City Planning Division – Study Work Program

10th floor, West Tower, City Hall
100 Queen Street West
Toronto, ON M5H 2N2
Attention: Nancy Martins

RE: PH12.3 City Planning Division – Study Work Program

Dear Chair Ana Bailao and Members, Planning and Housing Committee,

This is to present comments in support of the City Planning Division Study Work Program on behalf of the Federation of North Toronto Residents’ Associations (FoNTRA), an umbrella organization of over 30 resident associations in North Toronto and North York.

FoNTRA understands the importance of a vital and active planning function to the long-term health of the whole city including thriving and complete communities. City Planning Division activities basically consist of two streams: undertaking planning studies, and creating plans; and managing development applications. The Study Work Program includes such activities as Avenue Studies, Secondary Plans, Zoning By-law Updates, Heritage Conservation District (HCD) Studies, Community Heritage Resource Assessments (CHRA) and neighbourhood-specific Design Guidelines. The underlying principle is that the Study Program is critical in order to strengthen the position of the City in dealing with development applications. Unfortunately the waiting lists for studies and plans are long, and getting longer.

In order to assess part of the Study Work Program we have extracted and collated the Heritage Conservation studies (HCD studies and plans, CHRAs and other studies) by category i.e. 2020 Forecast, Hearings, Active beyond 2020 and On Hold (see attached). For example two projects from North York, Lawrence Park West HCD and Leaside CHRA, which
were authorized in 2014, are shown as “On Hold” (see attachment). In addition, the Neighbourhood Design Guidelines template which commenced in 2016 is now scheduled to be completed in 2020. In the meantime these neighbourhoods are left without policies and tools to protect their built form. Every two weeks the Committee of Adjustment allows projects that do not fit the established character of the community (and if refused, likely to be allowed by the Toronto Local Appeal Body (TLAB)) so there is a risk that that eventually when the tools and policies are undertaken it may become difficult to demonstrate the prevalence of the character causing them to be unique.

This kind of concern is not restricted to North York or to Heritage, but to the City generally and to various types of plans. Meanwhile City Planning is facing the biggest threat to its ability to manage development applications with the announced issuance of the regulations pertaining to the province’s legislative changes for planning and heritage under Bill 108, and Bill 138) in July 2020. This will disrupt City Planning’s agenda in ways that at this point, we are not fully aware. Meeting the compressed processing deadlines for regular applications and preparing for hearings following an increased number of planning appeals will inevitably put pressure on City-wide and area planning. We understand that for example a Preliminary Report may no longer be issued in advance of a Community Consultation meeting. We are very concerned about the impact of the provincial changes, and City Planning’s consequential response to these.

The development of secondary plans that take transportation and other required infrastructure needs into account along with the availability of parkland, schools, social service requirements, heritage studies, Zoning Reviews and neighbourhood-specific Design Guidelines are critical. It is important to get ahead of the development applications with completed plans, as is being demonstrated in Midtown (OPA 405) and Downtown (OPA406). While the 2020 Staff Recommended Budget includes small staffing and capital funding< increase for certain studies, the Division still lacks the resources to develop and update any but the most critical Secondary plans. Planning for the City’s future – for the population and jobs growth that is expected – necessarily suffers. And the lack of updated Secondary plans with clear population targets/densities and development guidelines necessarily means that too many planning decisions are left to be determined on an ad hoc basis by the Local Planning Appeal Tribunal.

We recommend: – that City Council provide funds to allow for Planning Studies to be maintained and increased despite the disruption caused by provincial legislative changes.

Thank you for the opportunity to express our ideas, concerns and recommendations regarding the 2020 City Planning Division Study Work Program.

Yours truly,

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cc: Gregg Lintern, Chief Planner and Executive Director, City Planning Division
Joe Nanos, Director, Community Planning, North District
Lynda Macdonald, Director, Community Planning, Toronto and East York District
Lorna Day, Director, Urban Design, City Planning Division