2020 City of Toronto Budget

FoNTRA understands the importance of a vital and active planning function to the longterm 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. Conducting pro-active planning activities such as Avenue Studies, Secondary Plans, Zoning By-law Updates, Heritage Conservation District (HCD) Studies, Cultural Heritage Resource Assessments (CHRA) and neighbourhood-specific Design Guidelines are vitally important. 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.

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City Tree Canopy Study

We are the collective voice for neighbourhood associations in North Toronto and North York and have many concerns about the ongoing health and sustainability of our tree canopy. We are writing to voice our support of the Infrastructure and Environment Committee recommendations.

Specifically, we support: using the findings in the 2018 Tree Canopy Study to inform ongoing programming; to increase tree planting and maintenance on private land; to increase the tree canopy to 40%; to facilitate plans to enhance the tree canopy in identified neighbourhoods that have experienced significant losses; and to facilitate the enforcement of tree protection.

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Construction Projects Right-of-way Occupancy

The Federation of North Toronto Residents’ Associations (FoNTRA) strongly supports the recommendation of the Infrastructure and Environment Committee to request the General Manager, Transportation Services, in consultation with the Chief Planner and Executive Director, City Planning to prepare a report on implementing a new right-of-way occupancy permit policy that defaults to a denial of requests, except when no other options are available.

In the event no other options are available and closure of the right-of-way adversely impacts the public use of the right-of-way, FoNTRA supports requiring that a percentage of the additional Gross Floor Area achieved by the developer, as a result of City right-of-way use for construction, is to be provided for public amenities, such affordable housing, childcare, or seniors’ services.

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City Planning Division – Study Work Program

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).

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.

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Committee of Adjustment Applications Analyses and Service Improvements

FoNTRA is pleased to see the staff report outlining various application analyses and service improvements over the past two years.

While some process improvements, including efforts to standardize procedures across all four districts, have been accomplished, the overall question remains – are Neighbourhood Planning (City Planning), the Zoning By-law (City Planning), the Committee of Adjustment (City Planning), administration of the Zoning By-law (Building) and Building Permit issuing (Building) producing outcomes intended by the Official Plan?

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Special Committee on Governance Summary of Findings

This is to provide our comments on the report and recommendations arising from the Special Committee on Governance (Committee) work relative to its mandate to consider the impacts on the City’s governance structure and processes arising from the reduction in the size of Council, and make recommendations to City Council on any further changes to its governance structure.

It reminds one of a WWII slogan…”Keep calm and carry on” i.e., that in general, things are fine, and there may be some tweaking required. On the contrary it is our impression that (1) the pressure on councillors, particularly in the central south/north corridor is intense, and unsustainable, and (2) the level and quality of discussion has declined in Standing Committees and in City Council due to the reduced number of Members, as Members are unable to cope with the range and complexity of the agendas that they are being asked to weigh in on. At this stage, it is impossible to know whether there are longer term implications of this concern.

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Toronto-Ontario Transit Update

We strongly support the cancellation of the upload of the TTC ownership to the province and in principle are in favour of a more ambitious Ontario Relief Line that extends all the way north to Eglinton and west to the Exhibition GO station. This expanded line will provide additional high density neighbourhoods with high speed transit and take pressure off the existing Yonge and Bloor-Danforth subway lines.

The Ontario Line is still at a conceptual stage, both in terms of route and transit technology. This poses a significant risk of delay beyond the alternate City Relief Line completion date. A relief line component of any Ontario Line Plan must be fast tracked. The Yonge and Bloor-Danforth lines are already heavily congested. And ridership demand for both lines is expected to continue to grow significantly.

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End to End Review of the Development Review Process

The staff report describes the results of a consultant lead process to re-engineer the Development Review Process. The report references the need to hire staff to implement the Review’s recommendations over a number of years. In the end, the staff report merely recommends that the report be received.

For the record, FoNTRA has, over several years, been engaged in discussing concerns about the current processes with City Planning staff and earlier this year submitted a proposal for an End to End Review focused on Committee of Adjustment and LPAT, which are part of the Development Review Process that is much in need of review (see Attachment).

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Proposed regulations pertaining to the community benefits authority

We are very concerned that the new tools proposed under the Community Benefits Charge Authority (CBCA) will not be adequate to provide for both hard infrastructure and the community facilities and parkland that will be needed to support complete communities and make new development liveable for people and families.

The Minister has stated that the new regulations should not result in municipalities having to make up any cost shortfalls. However, until the regulations are fully developed, it is not possible to assess the full impact of the changes to the Development Charges Act or the adequacy of the Community Benefits Charge Authority, and to verify the statement that the proposed regulation changes will be revenue neutral.

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“Minor” Residential Planning and Development Decision-Making in Toronto

This report outlines issues related to the Toronto Zoning By-law 569-2013 and the Toronto Committee of Adjustment’s handling of severances and minor variances related to residential land use planning and development.

City Planning and Toronto Building are both involved, but, rather than operate sequentially, they interlock:

  • Zoning By-law development and management is the responsibility of City Planning
  • Management of the Committee of Adjustment is the responsibility of City Planning
  • Intake, Review and Acceptance of Committee of Adjustment applications, and Zoning Examination Reviews (by-law administration) are the responsibility of Toronto Building.

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Committee of Adjustment – Panel Size and Structure

This communication is in support of staff report recommendations:

  • to increase the Committee of Adjustment (CoA) membership from 30 to 35 members, with two of the additional members assigned to the Toronto and East York (TEY) district and three to the Etobicoke York (EY) district;
  • that panel members be assigned to a district rather than a particular panel within a district.

We have no comment on the other administrative changes proposed.

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Public Input on City Council’s Governance System

This is to express FoNTRA’s strong support for the Proposal on Governance Changes and the work of the Special Committee (Proposal), submitted by the Harbord Village Residents’ Association (GV.New.GV1.2.1)

The provincially imposed changes to reduce the size of council has resulted in an increase in ward size, and in the councillor to resident ratio. We agree with Councillor Holyday that the governance issues facing the City of Toronto and its residents include:

“How the reduction in the size of Council has impacted, or may impact, the City’s governance; and Suggestions for changes to the City’s governance structure, including modernizing governance, following the reduction in the size of Council.”

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Budget Committee 2019 – FoNTRA comments

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. Planning activities such as Avenue Studies, Secondary Plans, Zoning By-law Updates, Heritage Conservation District (HCD) Studies and neighbourhood-specific Design Guidelines are urgently required, yet the waiting lists for such studies and plans are long.

The City Planning Division is swamped by site-specific applications, including Zoning By-law Amendments (ZBAs), and minor variance and consent applications to the Committee of Adjustment. In addition City Planning is forced to deal with the backlog of appeals resulting from the influx of appeals made before the cutoff for the OMB and the establishment of the Local Planning Appeals Tribunal. (LPAT).

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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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Midtown in Focus: Final Report Recommendations

As an organization that has participated actively in all stages of the Midtown in Focus (MiF) Planning process to date, as have a number of our member resident associations, we are unwilling to be drawn into recommending among a choice of options for part of the Plan area, viewed out of the context of consideration of the whole area, and at this late stage in a process that has been marked by strong public engagement efforts on the part of City Planning.

While MiF provides a planning framework for the future new development that results in significant residential intensification, it simply cannot proceed as provided for in the MiF plan without controls on the implementation. We offer a three part proposal to address this:

  1. permit employment generating developments and other non residential uses to proceed;
  2. restrict residential development to “small” projects (to be defined) and .
  3. develop a Phasing Plan for the MiF Plan that would be tied to transit and other missing infrastructure for the Yonge corridor actually coming on stream.

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Transit Planning Inquiry

We are writing to express our support for an updated inquiry into Toronto’s planning of major transit infrastructure projects.

We do not take a position on the manner by which such an inquiry is undertaken. How Toronto’s current transit investment plans are reviewed is a matter for City Council to decide. Nor do we wish to spend time debating how past decisions have been made. Our concern is with the present, and with what the future will bring. There is an urgent need for a review of transit investment priorities and for related development planning.

Our concern is simple: Transit capacity in Toronto’s central and midtown area — the corridor served by the Yonge Street subway— is already now overwhelmed in rush hours and at capacity even in off-peak daytime hours. It is often not possible in the morning rush-hour to board trains downtown from Eglinton or from stations south of Eglinton down to Bloor.

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Townhouse and Low-Rise Apartment Guidelines

We appreciate several aspects of the Guidelines, especially:

  • The “contextual approach” showing the evolution of, and the relationship between, the various typologies of the townhouse and low rise apartment building formats.
  • The principled approach to the statements of intent and direction
  • The requirement for a “block” context analysis for large sites
  • The practicability of the proposed actions, and case studies
  • The clear organization of the report and use of graphical presentations

However, the January 2018 edition of the Guidelines has been revised to incorporate several BILD comments. We strongly object to additional language on page 9 of the Introduction – How and where the guidelines apply (page 9) which refer to “balancing” of the need for new development to enhance and fit within the area context, and to accommodate housing in a growing city (see attachment).

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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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Waivers for Minor Variances

The Federation of North Toronto Residents’ Associations (“FoNTRA”) hereby requests that Toronto Building conduct a feasibility study for the elimination of the Use of Waivers in the identification of minor variances to the zoning by-laws for residential and commercial applications to the Committee of Adjustment (CofA).

The Waiver process started some years ago as an interim measure when a large backlog was created (and every application had to be redone) following the enactment of the consolidated By-law 569-2013.

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