Below are texts (for brevity I’ve omitted names of commenters; and for ease of online reading, I’ve added paragraph breaks) of additional submissions (which include some relevant photos, in Submissions 22 & 23):
The Thompson Orchard Community Association Inc. (“TOCA”) represents just over 400 households in the area between Mimico Creek on the west, Bloor Street on the north and Royal York Road to the east. A portion of the area TOCA represents lies within the flood zone of Mimico Creek. Our residents have experienced catastrophic flooding.
We have considered the 13 proposed changes to the rules implemented two years ago regarding laneway suites. The first point we wish to make is that the Notice of Meeting was not accompanied by the proposed zoning changes so the Notice is deficient.
Official Plan section 5.5.1 emphasizes the importance of a fair, open and accessible public process for amending by-laws and section 5.5.1 [c] iv stipulates that such amendments should be available for review at least 10 days prior to the statutory public meeting. This has not been done.
As a result, residents’ groups are not being given sufficient time to respond to the proposed changes. This is not appropriate and it is unnecessary. The matter should be adjourned for at least one month to allow proper notice.
Preferably the matter should be adjourned for longer than that to allow for consultation with residents’ groups, as it appears their views have been largely ignored in the drafting of the proposed changes (please see the comments under Gladki Report below).
If you choose not to adjourn this matter to allow the required notice period, for the reasons set out below, TOCA believes the proposed amendments should not be approved in their present form. The proposed amendments we are most concerned with, and the only ones we can deal with in the limited time we have had to review the proposed changes, are:
(i) the proposed amendment increasing the maximum permitted height of a laneway suite from 6.0 metres to 6.3 metres; and
(ii) the proposed amendments that reduce the amount of softscaping required.
Prior to discussing TOCA’s specific objections, TOCA wishes to make two general comments about the Gladki Report. First, many of the recommendations made are not explained. It appears that all the authors of the report have done is (i) look at what the most common request for variances were, and (ii) talk to six industry professionals.
The authors did not speak to residents’ groups and did very little – if anything – to determine the effect of their changes on neighbouring properties or the character of the neighbourhoods in which laneway suites will be built.
From reading the report it is clear that much of the reasoning behind the recommendations is simply based on the fact that a very, very small percentage of laneway suite applications sought a specific change. For instance, the report recommends that the height of laneway suites be increased from 6.0 metres to 6.75 metres based on 1 (one!) application for a variance.
When you look at the statistics cited in the Gladki report regarding building permit applications for laneway suites and the number of applications for variances, a strong case can be made that no zoning amendments are necessary. The vast majority of laneway suites did not require a variance so why is it necessary to change the zoning?
The second comment TOCA wishes to make comes from the preceding paragraph. The only people that appear to want these zoning changes are industry professionals. While their views are important, their views alone should not determine zoning changes, particularly when there is very little evidence that the zoning changes are required.
On page 29 of the Gladki Report it says:
A total of 10 applications sought variances to the height provisions of the zoning By-law. A total of 7 of the 10 applications were approved. Six of the 7 variances sought relief from the 4.0m height requirement and all proposed building heights less than 6m. The single variance to the 6.0m height requirement identified in our data sought a total laneway suite height of 6.96 m.
Thus, in the 2 years since laneway suites have been permitted, there has been only 1 (one) request for a height increase. Accordingly, there appears to be absolutely no reason to amend the bylaw to increase the height permitted to 6.3 metres, particularly when the Gladki report does not contain any discussion on the effect of such an increase on neighbouring properties or shadowing in the adjacent laneway. Hundreds of laneway suites have been successfully built without any need for a height increase.
TOCA believes that the proposed amendment increasing the maximum permitted height of a suite from 6.0 metres to 6.3 metres should be deleted/removed. It is clear from the Gladki report that there is no justification for it.
Section 5 of the proposed amendments propose several changes to soft landscaping requirements for laneway suites, all of which have the effect of reducing the soft landscaping. Other residents’ organizations have written to object to some of the inexplicable aspects of these proposed changes and TOCA supports their analysis.
More particularly, it is not clear why a pedestrian walkway has to be as large as 1.5 metres or why the walkway is not part of the 15% hardscaping allocation for the rear yard.
However, the main objection that TOCA has to these changes is that there has been no analysis at all on the effect of the proposed changes on stormwater management, tree canopy, heat islands, climate change or the appearance of the laneway itself.
Perhaps some of the proposed changes can be justified once an analysis of their effect has been done but the changes should not be implemented before such an analysis is done. On this issue, the Gladki Report and the proposed changes both seem to ignore the portions of the Official Plan and the Provincial Policy framework that stress the importance of sustainable development.
20. Confederation of Resident and Ratepayers Associations in Toronto
Re: Amendments to 569-2013 Governing Laneway Suites The Gladki Report and Changing Lanes Report
This letter is in furtherance of CORRA’s letter of the 16 November, 2021. In that letter CORRA reserved its right to comment on the draft by-laws given they had not been provided at least 10 days before the Statutory Public Meeting.
This letter will focus on the key amendments and should be read in conjunction with the earlier letter.
2. Amendment to 22.214.171.124(1)(E). This presumes that the residential building will be built in accordance with permits. This is a fallacious assumption. Often builders will get a permit and then go for variances to the Committee of Adjustment or simply not build in accordance with plans. The assumption may be that the foundations will exist, but this provision does not require that.
Clearly if the ancillary building is built before the residential building, then the foundations should exist. The proposed amendment is silent on that point. It needs to be cured. Additionally you may wish to make requirements that a residential building be set back from a laneway suite.
5. Amendment to 126.96.36.199(1) (B). While 1.5 is an improvement over 2.1 it still not appropriate. One of the problems faced by lots between 9 m and 6 m has been the tendency to pave over them. Given 15% of the area is exempted from soft landscaping, it is not desirable or appropriate to exempt a walkway. in addition to the 15%. Especially given CORRA’s prior comments concerning access from the street. Several groups will discuss the problem with flooding.
Amendment to 188.8.131.52(1) (C). Given there is a driveway, CORRA does not understand why once again , why the walkway cannot be accommodated within the 25% that is not landscaping. Any pathway can be from the driveway to the door of the laneway suite.
6. Amending 184.108.40.206(2)(B) by reducing the setback from 1.5 to 1 m given how narrow lanes can be is reducing the buffer between users of the laneway suite and vehicles using that laneway. For this reason it is undesirable.
7. Amending 220.127.116.11(3) (C). It should be noted that 1.5 m is a minimal separation to adjacent lots, this reduction is not warranted except to shoehorn development onto a lot.
8. Amending 18.104.22.168(3)(C). CORRA does not support these changes.
13. Amending 22.214.171.124(1)(B). There was insufficient evidence to support this change in the prior reports and when combined with the increase of mechanical equipment by 0.5 of a metre is unacceptable.
17. Amending 126.96.36.199(5). CORRA does not support increasing the height from 1 m to 1.5 of these elements.
Given there are also amendments coming forward for garden suites, it is CORRA’s position it is premature to deal with these amendments separate from the garden suites.
CORRA repeats its request that this matter be adjourned for proper notice and further review of the impacts and a consideration of ensuring that green space, tree canopy, drainage and impacts on adjacent properties are fully addressed.
21. Cliffcrest Scarborough Village SW Residents Association
Toronto Planning and Housing Committee – PH 29 Proposed Laneway Suites Zoning By-law Amendments
Cliffcrest Scarborough Village SW Resident Association, CSVSWRA, is a south east suburban community within Ward 20. Our members have participated in the Laneway Suites Monitoring and Evaluation reviews. This letter expresses our opposition to three of the proposed by-law amendments for Laneway Suites:
Re: The proposed amendment “Increasing the maximum permitted height of a suite from 6.0 metres to 6.3 metres” should be deleted/removed.
Accommodations for improving the ‘heat envelope’ can be effectively addressed with the use of a higher R-value foam insulation, an insulated concrete floor assembly and other height saving measures.
NO INCREASE to the height is required to improve the heat envelope. Higher ceiling heights should not be considered as valid criteria. Increasing the height will negatively impact the privacy of existing adjacent neighbours.
Additionally there is the concern of damaging the overarching tree branches and roots of mature trees, a valid environmental issue. Our endangered mature canopy contributes to maintaining a sustainable environment by providing shade, reducing thermal temperatures, reducing air pollution, absorbing excess precipitation, reducing runoff and sequestering carbon dioxide. The maximum height should be maintained at 6.0 metres.
The proposed amendment calls for “Exempting a walkway from the minimum required percentage of soft landscaping space between a suite and house where a lot exceeds a width of 6.0 metres.”
The City Staff proposal proposes that the total square metres for a walkway would be subtracted from the soft landscaping minimum required percentage; and the 15% hardscaping allocation of the yard would not be used for the walkway. Why?
No dimensions have been given for this walkway. Depending on the size of the walkway chosen, this has the potential of increasing the hardscaping allocation to 30% or more and decreasing the soft landscaping area to 70% or less.
Considering that COP26 has confirmed the global necessity of reducing our GHGs, municipalities can effectively and cooperatively address the issue by maximizing permeable ground surfaces, not reduce them, particularly in the urban cores which are heat sinks.
Rear Yard Setback:
The proposed amendment for reducing the Rear Yard Setback to 1 metre from 1.5 metres reduces the soft landscaping requirement at the rear of the suite. The resulting area could be added to the area between the house and the suite, which is another reason not to reduce the 85% soft landscaping by-law provision.
The proposed amendment for an exemption for a walkway against the 85% soft landscaping allocation should be deleted/removed.
We urge City Planning and the Planning and Housing Committee to NOT allow changes to the current provisions controlling Height of laneway suites and to NOT allow any changes that will reduce the current soft landscaping allocation of 85% to protect the neighbours and the environment.
Our Toronto municipality needs to respond to the environmental crisis of global warming by not only preserving but increasing our permeable ground areas and green spaces and by also protecting our MATURE TREE canopy
22. Swansea Area Ratepayers Association and Group
Ref: PH29.2 – Agenda Item Nov. 25 – Changing Lanes: The City of Toronto’s Review of Laneway Suites – Zoning By-law Amendments – Final Report
As an active Ratepayer Association working to support the Swansea Community, it has always been our hope that good planning would be the driving force behind any City of Toronto housing initiative. Expanding housing options can have a positive effect on Neighbourhoods if done in a manner which enhances the quality of life and character of the neighbourhood community.
With the push and rush to roll out the projects of the Expanding Housing Options in Neighbourhoods document, neighbourhoods feel overwhelmed rather than excited by the arrival of such initiatives as Laneway Suites (Houses?)
Further to this belief, we are writing to express our agreement with all of the concerns raised by CORRA in its letter to the Committee dated November l6, 2021. We have listed our issues and expanded the writing to question the issues, outcomes and potential consequences of the roll out of this initiative as identified in the CORRA letter as follows:
1. This meeting should be adjourned for at least another month as the Notice of Meeting did not contain the copy of the Draft Zoning By-Laws and as such the notice was not in compliance with Official Plan policies.
2. The height at 6m is almost the amount allocated to a regular house. The extra 0.3m should not be given to accommodate design features or under any other pretext.
3. The descriptor Soft Landscape should be changed to Green Landscape to respect the intention and the integrity of the tree canopy, environment, storm sewage systems and storm water drainage and run-off.
4. The Green Space must be maintained at 85%. Do not allow an extra 15% reduction for a walkway as this amount can be accommodated within the existing allowance for hard landscape.
5. Whichever is built first or last there should be an amendment to maintain the green landscape at 85% between the main residence and the supposed ancillary laneway suite.
6. What are the plans for City Council to expand the infrastructure budget to build new sewage and drainage systems for the overwhelmed neighbourhoods in this rush to over develop?
7. How prepared is the City of Toronto for the tragedy of the Climate Change driven rain storms and floods in Vancouver and New Jersey? Why don’t we prevent rather than having to prepare for these tragedies by protecting our tree canopy, the topography of each location for drainage and runoff and allowing the environment to take its natural course in protecting our ecosystems within the framework of these initiatives.
In conclusion, we repeat our request to defer this issue for at least another month to allow our communities the statutory amount to consult with you further to ensure that good planning and the community impacts are part of the discussion process.
Photo source: Swansea Area Ratepayers Association and Group
Lastly, you will see from this photo which we have provided that there is still time to learn from the over-development of this site. We neglect the advance of climate change and support for the green environment at our peril.
Many thanks for taking the time to read our letter and hopefully to address our issues.
23. ABC Residents Association, FoNTRA Working Group
Photo source: ABC Residents Association, FoNTRA Working Group
Laneway Suite Backyards: What is Happening? Is this OK? 435 Grace St: Suite Monthly Rent is $5,500.
New Neighbourhood Housing Options … must protect the environment!
• Amend Recommendation #4 to require staff report sooner than 2023.
• No reductions of soft landscaping standards until staff report is reviewed by PHC.
• City staff to inspect ALL built suites and report by Q1 2022 on the rear yard percentage of green growing space and tree canopy.
• Train CofA Members to consider climate change impact in their decisions.
• Add a condition requiring a canopy tree to be retained or planted on every Laneway Suite lot.
24. Bayview-Sheppard Neighbourhood Alliance
Re PH29.2 Changing Lanes: The City of Toronto’s Review of Laneway Suites – Monitoring Program and Zoning By-law Amendments – Final Report
Today the design skills, technology and products exist to prevent surface run-off from City lots. The need for Cities to incorporate run off prevention in their bylaws is strikingly obvious from increasing flood events around the world.
We are supportive of the Suites objective of maintaining most of the rear yard as open space and contiguous soft landscaping that is supportive of tree planting. However, we also ask that:
1. Allowing new residences in back yards should be accompanied by preventing surface run-off from any building hard surfaces or hard landscaping additions to a lot.
2. As permeable products and materials already exist for walkways, the proposed amendment for a soft landscaping exemption for a walkway against the 85% soft landscaping allocation should be deleted, irrespective of the lot width.
• To reduce the number of appeals to the Committee of Adjustment developers should be allowed to
exempt the walkway if they utilize permeable walkway materials or can present design approaches for approval that prevent run-off from the walkway surface.
3. We understand that City Planning Teams are recommending that various City departments report to the PHC in the first quarter of 2023 regarding potential strategies to protect and enhance the City’s tree canopy and growing space, while also supporting infill housing growth in the City’s Neighbourhoods.
• We ask that no reductions be made to soft landscaping standards until that report has been considered
by City Council and that public consultations be held on drafts of that report in 2022.
4. It is expected that some developers will play off the soft landscaping requirements for Laneway Suites against those for Garden Suites, or vice-versa. The arguments will likely be that any less strict portion of the standard should also be applied to the other type of Suite.
• In that regard whatever standards are applied to either type of Suite they should be tightly worded and
highly enforceable on their own merits.
5. Lastly, any new Zoning standards on Suites should be reviewed by the City within three years of implementation against City expectations and the experience of applications received and reviewed and/or granted.
Thank you for the opportunity to comment on these proposed amendments.
25. Palmerston Area Residents’ Association, Green Committee
The Palmerston Area Residents’ Association, PARA, represents the residents residing between Bathurst and Grace Streets, and College and Bloor Streets. Our neighbourhood is directly impacted by the Laneway Suites By-law as there are numerous laneways in our area and laneway suites, with many more in the planning stages.
We support laneway suites as one means of providing more housing within our neighbourhood.
However, we are writing to record our opposition to several proposed changes in the by-law that would reduce the required amount of softscaping on the property and increase the allowed height of the suites.
PARA’s Green Plan 2020 emphasizes that softscaping is a critical component in the mitigation of the effects of climate change. Softscaping is critical in storm water management as water from heavy rains (which are increasing in severity and frequency), needs to go somewhere – better to be absorbed by the soil than to go into our basements, including the many basement apartments in our
neighbourhood. Stormwater should nourish our gardens, not run off into our lakes creating higher levels of pollution in our source of drinking water.
Many of our backyards are already small. Reducing the softscaping component limits the areas for planting trees, essential for helping to absorb rainwater runoff and, just as important, for cooling the urban environment during our increasingly hot and lengthy summers.
We are strongly opposed to the increase in permitted hardscaping. Any increase in hardscaping contributes to the Urban Heat Island Effect, making heat waves more extreme. Heat waves have profound negative impacts on people’s health, as the heat dome in British Columbia where hundreds of people died this last summer illustrates. Given the increase in intensity and duration of summer heat waves, softscaping helps to decrease the negative impacts of our rising temperatures.
We are also opposed to any increase in height for the laneway suites. Extra height increases shadows, often on neighbouring properties. In small backyards, this impacts available sunshine which is so important for maintaining green space.
PARA’s Green Plan was approved by City Council, the same council that unanimously declared Toronto to be in a state of climate emergency in 2019. Part of the Climate Emergency declaration is a: “…commitment to protecting… our ecosystems and our community from climate change.” (Taken from the City of Toronto website)
The City has also developed a Resilience Strategy. One of its goals states: “Toronto is more resilient to climate change, including the hazards of flooding and heat.” It includes: “Take action to mitigate the effects of extreme heat. Communicate, synthesize and scale up ongoing City efforts to advance a system of green and blue infrastructure.”
Now, with the proposed laneway suites by-law amendments, the Council is being asked to relieve developers of some of their responsibility for that same green infrastructure that the City deems central to building climate resilience.
The Planning Department has stated that the purpose of increasing the hardscaping allowance is to reduce Committee of Adjustment applications. However, developers have often used a by-law as a basis to ask for more. Council needs to draw a line on softscaping requirements for laneway housing.
Yes, climate change is on our doorstep. It is imperative that the City look at all its actions through a climate change mitigation lens. Given the importance of softscaping, we find it nonsensical that any City by-law would allow for the wholesale reduction of softscaping. Rather than change the by-law, it’s time to educate people about the importance of softscaping. Housing is important, but if we don’t have a livable environment, all of us will suffer.
26. Long Branch Neighbourhood Association
RE: PHC 29.2 Changing Lanes: The City of Toronto’s Review of Laneway Suites – Monitoring Program and Zoning By-law Amendments
We can appreciate that preparations must occur to accommodate the large increase in population expected in the City of Toronto over the next several decades. However, we do not believe that the Recommended Zoning By-law changes will be beneficial for those same new residents nor the existing ones.
The report included with this proposal mentions the declaration of a climate emergency being voted in by City Council in Oct 2019. The Zoning By-law changes being proposed for Laneway Suites are going in exactly the opposite direction required to accomplish better climate stewardship in neighbourhoods in the City of Toronto.
We urge this Committee to send these Zoning By-law recommendations back for further consideration due to the negative impact they will have on soft landscaping, removing trees and creating an unfavourable environment for planting new trees, wildlife, birds and pollinators and achieving the goals of the Toronto Biodiversity Strategy, 2019 for our city.
“Biodiversity is essential for the health and well-being of all beings. These relationships are interdependent and reciprocal. Let’s protect and support the biodiversity of this place by building or by deepening one’s own relationship with the land” – quote by Carolynne Crawley, in the Forward, Toronto Biodiversity Strategy 2019.
According to the 2018 Tree Canopy Study, from 2008 – 2018, Toronto lost permeable surfaces at pan astonishing rate – the equivalent of 1,670 football fields – resulting in a decrease of available growing space for future tree canopy expansion. The most area converted to impervious land cover was in the Single-FAmily Residential land use areas. These proposed Zoning By-laws will do nothing to halt their loss of growing space but rather will exponentially accelerate the loss.
In particular, the concern we have are as follows:
Rear Yard Setbacks – Reducing the rear yard setback to 1.0m from 1.5m.
Side Yard Setbacks – Reducing the side yard setbacks from 1.5 to 1.o. We would strongly recommend increasing the side yard setbacks to allow space to plant trees in between laneway houses. 2m is severely undersized for this purpose.
Landscaping Requirements – Reduction in the soft landscaping requirements between the home and the Laneway Suite. In addition to the threat to trees mentioned earlier this will further reduce the amount of “green” in the yard. Trees and vegetation are important factors in battling climate change. Do not reduce the 85%soft landscaping in the yard. A sidewalk of no more than 1 metre wide made with permeable materials should be sufficient between then home and the Laneway house.
Maximum Height – We have concerns about the recommendation that building height be allowed to increase past 6 metres. And then allow yet additional height for structures on the roof by another 1.5m. The reason given for this increase in height is to allow for better insulation for the building.
While increased insulation is a good idea, certainly this increase in R-Value can be accommodated without increasing the height of the building. As the height increases, the more the negative impacts on neighbouring properties in terms of loss of privacy and light.
Floor area and size of the Laneway house – The Laneway house should be limited in size so that it does not become a “second house” in the backyard. There is nothing in the Zoning by-laws that pertain to a true “suite” size. Rather this allows a house virtually the same size as the main residential building on a lot. And does not count the second house towards the gross floor space.
It was referenced in the report that the criteria for Laneway Suites will influence that of Garden Suites. We would hope that very careful attention be paid to loss of Green Space when building either of these structures. The Garden Suite, being a possible “new build” as a separate building has even greater possibility of threatening trees and resulting in even more loss of plantable space.
Recommendation 4 from City Planning to this Committee lacks any reassurance that action will be taken to protect and enhance the City’s tree canopy and growing space and a deadline of a report to the Planning and Housing Committee in the first quarter of 2023 regarding potential strategies is far, far too little too late.
The Tree Canopy Report was done in 2018. That these potential strategies would then be coming 5 years later we hope would be unacceptable to this Committee.
According to the 2018 Tree Canopy Report, Long Branch is the hardest hit Neighbourhood for Tree Canopy Loss in all of Etobicoke-York and the 8th hardest hit Neighbourhood in all of the City. Our tree canopy was at 26.5% when the City set the goal to grow the City’s tree canopy coverage to 40%. Long Branch’s tree canopy, during this period of planned tree canopy growth, has declined to now only 15%.
Stronger tree protection is desperately needed now, before changes are made to building and intensification in areas where trees exist now, such as where Laneway Suites are planned.
Long Branch has experienced the greatest Tree Canopy loss (-43.4%) in all of Ward 3 and all of Etobicoke according to the 2018 Tree Canopy Study conducted by the City of Toronto.
* Source: City of Toronto 2018 Tree Canopy Study; KBM Resources Group Lallemand Inc/BioForest Dillon Consulting Ltd; Duinker, P. and Steenberg, J. Dalhousie University, Appendix 1: Canopy Change by Neighbourhood 2009-2018: 253.
The LBNA recognizes that intensification is necessary for the City of Toronto as the population grows larger. However, we hope that where this additional housing is being planned considers also providing additional infrastructure for neighbourhoods. All these new people will need schools, roads, improved transit, recreation facilities, etc. And also, more green infrastructure and trees.