September 29, 2025
Mayor Olivia Chow
Office of the Mayor
City Hall, 100 Queen Street West
Toronto, ON M5H 2N2
Sent via email
Re: Public Statements Regarding Architectural Services and Laneway Housing in the City of Toronto
Dear Mayor Chow,
We recognize the City’s efforts to improve the permit process, which the Toronto Star reported can take on average 24 months, a timeline that is three times longer than comparable jurisdictions in the United States as of August 13, 2025. This focus on improvement is necessary to address Toronto’s housing pressures.
We remain concerned, however, about the City’s communications and program design for the Preapproved Garden and Laneway Suite Plans. The intent to reduce cost and speed approvals is understandable. The current approach undermines that outcome and creates avoidable risk for homeowners and professionals.
Under the Ontario Building Code, architects are not required for residential projects under three storeys and 600 square metres. The City’s free preapproved plans still require a professional stamp from an engineer, an architect, or a BCIN qualified designer to satisfy the application. In practice, the combination of free plans and a stamp requirement, paired with restrictive use conditions, discourages architects from participating. This is not a path to quality or speed. It is a path to confusion and liability gaps.
The program’s requirement that no changes be made to the preapproved plans places the stamping professional in a position of accepting responsibility for work they did not design. That is not compatible with professional liability coverage. It does not reflect how accountable practice works, and it leaves homeowners exposed. In reality, most sites require at least minor adaptation to fit lot conditions, utilities, accessibility, envelope performance, and the Toronto Green Standard. The moment any modification is needed, the preapproval is invalid and time is lost. Even where no modification is requested, the plan must still be verified to fit the lot and comply with the Ontario Building Code. If it does not, homeowners waste time and money and the City absorbs processing cycles that do not advance approvals.
We are also concerned about public messaging that suggests the City is reducing design costs and that residents do not need to hire an architect. The first is unproven within the current backlog and process realities. The second is misleading. Architects add measurable value in safety, durability, climate performance, accessibility, construction quality, neighbourly fit, and long term operating cost. Toronto needs design that works on the ground, not just drawings that appear free at first glance.
A better approach is available. The Ulster House project in Harbord Village, led by architects Janna Loritt and Dean Goodman, illustrates how adaptable, people centred design paired with sound project management can deliver practical housing that fits context. The Canada Mortgage and Housing Corporation Design Catalogue work points to a scalable model where templates are starting points, not rigid endpoints. That is the model Toronto should adopt to get real results, faster and without compromising public safety or quality.
Our requests are clear and constructive:
We are ready to meet and help the City implement these changes. This is a solvable problem. Clear roles, accurate public guidance, and a program that treats architects as partners rather than optional add ons will move approvals faster while improving outcomes for residents.
Thank you for your attention. We look forward to a focused discussion on how the RAIC and the City can align to deliver housing solutions that are safe, efficient, and worthy of Toronto.
Sincerely,
Mayor Olivia Chow
Office of the Mayor
City Hall, 100 Queen Street West
Toronto, ON M5H 2N2
Sent via email
Re: Public Statements Regarding Architectural Services and Laneway Housing in the City of Toronto
Dear Mayor Chow,
We recognize the City’s efforts to improve the permit process, which the Toronto Star reported can take on average 24 months, a timeline that is three times longer than comparable jurisdictions in the United States as of August 13, 2025. This focus on improvement is necessary to address Toronto’s housing pressures.
We remain concerned, however, about the City’s communications and program design for the Preapproved Garden and Laneway Suite Plans. The intent to reduce cost and speed approvals is understandable. The current approach undermines that outcome and creates avoidable risk for homeowners and professionals.
Under the Ontario Building Code, architects are not required for residential projects under three storeys and 600 square metres. The City’s free preapproved plans still require a professional stamp from an engineer, an architect, or a BCIN qualified designer to satisfy the application. In practice, the combination of free plans and a stamp requirement, paired with restrictive use conditions, discourages architects from participating. This is not a path to quality or speed. It is a path to confusion and liability gaps.
The program’s requirement that no changes be made to the preapproved plans places the stamping professional in a position of accepting responsibility for work they did not design. That is not compatible with professional liability coverage. It does not reflect how accountable practice works, and it leaves homeowners exposed. In reality, most sites require at least minor adaptation to fit lot conditions, utilities, accessibility, envelope performance, and the Toronto Green Standard. The moment any modification is needed, the preapproval is invalid and time is lost. Even where no modification is requested, the plan must still be verified to fit the lot and comply with the Ontario Building Code. If it does not, homeowners waste time and money and the City absorbs processing cycles that do not advance approvals.
We are also concerned about public messaging that suggests the City is reducing design costs and that residents do not need to hire an architect. The first is unproven within the current backlog and process realities. The second is misleading. Architects add measurable value in safety, durability, climate performance, accessibility, construction quality, neighbourly fit, and long term operating cost. Toronto needs design that works on the ground, not just drawings that appear free at first glance.
A better approach is available. The Ulster House project in Harbord Village, led by architects Janna Loritt and Dean Goodman, illustrates how adaptable, people centred design paired with sound project management can deliver practical housing that fits context. The Canada Mortgage and Housing Corporation Design Catalogue work points to a scalable model where templates are starting points, not rigid endpoints. That is the model Toronto should adopt to get real results, faster and without compromising public safety or quality.
Our requests are clear and constructive:
1. Update public messaging to accurately reflect when professional architectural services add value and to avoid implying they are unnecessary.
2. Revise the preapproved program to allow limited, documented adaptation by an architect of record with clear attribution and responsibility, or provide an alternative pathway where architects can customize City templates without forfeiting eligibility for expedited review.
3. Establish a joint working session between City staff and the RAIC within the next two weeks to align on revisions that protect homeowners, reduce liability ambiguity, and actually shorten cycle times.
4. Launch a pilot in three wards that pairs preapproved templates with an opt in architectural assist, including a short list of firms and community design sessions to fine tune fit, code compliance, and Toronto Green Standard requirements.
5. Publish program metrics quarterly, including time to permit, rework rates, and homeowner satisfaction, so the public can see that approvals are both faster and better.
2. Revise the preapproved program to allow limited, documented adaptation by an architect of record with clear attribution and responsibility, or provide an alternative pathway where architects can customize City templates without forfeiting eligibility for expedited review.
3. Establish a joint working session between City staff and the RAIC within the next two weeks to align on revisions that protect homeowners, reduce liability ambiguity, and actually shorten cycle times.
4. Launch a pilot in three wards that pairs preapproved templates with an opt in architectural assist, including a short list of firms and community design sessions to fine tune fit, code compliance, and Toronto Green Standard requirements.
5. Publish program metrics quarterly, including time to permit, rework rates, and homeowner satisfaction, so the public can see that approvals are both faster and better.
We are ready to meet and help the City implement these changes. This is a solvable problem. Clear roles, accurate public guidance, and a program that treats architects as partners rather than optional add ons will move approvals faster while improving outcomes for residents.
Thank you for your attention. We look forward to a focused discussion on how the RAIC and the City can align to deliver housing solutions that are safe, efficient, and worthy of Toronto.
Sincerely,
| Mike Brennan Chief Executive Officer Royal Architectural Institute of Canada (613)404-2012 mbrennan@raic.org |
Silvio Baldassarra B.Arch, OAA, FRAIC Chair, RAIC Advisors to Professional Practice (RAPP) |