Opportunities to increase missing middle housing and gentle density, including supports for multigenerational housing

FUN Response to ERO #19-5286

The government is seeking input on how to diversify housing choices in existing neighbourhoods. This consultation is focused on finding ways to support gentle density and increase Ontario’s missing middle housing, including encouraging multigenerational housing solutions.

Proposal Summary, Environmental Resources Ontario

Question 1:

  • What are the biggest barriers and delays to diversifying the types of housing built in existing neighbourhoods?


The question is built on several assumptions – which are unproven:

  1. That the housing price issue can be solved through increasing supply.  Instead we need to address the demand issues, such as land speculation e.g. flipping, vacant housing, the real estate industry practices that force up prices;
  2. That there is a housing shortage when in fact the number of homes increased at a greater rate than population;
  3. That neighbourhoods are all the same and all need to be intensified when in fact there is a large variation in population trends among different neighbourhoods. In Toronto the neighbourhoods in the Yonge Corridor and those close to Lake Ontario are intensifying ; those in Scarborough and Etobicoke away from the Lake not so much.  This largely reflects the access to higher order transit in the former areas and the lack of this in the latter areas.
  4. That the existing zoning is the major barrier and if this is changed there will be a resulting diversity of homes developed.  No question the current zoning (and the Committee of Adjustment variance approval process) is permitting monster homes with density (FSI) far beyond the allowable. The experience in Toronto neighbourhoods that DO have zoning that allows missing middle housing is that  few of these types of housing are being built; instead, rather large single family houses (in some areas that end up being used as illegal Pop Up rooming houses) are applied for and built.  Therefore, it would appear that the barrier is NOT the zoning, but something else? Perhaps the Province should give municipalities the ability to refuse permits for oversized single, detached homes with large garages and encourage the developers to build more compactly and efficiently on the footprints of the existing houses to preserve greenspace and trees.  
  5. That the concept of neighbourhoods being “stable” and having “character” needs to be scrapped because it is restrictive.  The reality is that neighbourhood character is a matter of importance and pride and its nature varies – sometimes it is “consistency” – the repetition of the quiet vernacular, other times it is diversity and “heterogeneity” – it depends on the planning regime in place when the area was developed, and its subsequent history. The different types of neighbourhoods means that the desire for “as of right “application of new housing types is unfair and inappropriate.
    Change needs to be introduced gradually with respect to the differences and based on PLANS not on autocratic “one size fits all” rules.
  6. Missing Middle housing should not be allowed to remove existing affordable housing without replacement (which is the case today). And the City needs to have in place real protection for mature trees and growing space for younger trees.
  7. Communities and current residents need to see tangible enhancement to their communities – not only negative effects which is often the case currently
  8. There is an issue of financialization of housing – investors claim that only new buildings can solve the housing crisis. As a result development and housing sits unoccupied while waiting to creating a “clear space” on which to build a new house/townhome/high rise long before the planning approvals and building permits process begins. We need to see the potential of adapting and using existing structures more efficiently to house more people more quickly and more cheaply than building new.  We are in a Climate Crisis and to fix up an existing building is better for the environment than tearing it down and replacing it with new materials. Sustainable communities are not created by gentle intensification. They require a lot of planning. Currently, in much of the “in demand” ares, all condominium buyers are warned that their children may not be able to attend a local school.

Question 2:

  • What further changes to the planning and development process would you suggest to make it easier to support gentle density and build missing middle housing and multigenerational housing, in Ontario?


Governments could continue to create rigorous policy and enforcement frameworks for multi-tenant housing to encourage people to take advantage of existing provisions regarding occupancy. For example, most municipalities allow three unrelated
persons to live together in a single building. Many people could be sharing their houses, without losing their privacy, and supplementing their income, at minimal cost

Look at former places of worship that could be retrofitted into living spaces.

Government needs to ensure that community impacts such as schools and community centres and hospitals are provided for. The current provincial top-down process for schools fails totally in this regard

Question 3:

  • Are you aware of innovative approaches to land use planning and community building from other jurisdictions that would help increase the supply of missing middle and multigenerational housing?


Excellent examples of “good planning” employing innovative approaches are:

  1. Support for development of complete communities — Oakville Living Design Manual which focuses on meeting provincial objectives to grow more housing while creating healthy neighbourhoods (see attached)
  2. A well designed secondary suites program — City of Ottawa Secondary Suites (see attached –  LivDesignManual-v2-1.pdf (oakville.ca)
  3. Adaptive reuse of existing buildings, e.g.: Preston School seniors’ apartments in Preston; Eva’s Phoenix in downtown Toronto for transitional housing; Park Lofts on Annette Street in Toronto; Chapel Street Lofts in Cobourg was first a church, then a library and now six condos; and Seagram Lofts on the Lakeshore in Toronto.
  4. Alternatives to affordable housing: private developments, condominiums, laneway housing, garden suites or multiplexes will not result in affordability and security for renters. We need to support and encourage other alternatives which ensure long term rental or ownership at a reasonable cost for long time such as life lease and cooperative forms of tenure. But of course these work for people who desire comfortable housing not for investors who want to get their money out as quickly as possible!

Question 4: 

  • Are there any other changes that would help support opportunities for missing middle and multigenerational housing?


As above we feel that a one-size fits all approach will not be successful. The City needs to do secondary studies for individual neighbourhoods based on a prioritization process.

  1. Analyse the local needs, barriers and opportunities for growth
  2. Set goals/growth targets with associated timeframes
  3. Engage the community and property owners on developing a growth strategy and provide incentives,
  4. Governments need to address the funding needed for additional schools (or keeping schools that are at risk of being lost due to declining registration), community centres, parks, and greenspace.
  5. Monitor and assess progress on a regular basis (at least yearly to start) and be prepared to adjust if it is not working.

Image Credit: LoozrboyCC BY-SA 3.0, via Flickr