Ontario Legislature

FoNTRA Open Letter in Opposition to 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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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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Home Speculation and Home Flipping Tax Proposal

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.

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Garden Suites Community Consultation

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.

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Neighbourhood Change and Intensification Bulletin

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.

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Palmerston multiplex

Expanding Housing Options in Neighbourhoods

The overall EHON strategy is to permit increased density in the Neighbourhoods.  We support this strategy in principle based on the idea of encouraging development across the city rather than allowing over-development in certain parts of the city, such as the Yonge-Eglinton Centre.  However, it is critical that the strategy be create complete communities, not just residential growth. This initiative should not be about adding multiplexes but doing it in the context of building complete communities based on good transit access as well as community services, employment, cultural opportunities and shopping, etc. The study areas chosen should take these principles as a comprehensive framework. The best opportunities for this type of intensification are in the low density suburbs.

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The City of Toronto’s Review of Laneway Suites

FoNTRA members have participated in City Planning’s consultations to date and have submitted comments on earlier versions.

We remain concerned about two proposed changes that relax the current regulations: the increased permitted height; and the blanket exemption for walkways. The stated reason driving these changes is the frequency of variance requests at Committees of Adjustment. In our opinion such changes should not be based on Committee of Adjustment decisions without evaluating their reasons, if any, and without evaluating the impacts on abutting neighbours.

Proposed Increase in permitted height from 6m to 6.3m

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Laneway suites

Proposed Laneway Suites Zoning By-law Amendments

This is to provide our comments on the draft Laneway Suites By-law Amendments as indicated in the Notice of Public Meeting published in the Toronto Star on November 3, 2021. 

FoNTRA reps recently met with Graig Uens and Caroline Samuels on October 22, and we also participated in the Community Engagement meeting held on October 27. At the latter meeting Graig advised that any further comments should be submitted as soon as possible as this Item is scheduled to be heard at the Planning and Housing Committee meeting on November 25, 2021. We therefore were very surprised to see upon examination of the Notice of Public Meeting published in the Toronto Star indicates that some of the draft Bylaw Amendments are new or different compared with what was presented to FoNTRA and to the Community Consultation meeting. These matters are complex and these changes should have been presented at the consultations to ensure the public has a clear understanding of the implications and an opportunity to ask questions, rather than just seeing them in the draft bylaw.

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Inclusionary Zoning OP Amendment

This is to express the strong support of the Federation of North Toronto Residents Associations (FoNTRA) for the proposed Inclusionary Zoning (IZ) policy.

The proposed policy lays the foundation for IZ in Toronto. It supports individuals and families in our city who earn too much to be eligible for social housing, but not enough to afford market rents and prices.  City Planning claims that the proposed framework balances the need to create more inclusive and equitable communities, provides certainty about expectations for affordable housing, and ensures the City continues to support overall housing supply. City Planning commits to monitor implementation of the new policy, and review and report back within three years.

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Iceberg Homes

Iceberg houses are single-family houses with multi-storey underground basements below, and that may extend well beyond, the above-ground footprint of the structure. We have seen various examples recently, including the particularly notable instance in Hoggs Hollow.

In November 2020, the Committee of Adjustment approved an Iceberg home in Hoggs Hollow – a City designated Natural Heritage System located in a flood plain. Hoggs Hollow is also subject to a 1 hour evacuation in the event of a dam release on the Don River.  Despite numerous objections from Urban Forestry, a healthy 250 year old sugar maple was removed.

As a federation of resident associations we are concerned about the adverse impact of these structures, and the apparent lack of regulatory oversight.  It appears that the “iceberg aspects” are not subject to rigorous zoning and building code requirements.  These concerns include:

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Concorde Gate Zoning Amendment & Subdivision Applications

This is to provide our concerns about the above noted staff report and its recommendations.  FoNTRA would not generally get involved with “local” applications; however frankly this is an audacious application – out of scale, scope and context for the area.

The Rezoning Application and associated Plan of Subdivision application propose to demolish the existing office buildings on the lands at 1 to 3 Concorde Gate and 10 to 12 Concorde Place, and to redevelop the lands with five residential and mixed-use buildings consisting of nine towers ranging in height from 40 to 52 storeys. Overall, the application proposes a total of 4,086 dwelling units, 307,004 square metres of residential space, 841 square metres of retail space, and 437 square metres of community space. The overall gross floor area proposed is 308,284 square metres, which results in an overall density of 9.95 for the lands.

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