10th floor, West Tower, City Hall
100 Queen Street West
Toronto, ON M5H 2N2
Attention: Nancy Martins
Re: PH20.2 City Planning Division – Study Work Program Update
Dear Chair Ana Bailão, and Members of Planning and Housing Committee,
The Federation of North Toronto Residents’ Associations (FoNTRA), is an umbrella organization of over 30 residents associations in Midtown, 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. We recommend:
- That City Council approve additional resources in the 2021 Toronto Budget for City Planning Division’s Study Work Program; and
- that City Planning Division ensure that Studies, Plans and Guidelines directed to protection of neighbourhood character, i.e. HCD, CHRA, and Neighbourhood Guidelines are prioritized.
City Planning Division’s activities basically consist of two streams: the Study Work Program, and Development Review. The Study Work Program, which 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, is critical in order to advance the City’s strategic priorities, and also to strengthen the position of the City in dealing with development applications. It is also vital in dealing with a provincial government that does not respect the authority and jurisdiction of the City.
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 development applications with completed plans, as was demonstrated in both Midtown (OPA 405) and Downtown (OPA406).
However, examination of the Study Work Program proposed for 2021 compared with that for 2020 reveals some concerning trends. The waiting list for studies and plans is long, and getting longer. This trend appears to be especially true for studies which would protect established neighbourhoods, including Heritage Conservation (HCD studies and plans, and CHRAs), and City-Wide and Area Guidelines (such as Neighbourhood Design Guidelines). The Study Work Program data for these categories are collated here by status (Completed, Forecast for 2021, LPAT Hearings, Active (beyond 2021) and Hold for 2020 (Jan. 2020 report) and 2021 (Jan. 2021 report) – see attached.
This chart indicates that while there are a couple of additions to the list in 2021 (e.g. Jane-Finch CHRA), several studies have fallen back from Active (2020) to Hold (2021), i.e. Elm Street CHRA, Fort York HCD, Sunshine Valley HCD. And multiple studies continue to be on Hold, for example, Lawrence Park West HCD and Leaside CHRA, which were authorized as HCD studies in 2014. Meanwhile, the Neighbourhood Design Guidelines template project, which commenced in 2016, is also now downgraded from Forecast (2020) to Hold (2021). The latter is especially concerning as of two pilot areas (Long Branch and Willowdale) chosen for study, only one (Long Branch) was completed, and it appears now that the project is effectively abandoned?
The result of the inaction on these projects is that established neighbourhoods like Leaside, Lawrence Park, Summerhill, and Ramsden Park are left without policies and tools to protect their built form. Every two weeks. the Committee of Adjustment, in failing to take neighbourhood character into consideration, allows projects that do not fit the established character of the community (and what is refused by the CofA is likely to be allowed by the Toronto Local Appeal Body (TLAB) due to the same lack of neighbourhood protection policies and Council approved guidelines). The risk is that that eventually when the policies and guidelines are at last in place it may have become difficult to demonstrate the prevalence of the neighbourhood character that drove the need for protection tools in the first place. In addition, it remains to be seen whether the new Expanding Housing Options in Neighbourhoods projects present additional threats to the character of established neighbourhoods.
Meanwhile, City Planning is facing the biggest threat to its ability to manage development applications with the province’s legislative changes for planning and heritage under Bill 108, and Bill 138. This will disrupt City Planning’s agenda in ways of which, at this point, we are not yet 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 are very concerned about the impact of the provincial changes, such as Community Benefits Authority coming out of Bill 138, and Official Plan/Growth Plan Conformity and Municipal Comprehensive Review (MCR), and we strongly support City Planning’s consequential response to these.
We believe despite (or even because of) the extraordinary fiscal challenges facing the City, these issues need to be addressed at a City wide level – recognizing the strategic importance of City Planning with increases to the City Planning budget, and also at the Divisional level by ensuring that resources be made available for the protection of neighbourhoods. Thank you for the opportunity to express our ideas, concerns and recommendations regarding the2021 City Planning Division Study Work Program.
cc: Gregg Lintern, Chief Planner and Executive Director, City Planning Division
Kerri Voumvakis, Director, Strategic Initiatives
Lorna Day, Director, Urban Design, City Planning Division
Mary MacDonald, Senior Manager, Heritage Planning, City Planning Division