The government’s…

The government’s consultation rightly focuses on improving housing choice and affordability by addressing lot size restrictions. Ontario can achieve this by removing minimum lot sizes on serviced urban land and replacing them with measurable form standards. This would expand housing options and support infill without relying on fixed building types.

Once lot sizes vary, tying permissions to building forms like “4-plexes” or “6-plexes” becomes inconsistent. The same building could exceed density limits on one site and be underbuilt on another. Predictable, measurable form rules are essential if the province wants flexibility and fairness across municipalities.

1. Benefits and Risks

Reducing or removing minimum lot sizes can increase housing supply, affordability, and choice. The main risk comes from not clearly defining how form and density will be measured once lot sizes differ.
To maintain predictability, Ontario should define form through Floor Space Index (FSI) and Lot Coverage rather than by lot area or frontage. FSI measures total floor area as a percentage of the lot, while Lot Coverage measures the footprint. These two ratios together manage built form and density.
With these metrics, municipalities can allow flexibility while maintaining consistent scale and livability. Without them, removing minimums could lead to confusion and uneven application.

2. Best Practices from Other Jurisdictions

Japan’s national zoning framework uses two ratios, Floor Area Ratio (FAR) and Building Coverage Ratio (BCR), which correspond directly to Ontario’s FSI and Lot Coverage. There are no minimum lot sizes, yet form remains consistent.

FAR and BCR values are published in 10-point increments (for example 100 percent, 110 percent, 120 percent). Municipalities select combinations suited to local conditions. Ontario could apply the same logic by publishing provincial FSI and Lot Coverage values so municipalities can choose or blend them according to context. This keeps flexibility while ensuring predictability.

3. Circumstances Where Minimum Lot Sizes Are Necessary

Minimum lot sizes should remain only where they directly protect health or safety, such as:
• Areas without full municipal water or wastewater servicing.
• Lands affected by flood risk, unstable soils, or natural hazards.
• Locations where infrastructure or access requirements cannot otherwise be met.
For fully serviced urban residential land, these conditions do not apply, so minimum lot sizes serve no practical purpose.

4. Suggested Lot Size Standards and Implementation

In serviced urban areas, there should be no fixed minimum lot size. Municipalities could regulate building form using FSI and Lot Coverage.
For example, a low-rise residential area could use an FSI range of 100 to 200 percent and Lot Coverage of 40 to 60 percent. A higher FSI with lower coverage yields taller buildings, while a lower FSI with higher coverage yields shorter, broader ones.
Municipalities could select values for each zone or apply several combinations within one zone to create gradual transitions in density. This removes the need for arbitrary minimum area or frontage requirements while keeping development predictable.

5. Supporting Zoning and Performance Standards

Height, setback, and angular-plane rules can continue where needed to manage sunlight access or transitions. These should operate within the same provincial framework rather than being reinvented locally.

Parking, access, and stormwater requirements should be handled through zoning or site plan control, not through lot-size rules. Smaller lots can actually improve infrastructure efficiency and reduce per-unit environmental impact.

Where existing lots are irregular, municipalities can apply small tolerances for construction and survey precision, such as a few centimetres in height or about one percent in total floor area, to keep the system practical.

6. Environmental Considerations

Removing minimum lot sizes on serviced land reduces sprawl, shortens infrastructure extensions, and makes better use of existing networks. These are environmental benefits, not risks. Drainage, floodplain, and soil concerns are already managed through servicing standards and building codes.
Additional Considerations: Severance, Affordability, and Land Reorganization

Allowing smaller lots will not only create new infill opportunities but also make ownership more attainable. When people can buy smaller parcels, they can enter the market at a lower cost, while existing owners can sever and sell portions of their property to family members or other buyers.
Over time, this flexibility could open up new ways for communities to evolve. Groups of owners may wish to reorganize local streets, narrow overly wide roads, or dedicate small portions of land for shared green space. Some small severed parcels could be used for local needs such as parking, storage, or small-scale infill housing. Adjusting setbacks or lot coverage could allow existing owners to expand their homes or add new units within the same footprint.

In Japan, similar re-plotting projects allow owners to pool land, dedicate part of it for new roads or parks, and receive smaller but better-serviced parcels in return. Ontario does not have an equivalent framework, but subdivision and local-improvement tools could serve a similar purpose if modernized and applied collaboratively.

If Ontario moves ahead with lot-size reform, it should anticipate these long-term possibilities. Smaller lots increase choice now, and future coordination tools, whether through subdivision, local improvement, or municipal partnerships, can ensure these smaller parcels remain practical for redevelopment, infrastructure renewal, and shared public improvements.

Summary

Ontario can improve affordability and streamline development by removing minimum lot sizes on serviced urban residential land and replacing them with consistent, measurable form standards.
• Remove minimum lot sizes where full municipal servicing exists.
• Define built form using FSI (Floor Space Index) and Lot Coverage in 10-point increments.
• Allow municipalities to select or combine values within zones.
• Retain minimums only for wells, septic systems, or hazard lands.
• Apply height, setback, and angular-plane rules only where needed.
• Permit small dimensional tolerances for construction accuracy.
• Encourage gentle density and infill that uses existing infrastructure efficiently.
• Recognize that smaller parcels improve access to ownership and can be reorganized later to support new public spaces, narrower roads, or shared servicing.
This approach supports the government’s stated goals of increasing housing supply, promoting affordability, improving land efficiency, and aligning Ontario’s system with proven form-based planning methods used internationally.