City Planning presented several reasons for expanding commercial permissions in residential neighbourhoods. COTRA reviewed the City’s reports, data, maps and supporting information.
CLAIM 1
Small-scale retail in Neighbourhoods is mandated by the Official Plan.
COTRA’S RESPONSE
The Official Plan does not require blanket rezoning of residential properties. It says new small-scale retail, service and office uses “may be permitted” in Neighbourhoods where they have minimal adverse impacts on nearby residents, including impacts from noise, parking, deliveries and loading.
COTRA questions whether broad permissions for bars, restaurants, patios and other potentially higher-impact uses on residential streets meet that standard.
The concern is not theoretical. City Council itself subsequently asked the Province to consider restrictions on cannabis retail stores and liquor licences in areas designated as Neighbourhoods, and directed staff to examine safety considerations related to cannabis and alcohol.
CLAIM 2
The Committee of Adjustment process is a barrier to small businesses.
COTRA’S RESPONSE
The Committee of Adjustment process provides notice and an opportunity for residents to comment on an individual proposal and its potential local impacts.
City data cited in the City’s materials showed that approximately 90% of applications for non-residential uses in Neighbourhoods were approved.
This suggests that the existing process was not simply preventing small businesses from opening. It provided a way to consider individual properties while allowing residents to raise concerns about issues such as parking, traffic, noise and compatibility.
COTRA believes a targeted approval process is preferable to blanket permissions across residential areas.
Source: City of Toronto. Neighbourhood Retail & Services. Information and Reports May 2024 Proposals Report Materials: Attachment 4: Research and Consultation.
CLAIM 3
The changes will improve walkability by providing more local shops and services.
COTRA’S RESPONSE
Some neighbourhoods would benefit from better access to local shops and services. COTRA agrees that local retail can play an important role in complete communities.
But a blanket approach assumes that the same need exists everywhere.
Many neighbourhoods are already well served by established commercial streets, plazas and other nearby retail. Allowing new businesses on residential streets where demand has not been demonstrated could also create unfair competition for existing small businesses operating on established commercial streets, where they face commercial rents and other costs.
COTRA supports a targeted approach: identify where services are actually needed, then determine appropriate locations in consultation with local residents and businesses.
City of Toronto. Neighbourhood Retail & Services. Why Neighbourhood Retail & Services are Important.
CLAIM 4
City maps show gaps in access to retail and services.
COTRA’S RESPONSE
COTRA found significant problems with the City’s retail and services mapping.
The City’s map does not capture all existing retail activity, including:
- existing legal non-conforming businesses;
- commercial areas governed by former City of Toronto zoning by-laws;
- Employment Areas such as Geary Avenue; and
- some existing plazas in Commercial Local (CL) zones that are misclassified as residential.
These omissions can make areas appear to have fewer retail and service options than they actually do.
The City’s own earlier report explains that existing retail and service uses in Neighbourhoods may be legal non-conforming, may have been established through a rezoning or minor variance, or may have existed under earlier zoning rules.
If the underlying map does not show the full extent of existing commercial activity, it is difficult to use that map as evidence that blanket rezoning is necessary.
Source: City of Toronto. Neighbourhood Retail & Services. Information and Reports December 2024 Final Report Materials and Draft Zoning By-law Amendments: Proposals Report Materials: PH17.2 – Expanding Housing Options in Neighbourhoods – Neighbourhood Retail and Services Study Phase Two Final Report
CLAIM 5
The changes will bring vacant or “ghost” storefronts back into productive use.
COTRA’S RESPONSE
Some properties identified as former commercial or “ghost” stores have since been converted to residential use, including multi-unit rental housing.
Allowing commercial use again can create an incentive to convert existing rental housing to commercial space.
Under Section 50(1)(b) of Ontario’s Residential Tenancies Act, a landlord may terminate a tenancy to convert to non-residential use, subject to the requirements of the Act.
This creates a potential pathway for the loss of existing rental housing in order to create commercial space.
COTRA questions whether converting housing into small commercial spaces is an appropriate response when the need for additional retail has not been demonstrated in the specific neighbourhood.
Sources:
City of Toronto. Neighbourhood Retail & Services. Information and Reports December 2024 Final Report Materials and Draft Zoning By-law Amendments: Proposals Report Materials: PH17.2 – Expanding Housing Options in Neighbourhoods – Neighbourhood Retail and Services Study Phase Two Final Report
Ontario Residential Tenancies Act, Section 50: https://www.ontario.ca/laws/statute/06r17#BK72
CLAIM 6
The changes will help replace lost plazas and grocery stores.
COTRA’S RESPONSE
The City’s own zoning framework places significant limits on the size of new commercial establishments.
On Major Streets, the maximum is generally:
- 130 m2 (interior neighbourhoods) 150 m² (Major Streets) for an individual establishment;
- 400 m² total in an apartment building, subject to additional requirements.
A 150 m² space is approximately 1,600 square feet. That may accommodate a small local store or service, but it is not comparable to a typical full-service grocery store or shopping plaza.
COTRA therefore questions whether converting individual residential properties into small commercial spaces can realistically replace the larger grocery stores that have been lost.
There is also a broader planning question: if larger commercial areas are needed, shouldn’t the City be supporting existing plazas and commercial streets rather than dispersing small businesses onto residential streets?
City of Toronto. Neighbourhood Retail & Services. Information and Reports December 2024 Final Report Materials and Draft Zoning By-law Amendments: Proposals Report Materials: PH17.2 – Expanding Housing Options in Neighbourhoods – Neighbourhood Retail and Services Study Phase Two Final Report
CLAIM 7
The new permissions are a reasonable way to support small businesses and reduce red tape.
COTRA’S RESPONSE
Reducing red tape can benefit small businesses. But eliminating the individual review process also eliminates an important safeguard for neighbouring residents.
The previous process allowed the City to consider the circumstances of a particular property and allowed nearby residents to comment on issues such as noise, parking, traffic, deliveries and compatibility. It’s worth noting that the Ford government removed the right of appeal for neighbours under the CoA process, significantly streamlining development. It’s hard to understand why City Planning would want to remove the CoA process entirely before giving this major new change a chance to play out.
COTRA’s position is not that small businesses should be prevented from opening. It is that where businesses are needed, the City should identify appropriate locations rather than automatically permitting commercial uses across large areas of residential zoning.
City Council’s own decision recognized the need to monitor the new system and report back after the earlier of two years or 100 building permits/business licences, including consideration of dedicated enforcement resources.
What Toronto residents told us → [EXISTING PAGE/LINK: Survey Results]
What COTRA recommended → [EXISTING PAGE/LINK: What COTRA Recommended to City Council]