affect ALL levels of government, as the provincial boundaries and the municipal ward boundaries are currently the same as the federal ones since the number of Toronto wards was reduced to 25 in 2018.
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.
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.
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.
The Federation of North Toronto Residents Association (FoNTRA) strongly supports the motion, tabled by Councillor Kristyn Wong-Tam at the PHC meeting of June 28, 2021 to request a review of all aspects of the vision presented in “Imagining a New Town Centre for Midtown Toronto” prepared by the Midtown Working Group.
The unique opportunities for the Canada Square site were recognized by designation as a Special Study area in the Midtown in Focus Plan, developed with community consultation to provide comprehensive planning direction for the Yonge and Eglinton area. Unfortunately, the City’s lease agreement with Oxford Properties Group was made before that study could be undertaken. The Midtown Town Centre vision begins to provide the way forward.
This is to provide our comments on Expanding Housing Options in Neighbourhoods – Garden Suites – Proposals Report and its recommendations.
We note that the report is intended for public consultation not for decision on the proposals. While the types of proposals are generally OK, the details may need adjusting depending on the feedback, and also on the results of the laneway housing review. We are pleased that the report recognizes that neighbourhood character should be protected, and that consultation with the affected neighbourhoods is essential. While the learnings from the laneway housing experience will be useful, we continue to note the significant differences, particularly related to access, between laneway and garden suites.
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.