Re: Proposed Planning Act…

Re: Proposed Planning Act and City of Toronto Act Changes
Consultations on More Homes Built Faster: Ontario's Housing Supply Action Plan 2022-2023

We, the undersigned at the Centre for Urban Research and Land Development at Toronto Metropolitan University, agree with most of the proposed Planning Act and City of Toronto Act changes. However, we have specific comments and a recommendation for significantly increasing the number of missing middle housing units constructed.

1. Addressing the Missing Middle
• Allowing owners of single-family houses as-of-right, without the need to apply for a rezoning, to
build up to two additional units per lot (for a total of three) is a positive step. Still, it is not likely to
produce a sizable supply of new housing. Bolder action is needed.
• Replacing single-family houses with low-rise apartment buildings (generally four storeys or less, but
possibly up to six storeys) will produce many more housing units appealing to families and
individuals unable to afford a single-family house.
• It is recommended that adjacent single-family homeowners, as-of-right, are allowed to assemble
their properties into a larger land parcel for low-rise apartment development and sell the properties
to a builder to construct a low-rise apartment building.
• Our recommendation would provide a financial incentive for the homeowners to redevelop their
properties for low-rise apartments since the market values of their properties would be higher than
presently when redevelopment to low-rise apartments is not permitted.
• The Province's proposed changes would prohibit municipalities from imposing development
charges, parkland dedication or cash-in-lieu payments on the new infill units. This prohibition should
also apply to community benefits charges, which are not mentioned in the proposed changes.

2. Streamlining Municipal Planning Responsibilities
• We agree that duplication in planning policy and approval responsibility between certain upper-tier
municipalities (regions) and their lower tier should be removed.
• Decisions about the level of government that should be given sole responsibility for various policies
and approvals should be based on an analysis of planning process efficiency and implications for
expediting the housing supply and related economic impacts.
• Policy matters like infrastructure planning and implementation for major roads, transit, wastewater
and water and land needs assessments are typically most appropriate at the regional level.

If you have any questions about our submission, don't hesitate to get in touch with us.

Frank Clayton
Senior Research Fellow, CUR
Toronto Metropolitan University

David Amborski
Director,
Toronto Metropolitan University