Proceeding with an MZO would…

ERO number

025-1368

Comment ID

182032

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

Proceeding with an MZO would lock in a delayed, investor-dependent multiple tower project that:
does not start until after 2030;
fails the Province’s priorities to get shovels in the ground now and build family homes faster, and
increases absorption, fiscal, and governance risk;
while conferring a large land-value windfall to a single developer without assurance that housing or public benefits will be delivered sooner
OPA 70 enables earlier starts and more deliverable housing by 2031 with lower public risk.

Key Findings
1. TOC density is an extreme outlier
Proposed TOC density (~10.8 FSI; ~2,490 people+jobs/ha) is unprecedented for a suburban GO MTSA, and extreme for any North American city
Roughly double the already-high OPA 70 TOC density (~5.75 FSI), without better outcomes. More than double the Milliken GO TOC.
2. TOC fails the “Shovels in the Ground Now” test
Tower construction is not expected to begin until ~2031, with a ~20-year build-out, and high project risk.
By contrast, Mid-rise delivery at OPA 70 densities can begin immediately and deliver more homes by 2031, with better profitability and lower risk.
Delivery speed and project duration—not peak density—drive near-term supply.
3. TOC built form targets a weak investor market; high risk of “paper density”
No independent market evidence supports financing or absorbing ~7,000 high-rise units on a single site; likely outcome is delay and back-loaded delivery.
Weak investor demand for TOC density condo towers increases probability of pauses, land banking, and “paper density.”
Mid-rise forms better support family units, usable parks, and earlier livability—improving absorption certainty.
4. Fiscal and infrastructure risk shifts to taxpayers
Infrastructure funding and delivery sequencing are not secured.
Parkland relies heavily on POPS (15%) rather than true public parks
OPA 70 integrates infrastructure planning, CPPS tools, and cost-recovery certainty.

5. Significant private land-value uplift with no delivery guarantee
MZO zoning uplift is estimated at ~$88 million for one developer.
No binding assurance that housing or public benefits will be delivered sooner as a result.
6. Governance concerns
The TOC MZO lacks any need urgency, municipal support (unanimous Council opposition), and demonstrable public interest.
Limited transparency and reliance on confidentiality mirror risks identified by the Auditor General in recent land-use reviews.

Conclusion
This is not a choice between growth and no growth. It is a choice between deliverable, family-oriented housing starts now under OPA 70 and speculative hyper-density with delayed outcomes under an MZO.
Recommended course: approve OPA 70 without delay and require any TOC proposal to align with it.