I object to the…

I object to the modifications to this policy and their impact on local planning. The proposed revisions undermine recent changes made by Toronto's Expanding Housing Options in Neighbourhoods initiative and lack sufficient public consultation. I am concerned that this modification wasn't published to the constituents yet will significantly change building policy in an established neighbourhood.

I specifically oppose the removal of the Floor Space Index (FSI) for Accessory Residential Units (ARUs). FSI ensures buildings fit neighbourhood scale, promotes mixed-use developments, supports infrastructure, preserves green spaces, and maintains neighbourhood character.

Our neighbourhood has permitted ARUs as of right for years with the FSI standard. Eliminating it is unnecessary and undermines the cohesive function of bylaw standards. This change will not guarantee additional units but may lead to large houses with unoccupied roughed-in ARUs, failing to create affordable housing.

Removing the angular plane will increase shadowing and limit plantable space. Expanding the as-of-right building envelope threatens mature trees by interfering with their root systems. A minimum distance of 4 meters between the main house and garden suite compromises soft landscaping and worsens heat islands.

Eliminating minimum lot sizes for ARUs allows for homes with unguaranteed ARUs, risking affordability. Garden suites have not contributed to affordable units in our neighbourhood, and increasing the as-of-right envelope will remove protected trees without notifying owners.

Expanding hardscaping contradicts efforts to mitigate climate change and violates PPS 2024 by neglecting the importance of trees and soft landscaping. These changes conflict with the City of Toronto's Forest Management Plan, which aims for a 40% tree canopy for livability. Tree preservation must align with development.

Trees enhance property values, improve air quality, sequester carbon, support biodiversity, aid stormwater management, beautify neighbourhoods, promote walkability, reduce noise, and enhance quality of life.

The proposed amendments contradict PPS 2024 policies on energy conservation, air quality, and climate change adaptation. Planning authorities should focus on reducing greenhouse gas emissions, promoting green infrastructure, and maximizing vegetative surfaces. Specifically:

2.9 Energy Conservation, Air Quality and Climate Change

1. Planning authorities shall plan to reduce greenhouse gas emissions and prepare for the impacts of a changing climate through approaches that:
b) incorporate climate change considerations in planning for and the development of infrastructure, including stormwater management systems, and public service facilities;
c) support energy conservation and efficiency;
d) promote green infrastructure, low impact development, and active transportation, protect the environment and improve air quality; and
e) take into consideration any additional approaches that help reduce greenhouse gas emissions and build community resilience to the impacts of a changing climate.

8. Planning for stormwater management shall:
c) minimize erosion and changes in water balance including through the use of green infrastructure;
d) mitigate risks to human health, safety, property and the environment;
e) maximize the extent and function of vegetative and pervious surfaces;
f) promote best practices, including stormwater attenuation and re-use, water conservation and efficiency, and low impact development; and
g) align with any comprehensive municipal plans for stormwater management that consider cumulative impacts of stormwater from development on a watershed scale.