March 18, 2020
Chief Planner and Executive Director City Planning Division
RE: City of Toronto Survey of Neighbourhood Housing Needs and Growth
Dear Mr. Lintern,
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.
- In order for an RA to come to a consensus on the responses there needed to be a way of opening the survey to more than one participant from the same organization, and more time was required to arrange/discuss and reach a consensus on responses by its Board.
- While the survey was issued on February 26, and re-issued March 5, the deadline of March 17 was insufficient given the necessity for discussion among RA members in order to arrive at a consensual response. We note that the City policy has been to cancel or postpone meetings and surveys due to the COVID – 19 epidemic which is creating barriers for interactive groups to meet.
- Many neighbourhoods are experiencing an unprecedented level and scale of infill development, associated with increased height, massing and density, largely as a result of the increasing flexibility of Committees of Adjustment decision-making in regard to “minor variances”. This is resulting in development that does not fit with prevailing neighbourhood character.
- The City has lost momentum in the critically important effort to provide tools to protect neighbourhood character. The City has still not published the Neighbourhood Character Guidelines template. To date Guidelines been developed and approved for only one neighbourhood (Long Branch). Further the authorised heritage studies of certain character neighbourhoods, such as Lawrence Park (HCD) and Leaside (CHRA), are currently on hold, according to the City Planning’s Study Work Program for 2020.
- What planning framework will be established to ensure that the new building types will fit with the character of existing neighbourhoods? Building mass, amount of light, amount of open space, tree protection, parking forms etc. are important to character. Will the Zoning Bylaw have to be amended? Will they need Committee of Adjustment (and subsequent TLAB appeals/approval)? It appears that OPA 320, which was intended to strengthen the ability of the City to protect neighbourhood character, is tending to be ignored by both Committee and TLAB.
- What will be the impacts on existing infrastructure, achievement of affordable housing, tree cover and environmental objectives, and provision of schools, parks, transit services?
- We believe the most effective plan for the Yellow Belt would be to move forward with higher order transit investments in Etobicoke and Scarborough before dealing with land use changes. While the “missing middle” concept is supposed to apply to the whole “Yellow Belt” i.e. about 75% of the city’s area, the reality is that development currently (and current trends appear likely to continue) is concentrated in the Yonge Corridor and Lake side extensions east and west. However, the real need is to “spread out“ development to the whole city.
It increasingly appears to residents that the City has lost, or is close to losing the will to “maintain neighbourhood character”, and ensure equity in development across the city as required by the Official Plan. We need a stronger regulatory system.
We look forward to discussing this with you further.
cc: Mayor John Tory and Councillors
Michael Mizzi, Director, Committee of Adjustment and Zoning
Kerri Voumvakis, Director, Strategic Initiatives
District Directors, Community Planning