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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Regulatory Framework for Multi-tenant Houses

This is to reiterate our support for the proposed regulatory framework for Multi-Tenant Houses, as previously communicated in our letter to the June 28 PHC.

Our reason for communicating again on this matter is to express our opposition to the motion moved by Councillor Ana Bailao, and adopted by PHC, regarding fraternity and sorority houses. They meet the definition of rooming houses and should be included in the regulatory framework.

Our members who have lived experience with such student housing properties in their neighbourhoods report that these properties, which have similar features of rooming houses, can, unfortunately, have similar negative impacts on neighbours. Not all fraternity and sorority houses manage themselves well, and ensure safe conditions, and the community suffers.

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Questions regarding implementation of Multi-Tenant Housing Report

  1. Enforcement problems/life-threatening situations are reported with non-compliant and unlicensed Rooming Houses in zoned areas. What will be done between now and Nov. 1, 2022 in terms of inspection/enforcement to improve the situation? How will MLS and Toronto Fire make progress with these houses, especially the high risk priority houses, if they did not seek Budget allocations in 2021 to hire additional enforcement officers and fire inspectors, and are not planning to in 2022?
  2. Within the City of Toronto, fraternity houses were deemed to be Rooming Houses and they were given 3 years to become licensed. This has not happened. How is the City going to deal with these houses between now and Nov. 1, 2022? Are additional inspection/enforcement officers required?
  3. How will the City deal with illegal Rooming Houses between now and Nov. 1, 2022?

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Garden Suites

Garden Suites – Proposals Report

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.

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A New Regulatory Framework for Multi-Tenant Houses

This is to express our support in principle for the above noted report to create a new comprehensive regulatory and compliance framework (zoning bylaw amendments, licensing requirements), for Multi-Tenant Houses across Toronto.

We appreciate that this represents a cross-divisional multi-pronged initiative that has been a long time in development. We also note that City Planning delivered on our request made in connection with the earlier report (November 2020) to ensure that resident associations (including both tenants, homeowners) are given the opportunity to be engaged in the process of public and stakeholder engagement on the proposed zoning standards for city-wide permissions for multi-tenant housing.

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Laneway Suite Monitoring Report and Action on Garden Suites

As you are aware the various Enhanced Housing Options in Neighbourhoods initiatives, especially laneway suites and garden suites, are of great interest, and raise some concerns for residents.

We are aware that the Garden Suites staff report is coming to PHC on June 28th.  However we are of the opinion that the Laneway Suites Monitoring Report – a review of Laneway Housing initiatives – needs to be available to inform the consideration of Garden Suites and other initiatives. We have requested this throughout the public consultations. We also expressed that there needed to be resident engagement in the review.

Garden suites, as an additional unit on a lot, have much in common with laneway suites, that come with additional challenges from a public safety and community impact perspective. We believe there is unassailable logic of the need for the availability of the results of the laneway suites to inform the development of a garden suites policy.

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City of Toronto Survey of Neighbourhood Housing Needs and Growth

As you are aware the above noted survey has been (or was intended to be) distributed to all resident associations registered with the City. While we appreciate the attention to the views of residents of neighbourhoods, through their resident associations, we are hearing from our members of a number of serious operational concerns with the survey, as well as fundamental concerns about the whole initiative.

A number of active residents associations did not receive the survey when it was first sent out. Some of them received the link forwarded from other organizations such as FoNTRA, and likely several never did receive the survey, or received it very late, and did not have time by the deadline (March 17) to complete it.

Several RAs found that they were either unable to open the survey, or received a message that the organization had already completed the survey. The latter problem has led to the concern that, in some cases, individuals who may or may not represent the RA have completed the survey.

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Townhouse and Low-Rise Apartment Guidelines

We appreciate several aspects of the Guidelines, especially:

  • The “contextual approach” showing the evolution of, and the relationship between, the various typologies of the townhouse and low rise apartment building formats.
  • The principled approach to the statements of intent and direction
  • The requirement for a “block” context analysis for large sites
  • The practicability of the proposed actions, and case studies
  • The clear organization of the report and use of graphical presentations

However, the January 2018 edition of the Guidelines has been revised to incorporate several BILD comments. We strongly object to additional language on page 9 of the Introduction – How and where the guidelines apply (page 9) which refer to “balancing” of the need for new development to enhance and fit within the area context, and to accommodate housing in a growing city (see attachment).

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