We support the Government's…

We support the Government's initiatives to achieve or exceed the Provincial housing target of 1.5 million homes in Ontario and are convinced that Bill 134 will provide incentives and benefits for affordable housing.

We are concerned that affordability continues to fall victim to a host of policies, regulations and performance standards that create barriers that negatively impact positive efforts such as Bill 134.
Even seemly modest regulatory requirements can have a consequential impact on development and building costs and therefore affordability. The following are only a few examples of the of the considerations that add substantial costs to the provision of affordable housing in the City of Toronto:

Indoor and outdoor amenity requirements of 2 sq. m. for each apartment suite in a new build whether the development is market or affordable ;
Replacement rental suites in new developments are entitled to the same level of finishes; the same provision of amenities and facilities as market suites in the building notwithstanding the level of finishes and amenity in the original replacement suite;
Transitional angular planes that "protect" stable neighbourhoods that have exclusionary zoning for single family homes thereby limiting density and more consequentially requiring terracing that imposing consequential building cost;
Requirement of 100% office replacement in Toronto downtown and midtown secondary plans notwithstanding the significant long term change in the office environment accelerated by COVID;
Minimum density standards adopted by the City of Toronto for MTSAs and PMSTAs effectively neutralized by secondary plan height limit regulations.

City of Toronto Executive Committee will have for consideration at their meeting of October 31, 2023 and item entitled Generational Transformation of Toronto's Housing System to Urgently Build More Affordable Homes.The report contains calls to action from both the Federal and Provincial Governments and number of these requests, which if accepted, would impede and negate the delivery of the Government's Housing objectives. a samplong of these measures includes City zoning approvals to specify tenure; require exclusionary zoning across the entire City of Toronto; planning approvals to be conditional on time limits; re-introducing rent control to cover units occupied after November 15, 2018.

New policies and regulations can sometimes have unintended consequences. The Government's initiative to require municipalities to process applications in a timely fashion or be required to refund application fees has spawned an array of municipal strategies surrounding "complete applications" that have largely frustrated the intent of having applications dealt with in a timely fashion. We make this point and provide this example in the hope that the Government will insure that its efforts to provide 1.5 million homes over the next ten years is not frustrated or in fact defeated by competing and contrary policies and performance standards initiated at the local level.