Clearing the Path Towards a Safe and Accessible Winter

City Council and City staff are to be applauded for their efforts to ensure that residents have opportunities for outdoor recreation through the ActiveTO. program. Throughout the spring, summer and fall, people have taken to our outdoor spaces in large numbers to walk, run and bike while remaining physically distant. With the COVID-19 pandemic, walking and biking are more important than ever to physical and mental health, especially for seniors and people living with mobility challenges.

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Amendment 1 to the Growth Plan for the Greater Golden Horseshoe 2019

On 29 January 2019, FoNTRA submitted the attached brief commenting on the Proposed Amendment 1 to the Growth Plan for the Greater Golden Horseshoe 2017. Four members of FoNTRA’s Steering Committee also attended your Ministry’s Toronto Regional Round- table on Proposed Changes to Growth Plan on 13 February 2019, which you chaired. Un- fortunately, when the new Growth Plan for the Greater Golden Horseshoe 2019 came into effect on 16 May 2019, FoNTRA noted that few, if any, of its proposals had found their way into the new policy framework.

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TLAB Chair’s 2019 Annual Report

We appreciate the comprehensive review and report by Ian Lord, TLAB Chair. However we feel that while the report raises various matters related to the ongoing operation of the TLAB, it fails to look deeper to the workload generative issues that lie behind some of the issues raised.

Residents play a key role in the operation of the TLAB and need it to operate in a way that is fair to them. TLAB operates largely without input from residents. TLAB business meetings have been established but these are largely ineffective as mechanisms to provide input from residents. Procedure and rules continue to be added to the processes without effective input from residents. (See attached) Given that the appeal process is important to residents as it greatly affects their neighbourhoods, we play close attention to how TLAB is operating and see how it is unfair to residents.

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Committee of Adjustment Virtual Hearings prompts concerns from Residents Associations

As you know, we supported virtual hearings for applications based upon your commitment that these hearings would be used for applications with (truly) minor variances. We have been increasingly concerned that complex applications with many variances, and multiple community objections are being heard in virtual hearings. In addition:

  • the revised timeframes limit the opportunity for comments to be submitted both in writing and orally;
  • written comments are not being posted in time for them to be part of the Committee members deliberations;
  • participants who registered to speak to the Committee are not being allowed in/heard from;
  • participant’s objections are being disregarded by the Committee of Adjustment; and
  • members of the Committee are not acquainted with the tests and/or overtly deny the tests as laid out in the Planning Act and in the public notice.

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TLAB: improving resident participation in new policy initiatives

The agenda for the meeting included a couple of new initiatives: Draft Practice Direction 6: Expert Witnesses, and Evaluation Form). We were pleased that the Chair was willing to allow enough time to hear from residents’ representatives as well as to allow for a fulsome discussion among some Members. However in the end we feel that a multi-step approach to developing and approving such policies is required in order to achieve the best results. We suggest that, at a minimum, an initiative should go through two readings, with an initial meeting to present a proposal and gather stakeholder input, followed by a second meeting to present and receive input to the TLAB on a revised proposal. We suggest the Board might consider organizing the first meeting with mixed stakeholders so that there is an opportunity for enhanced understanding, perhaps with independent facilitation.

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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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City Tree Canopy Study

We are the collective voice for neighbourhood associations in North Toronto and North York and have many concerns about the ongoing health and sustainability of our tree canopy. We are writing to voice our support of the Infrastructure and Environment Committee recommendations.

Specifically, we support: using the findings in the 2018 Tree Canopy Study to inform ongoing programming; to increase tree planting and maintenance on private land; to increase the tree canopy to 40%; to facilitate plans to enhance the tree canopy in identified neighbourhoods that have experienced significant losses; and to facilitate the enforcement of tree protection.

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Construction Projects Right-of-way Occupancy

The Federation of North Toronto Residents’ Associations (FoNTRA) strongly supports the recommendation of the Infrastructure and Environment Committee to request the General Manager, Transportation Services, in consultation with the Chief Planner and Executive Director, City Planning to prepare a report on implementing a new right-of-way occupancy permit policy that defaults to a denial of requests, except when no other options are available.

In the event no other options are available and closure of the right-of-way adversely impacts the public use of the right-of-way, FoNTRA supports requiring that a percentage of the additional Gross Floor Area achieved by the developer, as a result of City right-of-way use for construction, is to be provided for public amenities, such affordable housing, childcare, or seniors’ services.

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Committee of Adjustment Applications Analyses and Service Improvements

FoNTRA is pleased to see the staff report outlining various application analyses and service improvements over the past two years.

While some process improvements, including efforts to standardize procedures across all four districts, have been accomplished, the overall question remains – are Neighbourhood Planning (City Planning), the Zoning By-law (City Planning), the Committee of Adjustment (City Planning), administration of the Zoning By-law (Building) and Building Permit issuing (Building) producing outcomes intended by the Official Plan?

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Toronto-Ontario Transit Update

We strongly support the cancellation of the upload of the TTC ownership to the province and in principle are in favour of a more ambitious Ontario Relief Line that extends all the way north to Eglinton and west to the Exhibition GO station. This expanded line will provide additional high density neighbourhoods with high speed transit and take pressure off the existing Yonge and Bloor-Danforth subway lines.

The Ontario Line is still at a conceptual stage, both in terms of route and transit technology. This poses a significant risk of delay beyond the alternate City Relief Line completion date. A relief line component of any Ontario Line Plan must be fast tracked. The Yonge and Bloor-Danforth lines are already heavily congested. And ridership demand for both lines is expected to continue to grow significantly.

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End to End Review of the Development Review Process

The staff report describes the results of a consultant lead process to re-engineer the Development Review Process. The report references the need to hire staff to implement the Review’s recommendations over a number of years. In the end, the staff report merely recommends that the report be received.

For the record, FoNTRA has, over several years, been engaged in discussing concerns about the current processes with City Planning staff and earlier this year submitted a proposal for an End to End Review focused on Committee of Adjustment and LPAT, which are part of the Development Review Process that is much in need of review (see Attachment).

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“Minor” Residential Planning and Development Decision-Making in Toronto

This report outlines issues related to the Toronto Zoning By-law 569-2013 and the Toronto Committee of Adjustment’s handling of severances and minor variances related to residential land use planning and development.

City Planning and Toronto Building are both involved, but, rather than operate sequentially, they interlock:

  • Zoning By-law development and management is the responsibility of City Planning
  • Management of the Committee of Adjustment is the responsibility of City Planning
  • Intake, Review and Acceptance of Committee of Adjustment applications, and Zoning Examination Reviews (by-law administration) are the responsibility of Toronto Building.

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Committee of Adjustment – Panel Size and Structure

This communication is in support of staff report recommendations:

  • to increase the Committee of Adjustment (CoA) membership from 30 to 35 members, with two of the additional members assigned to the Toronto and East York (TEY) district and three to the Etobicoke York (EY) district;
  • that panel members be assigned to a district rather than a particular panel within a district.

We have no comment on the other administrative changes proposed.

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Amendment 1 to the Growth Plan for the Greater Golden Horseshoe

According to the government, the “proposed changes address implementation challenges with the Plan that were identified by the municipal and development sectors and other stakeholders” and “are intended to provide greater flexibility and address barriers to building homes, creating jobs, attracting investments and putting in place the right infrastructure while protecting the environment.” We note for the record that FoNTRA, as one of the most significant stakeholder organization in the Province representing the interests of residents, had not been consulted.

The stated purpose of the proposed changes is “to quickly address identified implementation challenges with the Plan and to not unfairly disrupt housing and other developments currently underway,” so as “to unlock land faster for residential and commercial development and support more jobs and housing.” This seems to suggest that there is a shortage of land available for development and may explain the proposed deletion of existing language describing one of the Growth Plan’s key underlying concepts: “There is a large sup- ply of land already designated for future urban development in the GGH. In some communities, there may be more land designated for development than is required to accommodate forecasted growth to the horizon of this Plan.” Is there a shortage or a large supply of land designated for future development?

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Transit Planning Inquiry

We are writing to express our support for an updated inquiry into Toronto’s planning of major transit infrastructure projects.

We do not take a position on the manner by which such an inquiry is undertaken. How Toronto’s current transit investment plans are reviewed is a matter for City Council to decide. Nor do we wish to spend time debating how past decisions have been made. Our concern is with the present, and with what the future will bring. There is an urgent need for a review of transit investment priorities and for related development planning.

Our concern is simple: Transit capacity in Toronto’s central and midtown area — the corridor served by the Yonge Street subway— is already now overwhelmed in rush hours and at capacity even in off-peak daytime hours. It is often not possible in the morning rush-hour to board trains downtown from Eglinton or from stations south of Eglinton down to Bloor.

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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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Inclusionary Zoning

This is to express our strong support for the Planning and Growth Management Committee’s recommendation to City Council (which endorsed the staff report recommendation) to request the Province to amend the proposed inclusionary zoning regulations, and to consult further with municipalities and stakeholders on an appropriate and flexible implementation framework for inclusionary zoning, prior to proclaiming the regulation.

The Province’s proposed rules would

  • Restrict municipalities from requiring more than 5% of new units to be affordable (or 10% if they are in a Major Transit Station Area);
  • Prevent municipalities from requiring developers to build affordable units if the new development is a rental building;
  • Require the municipality to contribute 40% of the cost of making the units affordable. These rules would mean that, despite municipalities being given new powers, virtually no affordable housing would be built.

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