February 25, 2023
Toronto City Hall
100 Queen Street West
Toronto, ON M5H 2N2
Attention: Nancy Martins
Re: PH2.7 – Development Pipeline 2022
Dear Councillor Bradford and Members of the Planning and Housing Committee
This is a useful and important document. The data it presents provide ample evidence on the astounding imbalance between planning approvals and construction of new housing. But the data are also incomplete, because it says nothing about the provision of affordable housing for households with below-median income.
Our comments are exclusively focused on housing supply.
Approvals vs. construction
The incredible surge in planning applications for new housing projects in 2021 and 2022 is nothing short of amazing. More than triple the number of planning applications in 2021 as in each of the previous five years. (See Figure 2.) And as of June 2022, as many more applications in 2022 as in the entire year 2021.
Again, as of June 2022, enough residential planning applications in the pipeline to build 43 percent more than the total need by 2051 according to the Provincial Growth Plan.
The key question: How many of the approved developments will be built? How many have been submitted merely to raise land values? It is salutory to have this data presented when the issue before the Committee is how to make the approval process work more efficiently.
Municipal housing target
A closer look is provided by comparing applications to the 2031 target set by Bill 23.
The comparison is even more extreme: applications in the pipeline as of last June add up to more than double the provincially-set target. Who will buy all these units? Will they be built? Why the rush to approve more?
Affordable housing supply
The Pipeline Report provides no information on the key issue in the housing market — the construction of new housing that is affordable to below-median-income households.
Even if all approved units are built, at what price will they be sold? Or rented? One of the reasons for the huge surge in applications in 2021 and 2022 was to get planning applications into the pipeline before Inclusionary Zoning rules became effective.
The data summarized in Table 19 indicates that few of the applications submitted in 2022 were for purpose-built rental housing. And of these projects, how many were for high-rent units?
We need data on the markets that will be served by the applications that are in the pipeline. We recognize that this is not known until projects are completed. We urge the Committee to request that City Planning report on the breakdown of completed residential units by tenure (rental vs. ownership) and by size of unit.
Yours truly,
Geoff Kettel
Co-Chair, FoNTRA
Cathie Macdonald
Co-Chair, FoNTRA
CC: Gregg Lintern, Chief Planner and Executive Director, City Planning Division
Melanie Melnyk, Project Manager, Strategic Initiatives, Policy & Analysis
Philip Parker, Project Manager, Strategic Initiatives, Policy & Analysis