Toronto City Hall
100 Queen Street West
Toronto, ON M5H 2N2
Attention: Nancy Martins
RE: PH12.3 Expanding Housing Options in Neighbourhoods: Major Streets Study – Final Report
Dear Chair Pasternak and Members of Planning and Housing Committee,
FoNTRA hereby submits the following comments in regard to the Major Streets Study and the draft OPA 727 and amendments to 569-2013.
FoNTRA supports the general intent of the Major Streets initiative as being a logical framework to pursue opportunities for increased density in Neighbourhoods. However the proposal is presented as “one size fits all”, and no effort has been made to determine if the framework works in the varied street and settlement configurations, and transportation infrastructure, and cultural landscapes across the City. The methodology is not like that of an area planning study. It is simply an overlay of a standard set of permissions on the Official Plan Map 3 that shows road width.
In addition the resulting zoning bylaws will be subject to application for approval of “minor” variances from the Committee of Adjustment, and upon refusal will be allowed to appeal to the Toronto Local Appeal Board (TLAB) whereas residents opposed to the application have no right of appeal further to the Provincial Bill 23.
As such numerous questions arise, such as:
1. What properties are affected?
a. What is a Major Street?
- Map 3 Major Streets – based on road width; has not been updated from maps prepared by pre-amalgamation municipalities.
- Road width is too limited a consideration. Other considerations are the amount of traffic, transit availability and use, and bike lanes.
- The opportunities map included in last Fall’s consultations show sites that are schools, and heritage buildings, that should not be considered[1]
- Using only lot width, a number of streets are included that are of widely variable traffic conditions[2]
Recommendation: That a revised map be developed that shows where Major Street intensification is proposed.
b. Are area specific existing policy and regulations affected?
- An example is the comprehensive Townhouse Guidelines for a large section of Bayview, developed in consultation with local residents.
Recommendation – Clarify whether such area policy and guidelines remain or are they superseded?
c. How will the public know which properties are affected?
- Looking at OP Map 3 and at the yellow Neighbourhoods areas shown on OP Map X is not helpful.
Recommendation – A new series of maps should be provided to show the proposed affected sites.
d. How will 6 storey buildings fit in Neighbourhoods?
- Permitting 6 storey buildings in Neighbourhoods is contrary to existing Neighbourhoods policy. Many residents have concerns about permitting 6 storey buildings, while 4 are permitted generally in neighbourhoods. The recommendations include new specific regulations for these buildings.
Recommendation – Provide illustrations as to how the regulations for 6 storey buildings will operate in determining where such a building would be permitted and how it would relate to its neighbours.
2. How will the many proposed Official Plan and Zoning Bylaw changes affect local sites?
The report includes a wide range of proposed requirements, essentially the same as the Fall 2023 report but with some additions – such as processes for tree protection, special setback requirements for primary windows, soft landscaping, a requirement that buildings face the major street etc. But there is no information about how the proposals will fit on an actual lot
- The same abstract illustrations used in the Fall 2023 report are used in the Final Report to show some of the proposals. Updated illustrations on various different types of lots are needed.
Recommendation – Provide real site examples for different neighbourhoods.
- Parking is not required to be provided but on what basis? There will be some level of need and if not provided an impact will impact on adjacent residents. .
Recommendation – Consider street permit parking and complete street improvements
3. What approval process is needed?
a. This not a “normal” planning initiative that has clearly defined application – it is not clear which are Major Streets, where the proposals are actually located, and which neighbourhoods across the City are affected!
Recommendation – that maps of the affected lands be developed to show the affected properties at an appropriate scale.
Overall Recommendation –
- That PHC recommend that City Council direct staff to report to each of the Community Councils on the feasibility of the Major Streets proposal with respect to the specific major streets in the Community Council Area.
Yours truly,
Geoff Kettel
Co-Chair, FoNTRA
Cathie Macdonald
Co-Chair, FoNTRA
[1] See Attachment below – FoNTRA Major Streets – 7 Case Studies of Map Locations
[2] For example, a section of Avenue Road south of Oxton which has minimal traffic compared to Avenue Road to the north is part of a “major street” that continues east on Oxton and south on Oriole Parkway back to Avenue Road.