On February 5, 2025, the City of Toronto (the “City”) adopted Official Plan Amendment 778 (“OPA 778”). Alongside its dramatic expansion of the number and kilometres of “Avenues” designated in the City’s Official Plan, OPA 778 creates a revised policy framework to streamline development along these Avenues. We explore these changes, and the City’s identified next steps on this matter, below.
Changes in the Number and Kilometres of Avenues
OPA 778 adds approximately 283 kilometres of Avenues to “Map 2” in the City’s Official Plan (as seen below in Figure 1) thus increasing the total to 455 kilometres. New Avenues, apart from those being added separately through the upcoming Jane-Finch Secondary Plan, were identified by the City based on current and planned frequent and higher-order transit, proximity to Employment Areas, connections between preexisting Avenues, and proximity to major post-secondary institutions.
Figure 1 – Proposed New Avenues (Source: City of Toronto).
The Revised Policy Framework
OPA 778 replaces policy 2.2.3 of the City’s Official Plan (the “Previous Policy”) in its entirety. The new policy 2.2.3, as introduced through OPA 778 (the “Revised Avenues Policy”) makes several changes to streamline development and promote intensification, as discussed below.
Bye-Bye Avenue Studies and Avenue Segment Reviews
Under the Previous Policy, the City was generally required to prepare “Avenue Studies” for each Avenue, prior to development being permitted along them. Since 2002, when the Previous Policy was introduced, the City has only completed Avenue Studies for 30 of its Avenues, or 45% of the 172km of Avenues pre-OPA 778.
Where an Avenue study was not completed, developers could submit an “Avenue Segment Review” study. Given the lack of Avenues with Avenue Studies, this process was undertaken frequently. The review consisted of numerous requirements, the most onerous being an assessment of the entire Avenue Segment at a similar form, scale, and intensity to ensure no adverse impacts if development on this scale were carried out across the entire segment.
In practice, however, Avenue Segment Reviews slowed down the development review process, and much of the work replicated that contained in a Block Context Plan, which can form part of a complete application for development.
The Revised Avenues Policy has removed the need for either of these studies prior to submitting a zoning by-law amendment or other planning application to facilitate development.
Typology (Mostly) Defined
Whereas the Previous Policy only spoke to “reurbanization” of the City’s Avenues, the Revised Avenues Policy explicitly states that the City’s general planned built form of Avenues in Mixed Use Areas and Apartment Neighbourhoods is mid-rise. If a portion of an Avenue is in a Mixed Use Area and within 500-800 metres of existing and planned subway, light rail transit, and GO rail stations then higher densities are contemplated. Such increased densities around transit stations will be contemplated regardless of when the Minister of Municipal Affairs and Housing approves the City’s proposed Protected Major Transit Station Areas and Major Transit Station Areas.
For developers, landowners, and others looking to solve the housing crisis, this language is a welcome change to support the upzoning of lands to increase housing supply. However, this does not guarantee increased density everywhere.
Notably, the Revised Avenues Policy does not identify a preferred built form typology along Avenues where the associated land use is “Residential”. Moreover, the new sub-policy 8 provides that land use designation policies contained in Chapter 4 of the Official Plan (including the policies associated with the City’s low-density residential Neighbourhoods) continue to apply and prevail over lands designated as Avenues. While the City recently allowed townhomes and small-scale apartment buildings along Major Streets in Neighbourhoods through a separate official plan amendment in 2024, that amendment remains under appeal.
Additionally, the City must still go through the process to redesignate and rezone lands along Avenues to address other restrictions and to provide for additional height and density permissions. As a result, it is unclear what impact, if any, the Revised Avenues Policy will have on increasing density in these residential areas.
Minimizing Displacement
A new sub-policy, 2.2.3.6., also seeks to address issues related to the displacement of existing small businesses and community service providers along Avenues, particularly those operated by and/or serving racialized and marginalized populations by introducing new consultation requirements. As part of these requirements, an applicant must provide notice of its proposal to the existing small businesses and community service providers located on the applicant’s property, and demonstrate:
a) how the local community will be consulted to assess the range of local community needs for retail and services uses, and
b) how the existing small businesses and community service providers will be consulted to assess the potential for their return in the development.
The policy does not, however, create a right of return for small businesses and community service providers, which remain undefined within the City’s Official Plan and Zoning By-law.
Next Steps
As with most planning in the City, progress on implementation is incremental. The Planning Staff Report for OPA 778 placed before City Council recommended that staff “make best efforts” to advance a separate Official Plan Amendment and Zoning By-law Amendment to redesignate and rezone lands along the Avenues, to enable mid-rise and other higher density-boosting built forms. This is in line with previous rezoning efforts on portions of Toronto’s pre-existing Avenues, which we detailed in a previous blog post.
After consideration by City Council, however, this language was modified to ensure that any future Official Plan Amendment or Zoning By-law Amendments on this matter be subject to a comprehensive review and community consultation process. This process is to include analysis of parking considerations, infrastructure capacity, traffic operations, and impacts of redevelopment on properties with reversed frontages where the backyards of houses face the Avenues.
No timeframes were attached to the City’s decision, but Davies Howe LLP will continue to monitor changes to Toronto’s Official Plan and zoning by-laws. If you wish to obtain further information on your appeal rights, or how your property may be impacted by forthcoming City initiatives, please feel free to reach out to us.
