On March 9, 2026, the RAIC received this response from the Office of Mayor Olivia Chow to the RAIC’s previous letter requesting to improve the proposed Preapproved Garden and Laneway Suite Plans.
The RAIC sent the letter below demanding more clarity and accountability on the program.
April 1, 2026
Mayor Olivia Chow
Office of the Mayor
City Hall 100 Queen Street West
Toronto ON M5H 2N2
Sent via email
Re: Pre Approved Laneway and Garden Suite Plans
Dear Mayor Chow, I am writing further to our correspondence of July 10, 2025, and September 29, 2025, and the City’s response dated March 9, 2026, from the Chief Building Official regarding the City’s Pre Approved Garden and Laneway Suite Plans program. The response does not address the central questions raised, nor does it provide the level of transparency expected on a matter of clear public importance. The city continues to distribute and promote pre-approved housing drawings without identifying who authored them, whether a licensed architect was responsible, or how professional accountability is being maintained.
This is not a procedural issue. It goes directly to public confidence, liability, and the integrity of the program. If licensed architects prepared these drawings, that must be clearly stated, including authorship and scope of responsibility. If not, the City must explain how these designs were determined to meet the standards of safety, code compliance, and accountability expected within Ontario’s regulatory framework. Instead, responsibility appears to be shifted to homeowners without clarity on who is accountable for the design itself or how that accountability is sustained once those drawings are applied in real conditions.
This gap is not theoretical. Urban infill housing in Toronto operates within layered conditions of zoning, fire access, servicing, grading, accessibility, and performance requirements that demand site specific resolution. Standardized drawings cannot be separated from these realities, and a professional cannot reasonably assume responsibility for a design they did not author or that cannot be directly applied without modification. Where authorship is unclear and accountability is diffuse, the risk is not only technical, it is systemic.
The response does not address the central issues of the City offering the “Free” Pre Approved Plans for Garden and Laneway Suites which are for Permit and full construction: architectural, structural, mechanical and electrical with specifications to “Homeowners”. Without any regard of site, homeowner needs, material or design requirements or cost for the Homeowner. However, the Program which shifts all liability to the Homeowner specifically prohibits “Any Change” and if there is any change the pre-approve permit process is denied. How is this in the best interest of the Homeowner?
It also raises a broader concern about how housing delivery is being framed. The issue is not solely speed or administrative efficiency. Housing must respond to the expectations now placed on the built environment in Canada. This includes ensuring that development reflects an understanding of place, cultural context, and community relationships, recognizing that even small-scale infill contributes directly to neighbourhood fabric and should be approached with that level of awareness. It also requires that what is built performs over time, not simply at the point of permit approval. Buildings carry long term environmental impact, and housing assessed only against minimum code does not meet the expectation for durable, energy efficient, and climate responsive outcomes that reduce operating costs and improve resilience. In the same way, accessibility must be understood as long term usability and adaptability, supporting aging in place and changing needs, rather than minimum compliance that can quickly become insufficient or require costly retrofits. These expectations are not abstract. They align directly with current federal and provincial priorities, where the emphasis is on delivering housing that is inclusive, resilient, and sustainable, while accelerating supply. The issue is not only how quickly housing is delivered, but how well it performs over time and whether it strengthens or weakens long term public outcomes.
We also note that our request for a direct meeting with your office has not been addressed. Given the public nature of your original comments and the policy implications, this lack of engagement is concerning and does not reflect the seriousness of the issues raised.
The Royal Architectural Institute of Canada is the national voice for architecture and advocates in the public interest for excellence in the built environment. The City’s current approach risks creating confusion about the role of professional design, diminishing accountability, and establishing a precedent that separates housing delivery from the standards expected of it. Accordingly, we request the following:
- Disclosure of who authored the pre-approved drawings and confirmation of
professional responsibility. - Clarification of how liability and accountability are intended to function within
the program. - A meeting with you and senior City leadership within the next 30 days.
- A commitment to ensure public communications accurately reflect the role of
architectural expertise.
Toronto’s housing challenge is urgent.
However, urgency does not justify ambiguity or reduced accountability. It requires clarity, transparency, and a clear commitment to quality in the built environment, both in how housing is delivered and how it performs over time.
We remain ready to meet and resolve this constructively.
Sincerely,
Mike Brennan
Chief Executive Officer
Royal Architectural Institute of Canada
Silvio Baldassarra
B.Arch, OAA, FRAIC
Chair, RAIC Advisors to Professional
Practice (RAPP)
cc
Toronto Chief Building Official
Ontario Association of Architects (OAA)
RAIC Board of Directors
Toronto Society of Architects (TSA)
