Toronto’s draft plan for legalizing multiplexes is out. On the surface, it’s what More Neighbours has been asking for: permit four storeys and four units as-of-right on residential properties city-wide. In the details, however, it’s a little more complicated. This is incremental change with room for improvement, but to truly permit multiplexes city-wide, it will not be enough to just legalize them in name.Our recommendations and asks from city planning revolve around making multiplexes feasible to build across the city.
Here are some of the things worth thinking about when you give feedback through the City’s survey or attend one of the public consultations (Feb 21 from 2-4 pm, or Feb 23 from 6-8 pm). A more detailed explanation follows the summary.
- City Planning is proposing a 10 metre maximum height, unless higher is indicated on the zoning map. This would be an effective limit of three storeys. MNTO ask: permit a height of minimum 12-13 metres for multiplexes to support four storeys citywide.
- Basic box shapes would not be allowed in some zones at the maximum height because there is a step back or sloped roof requirement, which reduces usable space and is inefficient. MNTO ask: eliminate the step back requirement for multiplexes.
- The proposed zoning by-law adjusts the allowed building depth and setbacks from the lot lines to match those for detached homes. Previously, multiplexes were required to be smaller where they were allowed. MNTO ask: allow building depth up to 19 m for multiplexes in all zones.
- The floor space index (FSI) used to regulate density remains in place in this draft, with different limits across the city. With FSI limits, multiplexes will continue to be unfeasible to build on much of the city's land. More Neighbours would like to see the city move towards a simpler, form-based definition of density, based on building height, length, lot coverage, etc. MNTO ask (e.g. at the end of the survey): remove FSI requirements in favour of form-based zoning. At the very least, allow minimum 2.0 FSI for multiplexes city-wide.
Why do multiplexes matter?
Toronto has concentrated most of its growth into a small area of the city. Two-thirds of Toronto’s residential land allows one single detached house on each lot, a policy that was intended to provide stability. But change is inevitable: as children grew up and moved out, as parents aged without good options for smaller homes in their communities, the population of many of these Neighbourhoods shrank. Meanwhile, everyone else had to compete for homes in the small share of land where growth is allowed.
This exclusionary zoning has a terrible history, rooted in racism, classism, and misogyny. To this day, exclusionary outcomes continue to be reflected in demographic trends. These restricted yellow land use areas are wealthier, contain fewer immigrants, fewer renters, have more trees and park access, the list goes on. However, areas of Toronto that are still low-rise but allow multiplexes and small apartments have less inequality.
They also provide new housing opportunities for young families, commuters who have been priced out or those looking to downsize. After Auckland made changes to allow low-rise multi-unit housing in 2016, they doubled the number of homes completed per year and recent rent changes are below inflation. This doubling is what Ontario’s Housing Affordability Task Force set as a target. A City of Toronto report suggested that, if the densities of the restrictive Residential Detached (RD) and Residential Semi-detached (RS) zones were similar to the RM zones where multiplexes are allowed, they could house an additional 572,000 people, but the true number would be heavily dependent on the policy options chosen and financial viability.
Great. So we’re getting multiplexes?
If Council passes this, yes, but maybe not as many as we had hoped. What is proposed technically allows fourplexes on any residential lot in Toronto, but whether anyone could build a liveable one at a reasonable cost is a different matter. This is partly because of limitations that Council placed on the project from the start, so pressure could result in amendments from the new Council.
You may recall that Ontario moved to permit triplexes on residential lots as part of Bill 23, but they did not change any zoning, meaning that the size and other limitations on a triplex would be the same as for detached homes. The Ontario government’s own internal estimates suggested that these limitations would only result in about 50,000 new homes across the province. The Toronto rule changes follow a similar pattern, trying to make multiplexes look as much like detached homes as possible, potentially limiting where they can be built in practice. Here are some examples.
In the Official Plan, low-rise Neighbourhoods can be up to four storeys. The zoning removes other limitations on the number of storeys, which is good news, but then it places a height limit of ten metres anywhere that doesn’t have a higher value on the existing height overlay map. This is an effective limit of three storeys in those areas. A limit of 12-13 metres would truly allow the four storeys across the city that More Neighbours has been pushing for in its campaign to end exclusionary zoning.
In addition, several zones have separate requirements for main walls: in classic Toronto fashion, you cannot build a simple box shape, but must have step backs on some walls or a sloped roof. It isn’t clear why this limitation exists for low-rise buildings, other than it was an existing requirement for detached houses that has now been transferred to multiplexes. Flat walls tend to be simpler and cheaper for construction, as well as allowing more space for residents and reducing the areas for heat loss, which has environmental benefits.
When you take the City’s survey, you will see specific opportunities to weigh in on both of these changes. Make sure to ask for a minimum height limit of at least 12 metres and no step backs for multiplexes.
Building size and setbacks
A longstanding beef for those who spend too much time with Toronto zoning is that the R and RM zones allowed multiplexes, but required that the building be smaller than detached houses and set back further from the lot lines. This has finally been equalized and the newly allowed multiplexes in the RD, RS and RT zones followed suit. Under the proposal, you could build a multiplex that is as big as a detached home, but no bigger.
There is an opportunity to comment on building depth for multiplexes in the R zone, extending it from the new 17 m up to 19m, which would be the same as in RD and RS zones. In addition, the shorter 14 m building length and larger setbacks for low-rise apartments in the R zone remain untouched. Strictly speaking, these apartments are not “multiplexes” but it would be great to see these inconsistencies addressed without another two years of consultation.
Floor Space Index
Once you’ve defined the size, setbacks and height of a building, you might think that you know how big it can be. However, in many areas of Toronto, the zoning places an additional constraint on the building size called floor space index (FSI). If you want the details, you can read this explainer, but the main point is that it is unnecessary when you have defined the building’s form with other measurements.
In addition, the FSI is very low in some areas of the city, like Etobicoke, and doesn’t even exist in others, like most of Scarborough and North York. Keeping this limit will make multiplexes much more difficult to build in some areas and perpetuate inequality in Toronto.
City Planning has talked at several points about getting rid of FSI, including for the EHON program and in some low-rise areas of the midtown secondary plan. I’m not quite sure why it didn’t make this draft, but now seems like a great time to ask. When you take the survey, make sure to include in your comments at the end that you support removing FSI as a requirement for multiplexes or, at the very minimum, permit at least 2.0 FSI for multiplexes city-wide.
The basis of the Official Plan Amendment is a Site and Area Specific Policy that copies a different section of the Official Plan and adjusts it to remove a reference to “prevailing building types” and then says it overrides the section that it copied. In addition, references to “prevailing size” and “prevailing setbacks'' were kept, even though size and setbacks are defined by the zoning, as noted above. Rules about a building’s external appearance can be used to conceal concerns about who might live inside; built form rules then become a way to continue exclusionary policies.
Then there are references to tree protection and larger units that duplicate policies in the existing tree by-laws or could have been added to the Growing Up guidelines. On the surface, this sort of redundancy might just seem unnecessary and confusing. However, putting things into the Official Plan means that exceptions require an Official Plan Amendment, which is often a long and expensive process. Large highrise developers struggle to endure the uncertainty and delays added by the Official Plan Amendment process; a small, non-profit developer or the Etobicoke grandmother trying to convert her home to a multi-generational duplex stands little chance, particularly given the recent report that projects with fewer units aren’t approved any faster.
It isn’t clear what the implication of making suggestions rather than requirements in the Official Plan is or why Neighbourhoods are getting this treatment and non-Neighbourhoods are not. As-of-right should mean as-of-right. Adding existing citywide policies into the Official Plan - but only for Neighbourhoods - is once again privileging them and perpetuating exclusionary policies. It will be important to ask about the intentions of this approach and any unintended consequences in the consultation process.
It’s still good news
This is still a change worth supporting. It goes beyond what the provincial government did and makes greater strides in reducing exclusion in Toronto’s Neighbourhoods. There is thoughtful work accounting for common areas in gross floor area, allowing balconies and porches for each unit, and proposing to reverse the unfortunate policy that Council passed for secondary suites that prevented renters from having their own entrance at the front of their home. But it could be so much more. The housing crisis is now.
How you can help
- Fill out the survey. It is quite detailed, but it walks you through each of the proposed changes, including those described above, and gives you a chance to comment.
- Attend a public consultation. Virtually on February 21st from 2-4 pm or February 23rd from 6-8 pm.
- If you can’t attend the consultation or think of comments after submitting the survey, you can write to EHON@toronto.ca with feedback until March 10, 2023.
- We will have more to say when the final draft comes to Planning and Housing Committee later this year.