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
A-1
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
Yes
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.
A-2
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
needed.
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
Yes.
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
Yes
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.
