The City of Toronto (the “City”) is moving ahead with transforming its development review process through the implementation of the Concept 2 Keys (“C2K”) program, which we last reported on in October, 2020. C2K is the City’s response to its development review process report entitled End to End Review released in August 2019 (the “Report”). The Report aims to reimagine organizational structures, processes and technology to provide for a more seamless and collaborative approach to development review. In the age of virtual work environments, the need to foster collaboration between staff, applicants and the public has only increased.
What are the changes?
On a technical level, C2K’s changes to the review process include the launch of a new online application submission tool with new user-friendly forms and templates, and the expansion of the online intake portal. A new commenting mark-up tool will enable City staff and commenting partners to review planning applications, provide comments and collaboratively revise planning drawings. These changes are proposed to foster a more collaborative and iterative approach to development review, while simultaneously shortening review turnaround times.
Changes to the review process itself involve the creation of dedicated application review teams made up of members from various City divisions and overseen by new application managers and coordinators. Upon receipt of an application, teams will work to identify preliminary issues and communicate the City’s requirements and expectations. The hope is to provide a coordinated approach to development review that avoids conflicting instructions from different divisions. Should there be competing or conflicting priorities between divisions, a new Issues Resolution Table (“IRT”) has been created where new relationships and issues coordinators will facilitate internal discussion and resolve (or escalate) issues within ten business days, while updating the applicant on an ongoing basis.
Applicants can also bring issues to the IRT through a new relationship and issues management function on the review portal, which provides a single place to go to resolve file specific issues. Touch points with applicants and the City will also be increased, including through pre-application meetings, to avoid the need for the IRT to be used in all circumstances.
How is the program being implemented?
Currently, C2K is being piloted on affordable housing development applications and long-term care applications which meet the affordability criteria outlined in the City’s HousingTO 2020-2030 Acton Plan. Thirteen applications are currently participating in the C2K process (click here). Plans to gradually expand the process to non-affordable housing in a “Phase 2” have not yet been given a firm date.
The prioritization of affordable housing projects within C2K is consistent with the City’s goal of constructing 40,000 new affordable rental homes by 2030 and is sensible within the affordable housing context, where construction of projects are increasingly being spearheaded by the City itself. However, it remains to be seen whether this increased efficiency will be preferable for private applicants over filing an LPAT appeal for failure of Council to reach a decision within the prescribed statutory periods.
