Minimum unit sizes and unintended consequences

Last week, we made our second deputation for the Planning & Growth Management Committee on Midtown in Focus, the Proposed Yonge-Eglinton Secondary Plan.

This plan, along with TOCore which addresses our city’s downtown, introduces new minimum unit size requirements above and beyond those required by our building code. This seemingly well-intended measure to provide midtown residents with more living space can lead to some pretty predictable if unintended negative consequences.

We’ve included video of our deputation and a copy of our speech below.

Good morning.

My name is Chris Spoke and I’m a member of Housing Matters.

We are a group of Torontonians who advocate for increased housing supply to address the housing availability and affordability crisis that is pricing many renters, young people, and middle class families out of our city.

I appreciate being granted the opportunity today to comment, once again, on the Midtown in Focus Official Plan Amendment and would like to start by thanking Planning Staff for the diligent work that went into its preparation.

There is a lot to like within its 78 pages. Midtown is certainly one part of Toronto where we have not shied away from much needed-intensification, and we believe that the city is all the better for it.

That said, we would like to highlight one item in particular that we believe would have a particularly adverse effect on housing availability and affordability in midtown.

Section 7.1 of the proposed secondary plan outlines new minimum unit size requirements that are above and beyond those required by the building code.

Specifically, 2-bedroom units would require a minimum of 87 square meters of gross floor area, and 3-bedroom units would require a minimum of 100 square meters of gross floor area.

To put that in context, when looking at three recent projects under construction in midtown, we see an average size for 2-bedroom units of 63 square meters and an average size for 3-bedroom units of 96 square meters.

To make that a little more concrete, the average 2-bedroom unit that we’re seeing built in midtown is 28% smaller than the required minimum size set out in Midtown in Focus.

Larger unit sizes, considered on their own, are desirable and contribute to a better quality of life for their residents.

Of course, they can’t be considered on their own.

We believe that it is vitally important that we think through some of the second order effects of these new requirements.

Toronto is the fifth most expensive city in the world when measured as a ratio of housing prices to incomes, according to data compiled just this week by Bloomberg. More expensive, even, than New York City on this basis.

Requiring by law that new units be built to be significantly larger than they currently are would have the effect of:

1. Reducing the total number of new units delivered to the market, both by reducing the number that can fit within a given project and my rendering some projects uneconomic at the margin; and

2. Exacerbating our affordability crisis both through the straightforward logic that larger units are more expensive units and through the adverse impact on overall supply.

That said, we request that Midtown in Focus be amended to not include these new minimum unit size requirements, and to instead first take some time to monitor the impact that similar requirements that have been included in the TOCore downtown plan have on housing availability and affordability before extending them to midtown.

Thank you.