Federation of North Toronto Residents' Associations
Neighbourhoods Working Together on Community Issues
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?
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.”
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.
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.
There have been many critical reviews of the province’s Housing Affordability Task Force report. Here is a representative sample of these critical reviews.
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.
Recent proposed changes to housing policy have caused many city residents to reach out to their local provincial representative. A list of these representatives is available on the province of Ontario website.
The list provided above includes all the MPPs in the province and includes two addresses for each member. One address is the office in the legislative building and the other address is the constituency office.
Following a “leak”, Premier Doug Ford recently confirmed that the Mayors of the City of Toronto and the City of Ottawa would be given “strong mayor” powers by his newly re-elected government. This announcement, coming “out of the blue” (there was no mention of this as a promise during the Premier’s recent election campaign) is little more than an idea until the necessary legislation is introduced into the Legislature. Until then we don’t know the details of the “strong mayor” proposal.
The City proposed a new Regulatory Framework for Multi-Tenant Houses across Toronto in 2021. The current status report indicates that the regulatory framework will not be completed prior to 2023, given the number and complexity of the directions required by City Council in October, 2021; however some initial planning work has been completed.
We have reviewed the June 16, 2022 Status Report in the context of the earlier reports (June 2021, and October, 2021) and FoNTRA submissions. FoNTRA expressed qualified support both times. Referring back to FoNTRA’s concerns detailed in our June 25, 2021 letter and supported by our document “Questions regarding implementation of Multi-Tenant Housing Report”, our updated comments on some areas previously identified.
FoNTRA does not object in principle to the proposed OPA; however, we are skeptical about its feasibility and practicality. In a retail universe that satisfies consumers’ desires for both shopping convenience (via on-line and next day (or less) delivery), and bulk shopping at megastores like COSTCO, it is questionable whether there is any longer a desire and consequently an adequate market for new local neighbourhoods services, or whether this is a planners’ dream throwback to a simpler time.
This is to express our qualified support for the Motion:
We set our qualifications below.
The Ontario Land Tribunal is an unelected, unaccountable quasi-judicial body that has the “final say” over planning matters in Toronto and across Ontario.
The current Provincial government has (1) amalgamated the former five separate tribunals into one – the Ontario Land Tribunal (OLT) and (2) given it “final say” powers, reversing the advisory (to municipalities) powers given to the Local Planning Appeal Tribunal (LPAT) by the previous government. And procedural changes have reduced the involvement of participants in the hearings.
As a result it appears that the OLT is more politicized, more distant from the concerns of regular people, and less knowledgeable of land use planning than ever.
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.
This report sets out recommendations that would:
This correspondence is provided to indicate our strong support for Councillor Wong-Tam’s Motion that “City Council request the Government of Ontario to repeal Limitation 2 to Ontario Regulation 130/20 of the City of Toronto Act, returning the power to regulate construction noise to the City of Toronto” Limitation 2 to Ontario Regulation 130/20, enacted April 7, 2020, does not allow the City to regulate or prohibit noise in connection with construction. The Regulation overrides the City of Toronto’s municipal noise by-law through to October 7, 2021, to the detriment of residents.
FoNTRA wrote to the Premier on April 19 2020 to request that this measure (as well as making residential construction an essential service, opening a significant risk of COVID-19 infection to workers) be reversed. Excessive noise is a health hazard that impacts the physical and mental health, and quality of life of residents.
In April 2020, the City of Toronto’s bylaws limiting construction noise were suspended by Ontario provincial regulations 130/20 and 131/20 that permitted extended construction hours for a period of 18 months (till October 2021).
We recognize and understand the need for the Covid-19 related restrictions that were imposed on the various business sectors and social interactions over the last twelve months. All of Ontario is encouraged by the progress against Covid-19 through the aggressive and successful execution of the vaccination programs. As we look forward to the opportunity to return to some semblance of normal life, we believe now is the appropriate time to revisit the noise guidelines that extended construction hours on essential projects during the pandemic.
The recently enacted legislative changes to the Planning Act enhance the Minister’s authority for zoning orders across the province. This enhanced authority does not apply to lands within the Greenbelt Area. The enhanced authority allows the Minister to:
The changes are not helpful. Our issues with the expanded use of MZOs are:
We find that the government’s consultations on legislation it has already passed are a cynical attempt to green-wash legislation that was subject to totally inadequate consultation in the course of the legislative process before it was passed.
Our members agree that loud vehicular emissions continue to be a major problem on many arterials and freeways around the City, as well as locations like plaza parking lots. We understand that enforcement is difficult. The use of occasional Police check points to catch offenders cannot be effective. The City of Toronto should be taking a proactive approach to reducing excessive noise, which is not just annoying, it is a health issue. Emerging technologies and equipment can offer more effective ways to enforce the noise by-laws.