Proposed Planning Act and…

Proposed Planning Act and the City of Toronto Act Changes
(Schedules 9 and 1 of Bill 23- the proposed More Homes Built Faster Act, 2022)
ERO number: 019-6163

We wish to express our interest in several provisions under Schedules 9 and 1 under Bill 23 (More Homes Built Faster Act, 2022) which we believe will have negative consequences and impacts to employment lands despite not being specifically addressed in the proposed changes. First, the intent of the bill to address the housing shortages is laudable. We fear however, that the haste to do so has built in unintended consequences that go beyond the scope of the changes put forth.
Of most concern to us are the following proposed changes:
1. The prohibition of third-party appeals of most planning and development approvals,
2. Allowing the province to override municipal official plans to allow higher-density housing in strategic areas, including Major Transit Station Areas (MTSAs) to achieve Provincial density/housing targets
Emery Village BIA, which was formed in 2003, is Canada’s largest Business Improvement Area. Located in the north-west of the City of Toronto its borders including Highway 400 to the east, Wilson Ave. to the south, Steeles Ave. to the north and the Humber River/Islington to the west.
Emery Village BIA is also one of the City of Toronto’s largest designated Employment Zones comprised of 3,200 commercial, industrial and retail establishments which employs approximately 28,000 people. Under the Provincial Growth Plan the area is designated as a Provincial Significant Employment Zone (PSEZ). Once the Finch-West LRT is completed, the core of the BIA will include a Major Transit Station Area (MTSA). The latter designation will lead to higher density development in a radius area that will create sensitive use adjacencies. With the reduction of the buffer areas (from 800 metres to 500 metres) , along with the downstream pressures for faster approvals for residential development proposed under Bill 23, the long-term operations and economic viability for adjacent industrial and manufacturing land users ( in the core employment area) will face enormous pressure to give way to residential development.
Under the Growth Plan for Toronto, the goal is for the city to achieve accommodation for an additional 700,000 residents by 2051, while accommodating over 450,000 more jobs. With most employment areas built out, roughly less than 19% of the land use is designated for employment, including 5.2% in mixed use areas. Thus, the need to promote and enhance protection for employment areas is critical now and into the future.
Notwithstanding that employment zones are not specifically addressed in Bill 23, our concerns are that the implementation of the proposed changes will have downstream impacts by way of revised planning priorities and considerations. MTSAs are but one example of that to happen.
The BILD Municipal Benchmarking Study, which is referenced in the overview to Bill 23, municipal tools and processes are listed that could be modified and scored for expediting applications for housing development. However, the BILD Study’s demographic analysis fails to account for employment availability and land use and its relationship to the net migration trends, housing tenure and changes in household sizes.
While it is evident that Bill 23’s focus is to create the conditions and processes favourable for residential development, it overlooks the planning processes and tools (“guardrails”) essential for maintaining viable employment lands and to prevent the conversions that continues to put at risk, current and future employment growth. Under OPA 231, the City of Toronto has undertaken broad consultations to develop Employment Area Policies and zoning that bolster the protection of these lands. Our concerns echo those of other parties, that the pressures to build additional housing will threaten not just employment land and business operations but also sound planning practises and processes that work to balance priorities to create healthy communities and neighbourhoods with facilities, amenities, resources and access to jobs.
Al Ruggero
Project Manager
Emery Village Business Improvement Area
1885 Wilson Ave., Suite 209
Toronto, ON M9M 1A2

T: 416 744 7242
F: 416 744 7857
Email: al@emeryvillagebia.ca
Website: www.emeryvillagebia.ca