Federation of North Toronto Residents' Associations
Neighbourhoods Working Together on Community Issues
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.
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?
FoNTRA like many across the City are extremely concerned about the legislated changes made by the Province to the City’s development approval system, which are being introduced without meaningful consultation with municipalities or the public. FoNTRA notes, with great concern, the significant reduction of public consultation in the revised application review process, which will deprive the public of important information for consideration and will be extremely detrimental to the outcome.
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.
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.
There have been many critical reviews of the province’s Housing Affordability Task Force report. Here is a representative sample of these critical reviews.
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.
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.
July 4, 2022 10th floor, West Tower, City Hall100 Queen Street West Toronto, ON M5H 2N2 Attention: Nancy Martins PH32: Expanding Housing Options in Neighbourhoods: Major Streets – Interim Report Dear Deputy Mayor Ana Bailão, Chair, and Members, Planning and Housing Committee FoNTRA represents over 30 residents’ associations in the area generally bounded by Sheppard …
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.
This is express our strong support for the Motion which requests City Staff to undertake a comprehensive study of the Toronto housing market from a municipal perspective to inform actions that City Council can take to support residents in finding an affordable home that suits their needs.
We applaud the scope – even perhaps the audacity – of the 11 proposed directions to staff. Thus far the City has devoted its efforts (not unlike that of other orders of government) on macro housing supply matters, and we especially support the proposed direction to report on:
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:
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.
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:
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.
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.
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.
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.