Toronto: Getting Serious about Public Realm + Built Form

November 16, 2020

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On September 21, 2020, the Ministry of Municipal Affairs and Housing approved City of Toronto Official Plan Amendments (OPA) 479 and 480. OPA 479 includes new and amended policies for the public realm, and OPA 480 includes new and amended policies for built form. Both were the result of the City’s Official Plan review initiated nearly a decade ago.

While OPA 479 and 480 establish more robust and rigorous policy directions for new developments, they remain generally qualitative in nature. The new in-force public realm and built form policy changes strengthen existing policies and provide further clarity and design direction on standards for the public realm and consistency across built form typologies. The policies advance design objectives and qualitative principles from the Tall Building and Mid-rise Design Guidelines, but do not go as far as providing quantitative metrics.

The policies also introduce new submission requirements, requiring a Block Context Plan and a Soil Volume Plan to ensure a Complete Application. As of September 21, a proposed development must respond to these policies to ensure conformity with the Official Plan, and any Planning Rationale must provide a justification of the proposed development against the new policies. These new policies should not apply to applications that were deemed complete prior to September 21, 2020.

OPA 479: Getting Serious About the Public Realm

OPA 479 amends Section 3.1.1, The Public Realm, within Official Plan Chapter 3 “Building a Successful City”. In general, OPA 479 puts new emphasis on the importance of public realm and amends policies to provide greater clarity with respect to design standards for new developments. Whereas the Official Plan policies were previously quite general and aspirational, the amended policies are direct and imperative.

The new and amended policies provide enhanced detail and specification for all parts of the public realm, including sidewalks, laneways, Privately-Owned Publicly Accessible Spaces (POPS) and parks. The top five changes to Section 3.1.1 are:

  • All new streets are required to be public streets, unless otherwise deemed appropriate by the City (
  • New streets will provide frontage and visibility on natural and human-made features including parks, cemeteries, school yards and campus lands (
  • As part of the public realm, lanes will be public and opportunities for lane enhancements should be identified as part of the development approval process (
  • Parks and POPS will be located with public street frontages to establish direct visual and physical access (
  • Consultation, partnerships and collaboration with Indigenous communities is encouraged for planning and design of the public ream (

OPA 479 is clear that while POPS are spaces that contribute to the public realm and are privately owned and maintained, they do not replace the need for new public parks and open spaces. Policy is specific about the role and function of POPS, requiring that they be located in highly visible locations and programmed for users of a variety of ages and abilities.

New and modified submission requirements will assist City staff in evaluating the quality of the public realm for new developments:

  • The Arborist/Tree Preservation Report is replaced by three separate components: Arborist Report, Tree Protection Plan and a Soil Volume Plan. The Soil Volume Plan is an entirely new requirement and intended to demonstrate that adequate soil volume suitable to support plant growth is being provided on site. All three studies are required for Zoning By-law Amendment, Plan of Subdivision, Site Plan and Consent to Sever applications.
  • The Block Context Plan provides a written and illustrated justification of how the development fits within the block and surrounding context. The Block Context Plan is expected to address matters such as the layout and design of existing and proposed streets, pedestrian circulation network, the location of existing and future public destinations, the layout of development parcels, building massing, existing and possible locations for public art, existing and proposed cycling routes, and phasing of development. Not unlike a Planning Rationale, the Block Context Plan must demonstrate conformity with the Official Plan policy and demonstrate good planning and urban design. A Block Context Plan is required for an Official Plan Amendment, Zoning By-law Amendment, Site Specific Zoning By-law, Plans of Subdivision, and Site Plan Control. Urban Strategies’ integrated approach to Planning Rationale and Urban Design Analysis reports already advances many requirements of Block Context Plan. We have quickly pivoted to integrate the Block Context Plan as a discrete element of our reports.

OPA 480: Addressing All Areas of Built Form

OPA 480 amends Sections 3.1.2 and 3.1.3 of the Official Plan to introduce more robust policies to control the built form of new developments. The revised policies focus on infill and intensification, reinforcing the need to consider fit within the existing and planned context carefully. Many of the built form policies focus on providing a more comfortable pedestrian experience and improving the quality of the public realm.

The new and amended policies provide direction with respect to site access for all modes of transportation, comfortable wind conditions for sitting and standing, access to sunlight, and street wall heights. Policy encourages development to provide amenities for pedestrians in the public realm to make areas adjacent to streets, parks and open spaces attractive, interesting, comfortable and functional for pedestrians. Policy directs blocks with access to direct sunlight to prioritize the provision of accessible open space in those locations. Policy emphasizes the need for developments to transition to adjacent parks and open spaces to provide access to sunlight. Policy requires that good transition be achieved to areas of different building heights, with a transition in scale provided within a development site. A key question for applications will be determining what constitutes “good transition” in scale. For all of these policies, there is no quantitative direction provided.

Some new policies seem to be oriented to major developments in the Downtown and other high density mixed use locations. For example:

  • Policy requires the removal of existing surface parking and vehicular access between the front of a building and the public street. While the intent of the policy has merit, the requirement may have unintended consequences for sites within lower-density neighbourhoods, employment districts, or even minor infill developments or renovations that require Planning Applications.
  • Policy used to apply to just “new development”, but now applies to all “development.” This foundational built form policy provides direction with respect to building siting and design, setbacks, open spaces, ground floor uses and sightlines, and wind conditions for pedestrians. The application of these policies to all development is a significant change, and the extent to which this policy would apply to minor renovations or additions that require a minor variance remains to be seen.
  • Policy encourages development to be located and massed to fit within the existing and planned context by providing streetwall heights and setbacks that fit harmoniously within the existing and planned context. For development projects outside of the downtown core, including mall redevelopments, there likely is no existing context or streetwall height to consider. Many projects on sites outside of the downtown core are precedent setting and are the first step in creating the future context.

Section 3.1.3 of the Official Plan “Built Form – Tall Buildings” has been changed to “Built Form – Building Types”, which now addresses tall, mid-rise and low-rise buildings. The new policies formalize various design guidelines into more substantive Official Plan policies, though without the quantitative numbers that are found in the guidelines. For example, for mid-rise buildings on deep sites, Policy encourages the design to provide and frame accessible and well-proportioned open spaces that have access to sunlight and daylight. The Mid-rise Design Guidelines outline specific setbacks and angular planes for buildings on deep sites to consider. Policy states that base buildings of a tall building should respect and reinforce good street proportion and pedestrian scale, and be lined with active, grade-related uses. The Tall Building Design Guidelines are more specific regarding the height of the base building, recommending that base buildings appropriately frame the public realm to provide least 5 hours of sunlight on the opposite side of the street.

Moving Forward with the new Public Realm and Built Form Policies

All new development applications submitted after September 21, 2020 are required to demonstrate how the new policies are met. However, while OPA 479 and 480 put more emphasis on the public realm and provide guidance for built form and massing, they do not prescribe specific quantitative measures. More specific design guidance, including metrics, can still be found in the City’s various design guidelines.

Urban Strategies has a strong understanding of planning policy and the planning approvals process.  We would be pleased to explore any questions about land use planning and what these policy changes mean for you. Please get in touch with Ben Hoff if you have any inquiries.

By: Michelle Rowland and Antonio (Tony) De Franco