Thank you for the…

Thank you for the opportunity to submit a comment.

I hope the Ministry will consider adding specific setback guidance for additional dwelling units (ADUs) on through-lots, also known as "double frontage lots", a rare anomaly that falls between the definitions of garden suites, laneway suites, and regular houses.

An ADU located in the garden of one house that “backs” onto a city street (as opposed to a laneway) effectively “fronts” onto that street, and should follow setback guidelines for any other houses fronting on a street.

Toronto’s current bylaw says:
"if [a garden suite] is on a through lot, and a residential building on an adjacent lot fronts on the street that abuts the rear lot line of the through lot, the required minimum rear yard setback for the… garden suite is equal to the required minimum front yard setback for the residential building on the adjacent lot."

However, in some cases, there are no prior residential buildings fronting on the rear lot line of a through-lot that could set a precedent. As a result, there is the potential for new homes fronting on a city street with as little as zero setback from the street itself, if there is no sidewalk or boulevard, and if the builder of the garden suite claims they are grandfathered by an old garage built right up to the lot line.

Homeowners who back onto that street quite understandably care less about such things than those who front onto it. This is the key difference from laneway suites and classic garden suites, where all parties have their backs to the alley or backyard area in question.

Thank you for your consideration of this rare but important edge case.