Housing Matters recently made a deputation for the Planning & Growth Management Committee on the Townhouse and Low-Rise Apartment Guidelines which, if adopted, will be replacing the Infill Townhouse Guidelines.

These guidelines are of particular interest to us as they address the so-called Missing Middle, meaning those housing types that could introduce gentle density to our neighbourhoods but are not being built in large numbers (hence the “missing”).

We’ve just gotten video of the deputation, viewable below along with a copy of our speech.

Good afternoon.

My name is Chris Spoke and I am a member of Housing Matters.

We are a group of Torontonians who advocate for increased housing supply to address the housing availability and affordability crisis that is pricing many young people and middle class families out of the city.

We take very seriously the common sense notion that, if we want more people to have housing in Toronto, we’re going to need to build more housing.

Through land use rules that constrain supply, we’ve made it effectively impossible to build enough new housing to accommodate our rising population and new household formation.

This is why we have a 1.1% rental vacancy rate. It’s also why prices continue to rise so rapidly.

The Townhouse and Low-Rise Guidelines are of particular interest to us as they address the so-called Missing Middle, meaning those housing types that are ideal for introducing family-friendly, ground-oriented “gentle density” into our neighbourhoods.

It is from this perspective that we’ve reviewed these guidelines. We believe that though many of the items included may be desirable when applied judiciously to individual projects, when taken as a whole and blanketed across the whole city, they risk acting to further constrain the supply of these desperately needed housing types.

By their nature, urban infill sites are limited in their size and configuration, and require flexibility and efficient design to be viable development sites at all. Overly prescriptive design guidelines often act to prohibit the creative use of land, or to prevent what might otherwise be higher and better uses.

For example, the provisions to introduce breaks to townhouses every 36.0m, or outdoor amenity space for projects of 20 units or more, while no doubt easily defended individually on their merits, can render otherwise desirable projects uneconomic. When faced with a housing availability and affordability crisis, we must consider these possible consequences.

Each added provision shrinks the number of sites in Toronto that might be suitable for this type of development. Taken as a whole — and please note that this document is over twice as long as the 2003 Infill Townhouse Guidelines that it is replacing — these guidelines can act against the interests of viable intensification.

Under these new guidelines, Manhattan’s Upper West Side, Brooklyn’s Park Slope, London’s Kensington, and in fact, most beautiful and desirable low-rise neighbourhoods in major global cities would not be approved.

In the Background section of the Guidelines, a number of key issues are listed.

These include references to fit and transition to existing neighbourhoods, parks and open space, setbacks and generous facing distances, quality of design, and more. Importantly, these also include a directive to:

“Encourage affordable and transit-supportive housing developments with a range of building types and unit sizes appropriate for families.”

We believe that this point in particular should act as the primary objective of these guidelines. How do we maximize the potential of well-situated, underused land in our city to create homes for people?

Circling back to amenity spaces, although these are required per our zoning bylaws and are not introduced by the guidelines, we should acknowledge that these type of “nice-to-have” spaces can work against the provision of added housing in any development.

Valuable land dedicated to amenity spaces reduces the space available for homes, which increases cost per unit. They also introduce to residents new costs to maintain.

While shared outdoor spaces, including areas for pets and playgrounds for children, are absolutely central to the enjoyment and quality of life in an urban environment, these guidelines represent a missed opportunity to acknowledge that these spaces are often best provided more centrally and might not be necessary for every project of 20 units or more.

This is the type of flexibility and recognition of priorities that the Guidelines should provide to be used in complement with zoning bylaws.

Family-friendly does not necessarily mean one playground per ‘x’ number of townhomes, but it does mean being able to afford a home for your family at all.

Further to this point, one stated purpose of the guidelines is to establish a balance between the protection of stable residential neighbourhoods and heritage features while allowing for appropriate infill development and intensification.

This is one of the main conflicts that arises with planning in any city, and we believe that when a compromise must be made, the balance should be struck in favour of encouraging infill and intensification.

We should not continue to prioritize the concerns of established homeowners over those of renters and new homebuyers. We must look forward. We have an opportunity here to cement the priority of increasing availability and affordability of housing.

To that end, we request that you take our feedback into consideration when implementing these guidelines, when training staff on how to interpret and enforce them, and when evaluating development proposals and weighting the various tradeoffs involved.

Thank you.