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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FoNTRA expresses concern about the planning rationale for amending the Official Plan to permit neighbourhood retail stores

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.

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Committee of Adjustment Feedback

The City of Toronto is conducting a review of the Committee of Adjustment. Led by the City Planning Division, the objective of the review is to improve effective participation in the public hearing process. A third-party consultant, KPMG, was retained to carry out the work.

KPMG has already begun work on this project including two feedback sessions held on June 2nd and June 13th with residents’ associations invited to attend. We understand that about 30 residents’ associations participated in these sessions.

FoNTRA has completed some research work related to this subject and has created three reports…

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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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Request to pause federal funding for YNSE

Subject: Request that you pause federal funding for the YNSE until a deal is made public

Dear Prime Minister,

On behalf of the resident and ratepayer groups in York Region and elsewhere in the GTA, listed below, I respectfully request that your government pause payment to the Government of Ontario of your government’s 40% portion of funding for the Yonge North Subway Extension (YNSE) until such time that the Government of Ontario makes public the details of a financial deal it made sometime in 2021-2022 with the owner of lands on either side of Highway 407 at Yonge Street, and until such time that the Government of Ontario meets all conditions and guarantees for funding set forth by your government.

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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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It’s time to free Toronto from the Ontario Land Tribunal

This is to express our qualified support for the Motion:

  • that City Council request the Province of Ontario to dissolve the Ontario Land Tribunal and replace it with a true appeals body that only grants hearings based on an error in law or procedure.

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.

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Developing a Parking Strategy for Toronto

The Federation of North Toronto Residents Association (FoNTRA) is supportive of the Active TO Midtown Yonge complete street Pilot installed last year.  ActiveTO bike lanes are an important part of the City’s transportation system, helping to reduce automobile use, to enliven the streets, and support the businesses along Yonge Street in Midtown.

We appreciate that the current pattern of streets to the west and the Yellow Creek ravine to the east result in land-locked communities that create challenges to the implementation of the pilot. We are aware that Councillors Layton and Matlow are currently working with Transportation staff and residents to resolve the localized concerns about the current installation of bike lanes and CaféTO installations along with related initiatives to reduce traffic congestion on Yonge Street, such as left-turn lanes. Two of our member organizations are opposed to bike lanes on Yonge Street and their impact on traffic, and another has raised issues re: access to residential streets and impacts of upcoming construction related to development projects, we urge the Committee and City Council to ensure that the traffic concerns underlying their opposition are addressed in the proposed extension of the ActiveTO Yonge Street Pilot.

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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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2022 Cycling Infrastructure Installation

The Federation of North Toronto Residents Association (FoNTRA) is supportive of the Active TO Midtown Yonge complete street Pilot installed last year.  ActiveTO bike lanes are an important part of the City’s transportation system, helping to reduce automobile use, to enliven the streets, and support the businesses along Yonge Street in Midtown.

We appreciate that the current pattern of streets to the west and the Yellow Creek ravine to the east result in land-locked communities that create challenges to the implementation of the pilot. We are aware that Councillors Layton and Matlow are currently working with Transportation staff and residents to resolve the localized concerns about the current installation of bike lanes and CaféTO installations along with related initiatives to reduce traffic congestion on Yonge Street, such as left-turn lanes. Two of our member organizations are opposed to bike lanes on Yonge Street and their impact on traffic, and another has raised issues re: access to residential streets and impacts of upcoming construction related to development projects, we urge the Committee and City Council to ensure that the traffic concerns underlying their opposition are addressed in the proposed extension of the ActiveTO Yonge Street Pilot.

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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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Stop Out-of-Control Housing Prices

This is to express our strong support for the Motion and Recommendation from Executive Committee to request that the Government of Ontario help to stop out-of-control housing prices by imposing a home speculation and home flipping tax. 

The latter view has been eloquently expressed by Professor Patrick Conlon[1] noting that cities such as Vancouver have “already tried harder than anywhere else in North America to add housing supply in the hopes of lowering home prices and sadly it has not worked…..what’s happening in B.C. is happening elsewhere — whether they are adding housing slowly or quickly. It makes no difference if these cities are constraining supply like San Francisco, California, or letting it rip like Austin, Texas. Everywhere, housing prices are separating from the ability of average wage earners to afford homes.

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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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Updating legislation for Mount Pleasant Group of Cemeteries

We are writing to express our strong support for the proposed legislation (Bill 74, Mount Pleasant Public Cemeteries Act, 2021), introduced by Jessica Bell, MPP, that will update and modernize the Mount Pleasant Group of Cemeteries Charter, which dates from 1871.The legislation is in desperate need of modernization to bring it up to today’s standards of accountability and transparency. This new bill will repatriate the Mount Pleasant Group of Cemeteries back to the people of Ontario, safeguarding what the public originally created.

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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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Actions to Reaffirm Toronto’s Tree Canopy Target

This is to express our strong support for IEC’s recommendation that City Council reaffirm Toronto’s target of 40 percent tree canopy cover by 2050 to align with the City of Toronto’s TransformTO Net Zero Strategy. However we strongly feel that mere reaffirmation of the 40 percent tree canopy target is inadequate and ineffective. We have to:

(1) actually protect the private trees that are of protected size;
(2) strengthen the Tree Protection By-laws,
(3) increase enforcement of the existing (and hopefully enhanced) Tree Protection Bylaws
(4) Increase replacement planting when trees are to be removed.
and
(5) maintain and enhance the existing protection for soft landscaping in the Zoning Bylaws

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Critical Steps for Net Zero by 2040

This is to express our strong support for this report and its recommendations. We do however question whether the City has a mechanism in place to ensure that its policies are in sync with respect to the City’s approved Climate goals.  We believe this continues to be an issue. For example elsewhere on City Council’s agenda:

PH29.2 Changing Lanes: The City of Toronto’s Review of Laneway Suites – Monitoring Program and Zoning By-law Amendments – Final Report
The proposed reduction of the soft landscaping requirement in the Laneway Suites by-law is contrary to the Climate imperative to maintain or enhance protection for soft landscaping in the Zoning Bylaws.

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