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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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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Proposed implementation of provisions in the Planning Act

The recently enacted legislative changes to the Planning Act enhance the Minister’s authority for zoning orders across the province. This enhanced authority does not apply to lands within the Greenbelt Area. The enhanced authority allows the Minister to:

  • require inclusionary zoning for affordable housing (inclusionary zoning),
  • remove municipal use of site plan control and require agreements between the municipality and development proponent (or landowner) concerning site plan matters, and;
  • make amendments to Minister’s Zoning Orders that use any of these enhanced authorities without first giving public notice.

The changes are not helpful.  Our issues with the expanded use of MZOs are:

  1. Lack of relevant consultation with Bill 197 – will the province listen to this round?

We find that the government’s consultations on legislation it has already passed are a cynical attempt to green-wash legislation that was subject to totally inadequate consultation in the course of the legislative process before it was passed.

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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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development

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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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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