The Residential Construction Council of Ontario (RESCON) issues its concerns regarding the City of Toronto’s pre-application consultations. The organization states that it is worried that the city might not have the resources that are necessary to carry out mandatory pre-application consultations with developers on a timely basis.
“Any delays in these consultations might stall the construction of much-needed housing,” says RESCON president Richard Lyall. “There are already enough bottlenecks in the development approvals system. We want to make sure that the city has enough planning department and other staff on hand to do the consultations. We are not building enough homes and any further delays will only escalate the cost of housing.”
Last week, city council voted to make it mandatory for developers to attend consultations with planning department staff and other relevant agencies before they can apply to start a project. Developers would also be urged to consult with city councillors, business improvement areas, and resident and tenant associations. The new rule takes effect in November.
According to RESCON, residential builders are generally supportive of pre-application consultations and have participated in voluntary pre-application consultations. They allow developers to meet with city staff to discuss their proposals to get a clearer understanding of what is required to submit a formal planning application, in hopes of a more efficient evaluation of a subsequent submission.
However, now that the pre-application consultations are mandatory, RESCON has concerns about the capacity of planning department staff to handle such sessions as resources are already stretched.
The current standard for pre-application consultations targets 15 business days from the date of a meeting request to a scheduled meeting date, but applicants are experiencing waits well beyond the intended timeline, says RESCON.
In 2020, for example, there were 483 development applications and 449 requests for a pre-application consultation meeting. Yet, the city was only able to grant a meeting in the same year to just 67 per cent of applicants.
Toronto’s development review process involves up to 25 city divisions and entities, and potentially more than 30 external commenting agencies. Mandatory pre-application consultations will necessitate increased staff time as well as more collaboration between siloed departments.
“To be clear, pre-application consultations can improve application quality and make for good city-building outcomes,” says Lyall. “Such an initiative has worked in other jurisdictions like Copenhagen for example. Good results were achieved because problems were resolved earlier on. Our worry, however, is that transitioning from a voluntary to mandatory pre-application requirement will require more staff resources – without making other process improvements.”
RESCON supports sweeping reforms suggested recently by a provincial Housing Affordability Task Force, as they will help streamline the system and allow for managing an effective pre-approvals process, but is worried that the mandatory pre-application consultations will be used to triage development applications or add undue burden onto applicants prior to a formal development submission.
RESCON is suggesting that the city report on key performance indicators associated with the consultations before they are fully launched.
