Editorial: Why the Rush?

The slowness of the approvals process has been pegged as a key villain in the goal to increase the supply of housing in Ontario. But the truth is more complicated.

In recent years, the province has seen a flurry of bills in support of a provincial ten-year target to build 1.5 million homes. In October 2022, there was the More Homes Built Faster Act (Bill 23) and the More Homes for Everyone Act (Bill 109). Now, 2024 has seen the introduction of the Cutting Red Tape to Build More Homes Act (Bill 185).

A key theme in these Acts is the streamlining—and quickening—of approvals. Bill 23 removed the public meeting requirement for plans of subdivision, exempted developments of up to 10 units from site plan control, prevented third-party appeals on minor variance applications, removed the ability of municipal staff to require changes in exterior materials, and limited the role of conservation and heritage authorities.

Next, Bill 109 required site plan approvals to be completed by municipalities in 60 days, and to review projects requesting a by-law amendment within 90 days (or 120 days if the decision was concurrent with an official plan amendment application). To respond to what William Johnston, Toronto’s Interim Deputy City Manager of Infrastructure and Development Services, characterized as the “punitive legislated timeline provisions” of this bill, the City of Toronto hired an additional 150 staff to manage the workload. The new timelines did not allow staff to provide even a single round of comments about matters as basic as a building’s height or the size requirements of a new sanitary pipe, so comments were pushed to a mandatory pre-application consultation phase.

Bill 185, if passed, will remove the requirement for mandatory pre-consultations—reducing the ability of municipal staff to make any meaningful comments on applications, unless a developer voluntarily opts-in to this process. In many cases, this will have the effect of further shortening the timeline with which developers proceed along the well-trod route of appealing an application rejected on the municipal level to the Ontario Land Tribunal, which has the authority to override local decisions.

While this may be helpful in smaller centres where staff are less well equipped to evaluate applications, in larger cities, the move to further reduce the review and oversight process for development applications will almost certainly have an overall negative effect on the quality of buildings. Perhaps this is a worthwhile trade-off for a rapid influx of new homes. But will quicker approvals ultimately get us more housing? 

A 2023 report from Gregg Lintern, Toronto’s Chief Planner and Executive Director of City Planning, suggests that the answer is: no. It found that 103,638 residential units had been built between 2017 and 2022, and that there were an additional 203,793 residential units—twice that number—that had already been approved, but not yet built. Many of these properties, presumably, are held by speculators who strategically upzone without ever having the intention to build. An additional 409,896 units were still under review at the time of Lintern’s report. If all of those units were realized over time, this would increase the total number of dwellings in Toronto by one half—exceeding the city’s projected 2051 population of 3.66 million by 14%. 

The same year, the Regional Planning Commissioners of Ontario undertook a similar exercise. It reported that, province-wide, there were already over 1,250,000 housing units approved before Bill 23 even came into the picture. If stakeholders were to collaborate in getting these already-approved units built, the report implied, the province would get to its goal without rushing further approvals or removing environmental controls.

In response, a report commissioned by developer lobby groups Building Industry and Land Development (BILD) and Ontario Home Builders’ Association (OHBA), countered that there were only 331,600 “shovel ready” units, and that an additional 731,000 were in the application process, needing additional approvals, requiring a servicing allocation, or awaiting decision from a municipal council.

Perhaps a balance will come into place with an additional provision proposed in Bill 185—a “use it or lose it” provision that will give municipalities the option to specify the expiry of site plan approvals after three years.

All of this points to problems in housing supply that go beyond what can be solved by cutting red tape alone: a meaningful acceleration in homebuilding would require addressing systemic problems such as inflation and the lack of tradespeople. As Lintern concluded in his 2023 report: “Provincial targets are aspirational and their pursuit will not result in actual completed homes without a complete rescaling of the capacity of the development industry to construct new homes.”

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