We are counsel to High Park…

We are counsel to High Park Plaza Ltd. (“Client”) with respect to the redevelopment of its lands
at 1730 Bloor Street West, Toronto, which is at the north-west corner of Indian Grove Road and
Bloor Street West (the “Subject Site”). The Subject Site is almost immediately adjacent to the
Keele Subway Station and within the MTSA area for the High Park Subway Station. Our Client
seeks to redevelop these lands with a 22-storey, 176 unit mixed use building with retail at grade.

We write to provide our Client’s comments on the City of Toronto’s (the “City”) proposed Official
Plan Amendment No. 540 (“OPA 540”) as it applies to the High Park Station PMTSA, SASP 652
(schedule 14 of OPA 540) and the Keele Station PMTSA, SASP 653 (schedule 15 of OPA 540).
For ease of reference, we have attached the relevant excerpts from OPA 540 that apply to the
Keele Station PMTSA and High Park Station PMTSA (collectively, the “PMTSAs”) at Appendix
“A”.

Our Client is concerned that the minimum densities identified by the City for the High Park
Station PMTSA and Keele Station PMTSA generally, and for the Subject Site specifically, are
too low to facilitate transit supportive development that optimizes use of these lands and transit.

As you know, one of the core objectives of provincial policy as reflected in the Provincial Policy
Statement 2020 and A Place to Grow: Growth Plan for the Greater Golden Horseshoe is to
increase density in protected major transit station areas and optimize use of these lands and
transit. The portion of Bloor Street West that falls within the PMTSAs is a prime location for
increased density. The City’s current policy regime for these lands is deficient to encourage the
level of density needed to support transit and optimize the use of these lands. We are hopeful
the Province will amend the OPAs before it so that they facilitate a level of density on the
Subject Site that optimizes use of the lands.

To illustrate the issue as it applies to the Subject Site, OPA 540 sets a minimum density of 2.0
FSI. This minimum density is in fact lower than the as-of-right density permission that exists in
the City’s Zoning By-law for the Subject Site, which is 5.5 FSI. A minimum FSI of 2.0, as
proposed in OPA 540, is insufficient to facilitate transit supportive development that optimizes
use of the land as it would not facilitate any form of high rise building on the Subject Site.
Request

Our Client requests the Province to revise the High Park Station PMTSA, SASP 652 (schedule
14 of OPA 540) and the Keele Station PMTSA, SASP 653 (schedule 15 of OPA 540) to
increase the minimum density for the Subject Site to 10.5 FSI. This would facilitate a 22 storey
mixed use building on the Subject Site as described in more detail below. This can be done by
amending Map 2 to SASP 652 and SASP 653 to reflect this increased minimum density for the
Subject Site.

If our requested amendments are not made, and SASP 652 and SASP 653 are approved in the
form as adopted by the City, these planning instruments will do little to achieve the Province’s
minimum persons and job targets for these PMTSA –which is set at a minimum of 200 persons
and jobs per hectare. This is especially the case for the Subject Site, as the PMTSAs would not
facilitate high rise development on the Subject Site. This should not be an outcome that the
Province should approve given its objective to intensify within major transit station areas. The
Subject Site is perfectly situated for such density because it has the size, frontage, and
proximity to Keele Station. It is almost adjacent to Keele Station, and is within 150 metre walking
distance to the station entrance.

The Subject Site

The Subject Site is a 1220 square metre (13,132 sq. ft.) parcel of land on the north side of Bloor
Street West, approximately 40 metres east of Keele Street. The entrance for Keele Station is
located at the north west corner of Keele Street and Bloor Street West. Keele Station is directly
adjacent to the rear of the Subject Site. A location map showing the Subject Site and its
proximity to Keele Station is attached at Appendix “B”.
The Subject Site is designated Mixed Use Areas on Map 17 of the City’s Official Plan. An
excerpt of Map 17 is attached at Appendix “C”. The Subject Site is zoned Mixed Commercial
Residential (MCR T5.5 C2.0 R4.5, H 32.0) in the former City of Toronto By-law 438-86 and
pursuant to area specific By-law 1222-2009. The zoning permits a density of 5.5 times the lot
area and a height maximum of 32 metres. By-law 1222-2009 that applies to the Subject Site is
attached at Appendix “D”.

Proposed Development

Our Client seeks to redevelop the Subject Site with a 22 storey, 176 unit mixed use building with
retail at grade. A building of this size would make a meaningful contribution to the Province’s
minimum resident and job target for the PMTSAs. To facilitate such a building on the Subject
Site, a minimum FSI of 10.5 FSI is required.

Our Client’s architect, with input from other experts, have prepared a concept block plan for the
proposed development, which is attached at Appendix “E”. This concept block plan shows the
proposed development in pink together proposed retail at grade in blue. It also shows how the
adjacent lands in the block could be redeveloped in purple.

We thank you for your time in reviewing this submission. We would be pleased to discuss with
you any of the above proposed amendments, or our concerns more generally, at your
convenience. We look forward to the Province’s revisions to, and approval of, OPA 540.

Yours truly,
WeirFoulds LLP