aerial view of planned community

FoNTRA opposes proposed changes to Ontario’s land use planning framework

FoNTRA is an umbrella organization representing over 30 residents’ associations in central Toronto engaged in public policy debates on planning and development issues that directly affect our members. Its interventions are guided by pursuing the following goals: 1) rational and stable statutory planning framework; 2) local and regional planning that engages all stakeholders, without ad hoc provincial overrides; 3) intelligent density distribution that fosters complete communities and efficient public transport networks; 4) balancing housing supply with real demand; and, 5) resilient and ecological development patterns with compact communities.

FoNTRA’s report concludes that the proposed Provincial Planning Statement (PPS) and the simultaneous repeal of the Growth Plan for the Golden Horseshoe should not proceed since these initiatives are not only harmful but also entirely unnecessary. FoNTRA, respectfully, urges the government to withdraw the proposed Provincial Planning Statement and to maintain the Growth Plan for the Greater Golden Horseshoe.

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low-rise residential condo under construction at 7 Dale Ave. Toronto

Zoning by-law simplification and modernization for low-rise residential zones

FoNTRA supports the objectives of the Housing Action Plan and looks forward to participating in the upcoming consultations related to implementation of the objectives of “simplification”, “harmonization” and “modernization”.

The report notes that “A key objective of the Plan is that new development be sensitive, gradual and “fit” the existing physical character to respect and reinforce the general physical patterns in Neighbourhoods.”

We agree that this must remain the overriding objective for the consultation process, which is to begin shortly. All neighbourhoods are not all alike and their differences are important in making our City a great place to live.

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New multiplex housing on High Park Avenue

Defer multiplex decisions until after mayoral election

FoNTRA supports intensification. It sees it as necessary for the city. On the other hand, it wants to be sure that, as the city intensifies, it does it well. It is crucial that Toronto remain green, and, given climate change, that it become greener. And it is important to build an attractive city. The new multiplexes should fit in well with their neighbourhoods. Some neighbourhoods already have duplexes, triplexes, and four-plexes, and often they harmonize with their surroundings. We can look to them for models for building well.

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FoNTRA observes that 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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FoNTRA says that the 2023 Housing Action Plan lacks a staff report and Multi-Tenant Housing report raised 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 raises concerns about the legislated changes made by the Province which are introduced without meaningful consultation with municipalities or the public.

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.

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Ontario Legislature

FoNTRA open letter opposing Bill 23

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.

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FoNTRA cites grave concerns with Bill 23

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.

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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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FoNTRA provides comments on Multi-Tenant Housing Report in areas of Enforcement, Budget and Evaluation

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.

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FoNTRA requests that City Planning engage in local consultation for the Expanding Housing Options Study

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 …

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Howland Ave. Toronto - multiplex

EHON Multiplex Study: Draft Official Plan Amendment

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.

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Exploring Municipal Solutions to the Housing Crisis in Toronto

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:

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Review of Provincial Housing Affordability Task Force

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.

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FoNTRA comments on Ontario Housing Affordability Task Force Report

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.

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Palmerston multiplex

Expanding Housing Options in Neighbourhoods – Update Report

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.

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Expanding Housing Options in Neighbourhoods

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:

  • The proposed Garden Suites Amendments should not apply at this time to lots where multiplex building types are permitted. And appropriate regulations should be developed for garden suites on lots with multiplexes in the multiplex study now underway;
  • Separation distance of the primary building from the ancillary dwelling and where measurements are taken;
  • The need for additional regulations for the conversion of existing ancillary buildings to protect light, view, and privacy of buildings on the lot and neighbours;
  • Communications, monitoring of implementation, and needed supporting processes and information systems.

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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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