July 9, 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,
On behalf of the Royal Architectural Institute of Canada (RAIC), we are reaching out to express a sincere interest in learning more about the City of Toronto’s initiative to offer free design plans for garden and laneway suites. We recognize and support the City's goal of increasing housing access and affordability, and we are eager to better understand the approach and its implementation.
We noted your recent remarks suggesting that an architect or planner may not be necessary for these types of projects. While this may reflect a desire to streamline delivery and improve access, we would appreciate the opportunity to understand more about the guiding principles, the consultation process, and how design expertise was considered in this context.
Regulatory Requirements and Liability Concerns
Under Ontario law, certain infill conditions, fire access issues and accessibility considerations can require architectural involvement. Even when those thresholds are not required, municipalities routinely require stamped drawings from licensed professionals during permitting.
Encouraging homeowners to bypass architectural oversight may inadvertently place them in violation of these laws and expose them to liability. It also signals that design expertise, the very thing that ensures safety, performance and resilience, is unnecessary. That message is not just wrong, it is dangerous.
Without proper professional oversight:
Professional Standards and Public Safety
Architects do not merely draw plans. They are accountable professionals governed by their provincial and/or territorial licensing authority and in this case the Ontario Association of Architects (OAA). They are trained, regulated, and continuously educated to safeguard the public by ensuring compliance with zoning bylaws, fire safety, building code requirements, energy performance, and accessibility.
In fact, combined firms offering both engineering and architectural services must be majority-controlled by licensed architects to legally provide architectural services. This division of professional scope is not arbitrary; it is embedded in Ontario’s regulatory regime to protect public safety and ensure accountability.
Architects as Housing Enablers
Architects are not a barrier to housing supply. They are a critical part of delivering it properly. The 2024 Altus Group report prepared for the OAA found that Ontario’s site plan delays cost the economy 3.5 billion dollars annually. The delays stem not from architects but from inefficient municipal processes.
In our experience, architects support timely and efficient housing delivery by designing solutions that are ready to build, adaptive to constraints, and responsive to evolving needs. Especially in contexts like laneway and garden suites, architects help navigate site-specific conditions, technical challenges, and the relationship between private and public space. They are vital in adapting plans to irregular lot lines, servicing constraints tree protection zones, accessibility standards, fire access and more.
Their involvement often improves outcomes through thoughtful planning, integration of sustainability goals, attention to human experience, and consideration for long-term maintenance and quality. Their collaborative, problem-solving approach is well suited to complementing municipal programs like this.
Request for Clarification
Given the City’s promotion of free designs for laneway and garden suites we formally request that you clarify the following.
A Collaborative Path Forward
The RAIC respectfully asks that your office and the City of Toronto:
Toronto’s housing needs are real and urgent and as a comparable example, the Canada Mortgage and Housing Corporation’s Design Catalogue initiative may be of interest. This program brought together architectural expertise to develop a curated set of adaptable housing designs. It offers a model for how municipalities can leverage professional input while offering accessible design resources to the public.
The RAIC supports solutions that are both responsive and responsible, and that recognize the role of design professionals as allies in building inclusive, resilient, and vibrant communities.
We would highly encourage and welcome a conversation with you and your office to learn more and explore how the architectural profession can support future initiatives aligned with the City’s housing goals.
Sincerely,
Cc
Ontario Association of Architects (OAA)
Toronto Society of Architects (TSA)
Toronto Chief Building Official
City Planning Division, City of Toronto
RAIC Board of Directors
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,
On behalf of the Royal Architectural Institute of Canada (RAIC), we are reaching out to express a sincere interest in learning more about the City of Toronto’s initiative to offer free design plans for garden and laneway suites. We recognize and support the City's goal of increasing housing access and affordability, and we are eager to better understand the approach and its implementation.
We noted your recent remarks suggesting that an architect or planner may not be necessary for these types of projects. While this may reflect a desire to streamline delivery and improve access, we would appreciate the opportunity to understand more about the guiding principles, the consultation process, and how design expertise was considered in this context.
Regulatory Requirements and Liability Concerns
Under Ontario law, certain infill conditions, fire access issues and accessibility considerations can require architectural involvement. Even when those thresholds are not required, municipalities routinely require stamped drawings from licensed professionals during permitting.
Encouraging homeowners to bypass architectural oversight may inadvertently place them in violation of these laws and expose them to liability. It also signals that design expertise, the very thing that ensures safety, performance and resilience, is unnecessary. That message is not just wrong, it is dangerous.
Without proper professional oversight:
- Homeowners risk code violations and costly rework
- Municipalities are exposed to legal liability for approving flawed plans
- Neighbouring properties may face safety or servicing issues
- The broader housing system absorbs the cost of non-compliant or unsafe dwellings
Professional Standards and Public Safety
Architects do not merely draw plans. They are accountable professionals governed by their provincial and/or territorial licensing authority and in this case the Ontario Association of Architects (OAA). They are trained, regulated, and continuously educated to safeguard the public by ensuring compliance with zoning bylaws, fire safety, building code requirements, energy performance, and accessibility.
In fact, combined firms offering both engineering and architectural services must be majority-controlled by licensed architects to legally provide architectural services. This division of professional scope is not arbitrary; it is embedded in Ontario’s regulatory regime to protect public safety and ensure accountability.
Architects as Housing Enablers
Architects are not a barrier to housing supply. They are a critical part of delivering it properly. The 2024 Altus Group report prepared for the OAA found that Ontario’s site plan delays cost the economy 3.5 billion dollars annually. The delays stem not from architects but from inefficient municipal processes.
In our experience, architects support timely and efficient housing delivery by designing solutions that are ready to build, adaptive to constraints, and responsive to evolving needs. Especially in contexts like laneway and garden suites, architects help navigate site-specific conditions, technical challenges, and the relationship between private and public space. They are vital in adapting plans to irregular lot lines, servicing constraints tree protection zones, accessibility standards, fire access and more.
Their involvement often improves outcomes through thoughtful planning, integration of sustainability goals, attention to human experience, and consideration for long-term maintenance and quality. Their collaborative, problem-solving approach is well suited to complementing municipal programs like this.
Request for Clarification
Given the City’s promotion of free designs for laneway and garden suites we formally request that you clarify the following.
- Who prepared the drawings released to the public?
- If architectural services were involved, please confirm the name, license number, and scope of the professional involvement.
- If not, please explain how these drawings were deemed code compliant legally valid and suitable for public use.
- How will the City support homeowners in adapting the designs to fit individual lot conditions and neighborhood contexts?
- What consultation process was undertaken in developing this initiative?
A Collaborative Path Forward
The RAIC respectfully asks that your office and the City of Toronto:
- Publicly clarify your statement including the circumstances where an architect is required under law and the risks of bypassing professional design.
- Revise all City communications on the laneway and garden suite program to include appropriate legal disclaimers and clear direction about when architectural services are required.
- Engage directly with the RAIC and the OAA to ensure future housing initiatives reflect legal requirements, uphold public safety, and harness professional design expertise to meet Toronto’s housing goals.
Toronto’s housing needs are real and urgent and as a comparable example, the Canada Mortgage and Housing Corporation’s Design Catalogue initiative may be of interest. This program brought together architectural expertise to develop a curated set of adaptable housing designs. It offers a model for how municipalities can leverage professional input while offering accessible design resources to the public.
The RAIC supports solutions that are both responsive and responsible, and that recognize the role of design professionals as allies in building inclusive, resilient, and vibrant communities.
We would highly encourage and welcome a conversation with you and your office to learn more and explore how the architectural profession can support future initiatives aligned with the City’s housing goals.
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) |
Ontario Association of Architects (OAA)
Toronto Society of Architects (TSA)
Toronto Chief Building Official
City Planning Division, City of Toronto
RAIC Board of Directors