Big changes are underway for many of Ontario’s municipalities in the Greater Golden Horseshoe (GGH) as they are required to undergo a process to bring local plans into conformity with A Place to Grow: The Growth Plan 2019.  The Growth Plan 2019 (which came into effect in May 2019 and was amended in August 2020) sets new policies, revised targets, and new growth forecasts and intensification strategies. Some of the most impactful changes are those related to employment lands and major transit station areas (MTSAs). Lower-tier, single-tier and upper-tier municipalities must undertake a process referred to as a Municipal Comprehensive Review (MCR), to ensure their official plans conform with the new and modified policies in the Growth Plan 2019.  Following the completion of the MCR process, they must submit a new official plan or an official plan amendment to the Minister for final approval. There is no appeal of the Minister’s decision.

As part of the MCR process, each municipality must craft a plan detailing the study and processes required to reach conformity with the Growth Plan, 2019. This study, public consultation, and the passing of the necessary policy updates are required to be completed by July 2, 2022.

In the City of Toronto, the MCR is structured around four significant policy matters including Managing Forecasted Growth through Intensification; Protecting Employment Lands; Considering Requests to Convert Employment Areas; and Updating the Official Plan’s Environmental Policies.

This blog post focuses on one aspect of the City of Toronto MCR: the process for Employment Area conversions.

Employment Areas are important places that provide the land supply underpinning the success of our region’s economy, and accordingly, employment lands are protected in layers of planning policy. However, like all land uses, the landscape of employment –where it is taking place, what land needs are or are not necessary for success, what new uses are more appropriate, and understanding space needs of these uses – changes over time. This shifting employment needs may require modifications to the planning framework.

The Growth Plan 2019 lays out policies to permit conversions to other uses which can only be considered through a municipal comprehensive review, subject to specific criteria. In the City of Toronto, the Growth Plan’s conversion criteria have been elaborated upon through additional Official Plan policies. These policies require a comprehensive analysis to demonstrate why the conversion of employment lands would be appropriate and what impacts there may be to such a change in land use.

In general, the conversion criteria revolve around:

• demonstrating the need for conversion,
• ensuring the City will maintain a sufficient supply of employment lands,
• consideration for the viability of the employment area and
• the availability of services to accommodate the proposed use(s).

A conversion request requires the submission of a number of studies or professional opinions, synthesized into a conversion rationale. In some cases, a proof of concept massing and site strategy with high-level development statistics would be beneficial to include to help City staff understand the conversion.

The City learned a lesson from the OPA 231 MCR process, in which applications varied significantly in terms of timing of the request, detail, and content. Their May 19, 2020, Work Plan outlines a new process for conversion requests.

The City is now seeking to standardize submission requirements for conversion requests along with an application fee (the City has not yet released the amount). This time around the City is limiting the period during which they will accept conversion requests. The application window opened on August 4, 2020, and will close on August 3, 2021. With regards to process, conversion applications should begin with a pre-application meeting with Strategic Initiatives Policy and Analysis (SIPA) to confirm the scope and clarify any questions prior to submission. Unlike other statutory processes, conversion applications will not be deemed “complete”.

Given the lack of precise definition around the application requirements or the review process, early conversations with city staff will be a critical component to understanding and gathering the appropriate material to support an application. As described above, because the Minister is the approval authority for new Official Plans or Official Plan Amendments brought forward through the MCR process, there is no appeal of decisions on Conversion requests following the Minister’s decision.

Urban Strategies has a strong understanding of the conversion process and expertise in preparing Planning Rationales to support conversion requests along with conceptual massing strategies.  We would be pleased to explore any questions about your employment land holdings and what this MCR process may mean for you. Please get in touch with Ben Hoff with any inquiries.

Stay tuned for these blog posts over the coming days!

Authored by Leigh McGrath and Inger Squires.