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Zoning Reform Ideas

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Full (unofficial) set of recommendations from the Provincial Housing Task Force:


Damn. That is one comprehensive suite of changes. I would love to see this happen (but am not optimistic)

Oakville has already come out against:

It should be only six screenshots, I'm going to bring those forward for everyone. Good find!






Great recommendations. Really hoping Ford follows through with most of this. He would instantly get my full support.
Great recommendations. Really hoping Ford follows through with most of this. He would instantly get my full support.
As much as I would hope that this would happen - I doubt it :(

I think we’ll see the process/speed changes be proposed. People would get behind cutting red tape and speeding up permits. Those who go to deputations are…fairly low in number.

Unfortunately I don’t think there’s societal consensus on increasing the number of units per lot. I suspect that will get ignored and it’ll be on individual municipalities. I’ll go out on a limb and say we won’t see traction on that until 5-6 years from now.
Ok, time for me to offer comments on recommendations.

I'm just going to go line by line, in order from the report:

My comments are in Red. I'll do one section per post to keep the length sane.

Appendix A
Recommendations from the Draft Report of the Ontario
Housing Affordability Task Force (January 20, 2022)

1. Put Ontario’s housing need front and centre

a. Amend the Planning Act, Provincial Policy Statement, and Growth Plans to set
"growth in the housing supply" and "intensification within existing built-up areas"
of municipalities as the most important priorities in the mandate and purpose.

Shrug, changes nothing material.

2. Fix zoning that is strangling supply and reinforcing exclusion

a. Reduce exclusionary zoning in municipalities with populations over 100,000
through binding provincial action:

Sure, but how....

1) allow conversion of underutilized or redundant commercial properties to
residential or mixed residential and commercial use "as of right," which
means without requiring municipal approval

In a word: 'No'; simply put this would blow a hole through any effort to preserve employment lands at all; by allowing a developer/proponent to define redundant or under-utilized, both of which
can be self-inflicted.

Make some additional employment lands conversion easier, simply by admitting where its already happening and being pro-active, yes; but not as described above.

2) allow any type of residential housing up to four units and four storeys on a
single residential lot, subject to the provincial urban design guidance
proposed in recommendation [X]

Sure, but proposed this way it will get too much opposition, either apply this arterial roads only, or go to two storeys or 1 storey greater than the prevailing permissions, the greater of the two.
Not ideal, but it will pass.

3) enact Building Code and other policy changes to ensure meaningful
implementation (e.g., allow single-staircase construction for up to four
storeys, allow single egress, etc.)

Open to this, providing there are mandatory sprinklers, otherwise 2 exits is an essential safety feature in the event of a fire.

*note, we should be requiring sprinklers in all SFH construction, as has been done in Vancouver for years.

4) permit secondary suites, garden suites, and laneway houses province-wide

Yes, absolutely. I think this one stands a good chance of passing, low-hanging fruit.

5) use provincial tools to increase size, height, and density of all land along
major and minor arterials and transit corridors (including bus and streetcar)

Yes. This will get some pushback, but its a perfectly good idea and one totally worth a fight. I'd be content to compromise on as-of-right height permissions, for now
to get this through. Existing permission or four storeys, the greater of the two. (I'd support more, but that alone would do wonders, and crack-open lots of good sites.)

6) designate or rezone as mixed commercial and residential use all land along
transit corridors and all RA (Residential Apartment) to mixed commercial
and residential use in Toronto


7) encourage and incentivize municipalities to increase density in areas with
excess school capacity to benefit families with children

Fine, but amorphous, lacks actionable items.

8) Ensure municipalities use land for new communities efficiently and
effectively as they expand urban boundaries.

See above, too non-specific.

3. Align investments in roads and transit with growth

a. Pilot the use of the Community Planning and Permit System along the Ontario
Line, Hamilton LRT, and Highway 413 and provide funding to the affected
municipalities for internal and external resources, contingent on completion of
the work within 12 months

Shrug, needlessly convoluted, a variety of measures otherwise proposed or partially implemented (MTSAs, higher-as-of-right-zoning,
wider use of MCR zoning, and reduce red tape/fees/barriers for smaller applications would all be more useful) Also no to the 413, period, full-stop.

4. Give municipalities the right incentives

a. Develop a ($500 million/large) provincial housing accelerator fund to reward
municipalities that meet timeline, growth, and density targets.

No. Bureacratic nonsense. Invest the 500 pro-actively to unlock housing potential where investment in key infrastructure will make it possible. ie. New/expanded schools, parks libraries etc. One-time money, program is over and done in 5 years, (incentive to get the process started and done).

5. Start saying “yes in my backyard”

a. Create a more permissive land use, planning, and approvals system and
invalidate rules that seek to prevent growth or change, including to character,
in neighbourhoods

- exempt from site plan approval all projects of 10 units or less that conform
to the Official Plan and zoning by-laws

Maybe. I need to see what that would permit that is now not permitted. If we're just eliminating paperwork for its own sake, great.
But if there are rules enforced by the SPA process that would be by-passed, that needs discussion.

-establish province wide zoning standards for minimum lot sizes, maximum
building setbacks, minimum heights, angular planes, lot sizes, shadow
rules, front doors, building depth, landscaping and floor space index;

No. It doesn't make sense to have the same exact rules everywhere, communities are different from one another, the province should avoid micromanaging, and impose as

restore pre-2006 site plan exclusions (colour, texture, and type of materials,
window details, etc.) to the Planning Act,

No, we have enough trash design as it is; there is an argument for allowing more specificity on material quality, rather than mandating less.

and in cities over 50,000 reduce or
eliminate minimum parking requirements; and


b. Disallow public consultation on projects up to 10 units that comply with the
Official Plan and require only minor variances

- Modify, remove the public consultation in the form of a meeting/deputation, but preserve the opportunity for written submissions over a brief period.
Members of the public can sometimes offer excellent insights, the desire should not be to exclude those, but rather to avoid needless delay or creating a forum merely for venting.

c. Require municipalities to adhere to the maximum number of consultations set
out in legislation

This would presumably kill voluntary pre-application meetings in the community. Not sure that's wise. These
often provide a developer/proponent insight before a complete application is submission-ready, this can save money and time.

d. Require that all public consultations provide digital and accessible participation
options to include more people


e. Require mandatory delegation of site plan approvals and minor variances to
staff or pre-approved qualified third-party technical consultants and eliminate
Committees of Adjustment and local appeal bodies

Open to this, as the CoA process is certainly broken, and needlessly slow.

Due to Character limit this will be multiple posts.
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f. Prevent abuse of the heritage preservation and designation process by:

1) Prohibiting bulk listing for potential future heritage designations

Yes, I agree this process is suspect.

2) Prohibiting reactive heritage designations after a development application
has been filed

No. We have many buildings worthy of designation that as yet have no protection. While, ideally this would be addressed before any application is filed, that simply
isn't possible in this market.

3) Requiring municipalities to compensate property owners for the restrictions
placed on their ability to develop or sell their land as a result of heritage
designations, based on the principle of best economic use of land.

Absolutely not. I would favour a jail term for proposing the above idea. (only slight hyperbole)

g. Restore the right of developers to appeal Official Plans and Municipal
Comprehensive Reviews.

No. Developers have ample avenues to get approvals, and to appeal plans, and lobby on same; this just makes a mockery of the planning process if every private interest can hold anything and everything hostage to get their way.

6. Cut red tape and reduce costs

a. Legislate timelines at each stage of the provincial and municipal review
process, including site plan, minor variance, and provincial environmental
review, and deem an application approved if the response time is exceeded.
To deal with the possibility a municipality might issue a refusal simply to avoid the
timeline requirement, we recommend below that punitive sanctions for bad faith
apply at the Ontario Land Tribunal.

No. Unreasonably punitive and omits all the bad faith that occurs from many proponents/developers in the application process.

b. Require a pre-consultation with all relevant parties at which the municipality
sets out a binding list that defines clearly what constitutes a complete
application; confirms the number of consultations established in the previous
recommendations; and clarifies that if a member of a regulated profession such
as a professional engineer has stamped an application, the municipality has no
liability and no additional stamp is needed

Sure....I suppose..

c. Fund the creation of "approvals facilitators" with the authority to quickly resolve
conflicts among municipal and/or provincial authorities and ensure timelines
are met.

No, FFS not another bureaucratic process. The answer to 'red tape' is not more of the same.

d. Create a common, province-wide definition of plan of subdivision and standard
set of conditions which clarify which may be included; require the use of
standard province-wide legal agreements and, where feasible, plans of


e. Adopt the federal Building Code standard for wood frame construction up to 12


f. Require municipalities to provide the option of either pay on demand surety
bonds or letters of credit.


7. Fix the Ontario Land Tribunal

a. Allow project proponents defending an approved project to revise their
proposal and increase density, height, or size, up to the most permissive level
permitted by province or municipality before an appeal is heard at the Tribunal,
with the approval of the revised proposal becoming an option available to

Happens now

b. Where it is found that a municipality has refused an application simply to avoid
a deemed approval deadline, allow the Tribunal to award punitive damages.

No, one-sided, biased, heavy-handed.

c. Provide funding to increase staffing (adjudicators and case managers) by 50%,
provide market-competitive salaries and outsource more matters to mediators


where appropriate, and encourage the tribunal to set shorter time targets.
d. In clearing the existing backlog, require the Tribunal to prioritize projects
especially those close to the finish line, that will support growth in the housing
supply and intensification within existing built-up areas, as well as regional
water or utility infrastructure decisions that will unlock significant housing

No. In fairness, projects should be taken in the order in which appeals are filed. Anything else looks like playing favourites and brings the process into disrepute.

e. Prevent the abuse of process by third parties and municipalities:

1) Remove the right to appeal applications that conform to the Official Plan
and zoning.

Someone save me looking this up, what are the grounds of appeal if a proposal is compliant, now?

2) Require a $10,000 filing fee for third party appeals.

100% no. Will actively discriminate against low-income earners. Smaks of appeals only for the rich.

3) Provide discretion to adjudicators to award full costs to the successful party
in any appeal brought by a third party or by a municipality where its council
has overridden staff approval.

No to third parties, unreasonably punitive. Fair on municipalities where over-riding the advice of their own planners.

4) Encourage greater use of bench decisions, with written reasons to follow if
necessary, to resolve matters that seek to frustrate permitted development
and/or involve a straightforward matter.

No. It doesn't take long to write a simple, straight-forward decision. There is no need to expedite things by a few days or even weeks in a multi-year process where that may
bring allegations of favourtism or worse. Full decisions, in writing is a reasonable accord with good process.

At least one more post here due to character limits.
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8. Reduce fees, levies and charges to encourage more supply

a. Regarding cash in lieu of parkland, s.37, Community Benefit Charges, and
development charges:

1) Review reserve levels, collections and drawdowns annually to ensure funds
are being used in a timely fashion and for the intended purpose, and, where
review points to a significant concern, do not allow further collection until
the situation has been corrected

No, this punishes residents by saying they can't have more parkland if their government is slow spending the money. That puts the penalty
on a non-responsible party.

2) Except where allocated towards municipality-wide infrastructure projects,
require municipalities to spend funds in the neighbourhoods where they
were collected

Status quo.

b. Waive development charges and parkland cash-in-lieu and charge only modest
connection fees for all infill residential projects up to (10 units).


c. Waive development charges on all forms of affordable housing guaranteed to
be affordable for [50] years.


d. Prohibit interest on development charges beyond a municipality's borrowing

No. Interest should be calculated based on inflationary loss from time of assessment of charges to time they are paid.

e. Introduce a tax on developers for land where lots are fully serviced, building
permits that would add net new housing have been approved, and labour and
materials are available to undertake building, and construction has not
commenced within one year of these conditions being met

Sounds like a bureaucratic nightmare, and not clear that it would change much.

f. Work with municipalities to develop and implement a municipal services
corporation utility model for water and wastewater under which the municipal
corporation would borrow and amortize costs among customers instead of
using development charges.

No. If a development creates a cost for government by requiring expanded sewer/water capacity, the cost burden should on the developer
not on existing customers. Cost Externalization is bad.

g. Recommend that the federal government index the HST rebate on purpose-
built rental properties to present values and going forward.


h. Recommend that the federal government match the provincial rebate on new
home construction.

No. If there is no linkage to affordability then the rebate is a problem not a solution.

i. Rebate MPAC market rate property tax assessment on below-market
affordable homes.


j. Recommend that the federal government index the HST rebate on purpose-
built rental properties to present values and going forward.

Umm, this is the same as g above, report-writers should proof-read.
Last one, I swear! LOL

9. Create the Labour Force to meet the housing supply need

a. Advocate that the federal government adjust the immigration points system to
strongly favour needed trades and expedite immigration status for these

Sure; though its up to the province to make sure they are credentialed to work once they get here.

b. Increase from 9,000 to 20,000 the number of immigrants admitted under the
Ontario Immigrant Nominee Program, with the vast majority of those permitted
under foreign work and in-demand skills categories, and remove barriers to
recruitment within the Ontario Immigration Nominee Program.

So long as you remove 11,000 immigrants in other less desired categories. Otherwise you're adding up demand for 11,000 more households each year, when we're already falling

c. Improve funding for colleges, trade schools, and apprenticeships, encourage
unions and employers to provide more on-the-job training, and provide
incentives for municipalities to enhance apprentice opportunities on their
projects, with a focus on such traditionally underrepresented groups as women
and Indigenous people.
d. Undertake multi-stakeholder education program to promote skilled trades.


10. Allow new paths to ownership

a. Amend the Planning Act and Perpetuities Act to extend the maximum period
for land leases

b. Permit multi-tenant housing (renting rooms within a dwelling) province-wide

By all means.

11. Other (Data / Monitoring)

a. Resume reporting on housing data and use municipal reports required by the
Provincial Policy Statement, enforcing compliance through eligibility for
provincial funding.

No, needlessly bureaucratic, adds a reporting structure where action would suffice.

b. Report each year at the municipal and provincial level on any gap between
demand and supply and make underlying data freely available to the public.

Already known.

c. Require municipalities to use the Ministry of Finance population projections as
the basis for planning.

Since these are consistently wrong, that would seem to be a bad idea. Maybe get the projections right first.

d. Fund the development of a common data architecture standard, supported by
an external PropTech committee, across municipalities and provincial

WTF does that mean?

e. Require municipalities to provide their zoning laws with open data using GIS


f. Provide ($X million) (matched with Federal Accelerator) to municipalities to
adopt a proven off-the-shelf e-permitting system, and make provincial funding
for infrastructure contingent on adoption no later than 2026.

Just go with (2.2) "allow any type of residential housing up to four units and four storeys on a single residential lot, subject to the provincial urban design guidance proposed in recommendation [X]".

Not sure about Northern Light's concern about it passing or not? Who has to pass it? If the province says so, I think it's a done deal - No?
Just go with (2.2) "allow any type of residential housing up to four units and four storeys on a single residential lot, subject to the provincial urban design guidance proposed in recommendation [X]".

Not sure about Northern Light's concern about it passing or not? Who has to pass it? If the province says so, I think it's a done deal - No?

I don't think the province is likely to pass that by legislation or regulation; that it would garner too much opposition.

I could be wrong; but we've seen Provincial governments reluctant to move in this type of way for a long time.

That's why I suggested going with something similar, but lesser in height in the interiors of neighbourhoods (unless the prevailing height/permission was 3 storeys in which case 4 would come into effect in my proposal).

The object to me is advancable actions, which are unlikely to be rolled back.

One of those don't let perfection become the enemy of the good things.
Just go with (2.2) "allow any type of residential housing up to four units and four storeys on a single residential lot, subject to the provincial urban design guidance proposed in recommendation [X]".

Not sure about Northern Light's concern about it passing or not? Who has to pass it? If the province says so, I think it's a done deal - No?

There are a lot of other ideas, some good some bad, but I agree that this is the heart of it and the most pressing piece to have done.