Letter to City of Vaughan Council re: Municipal Housing Pledge – March 7, 2023

This letter was submitted to the City of Vaughan’s Committee of the Whole meeting on March 8, 2023, Item #13. For more on the Missing Middle, read my blog post from January 30, 2023.

Implementing the province’s housing pledge must emphasize development that does not encourage sprawl, which would risk placing future financial pressure on the City of Vaughan. This may not be the best path to ensure that individuals of all incomes can call Vaughan home in the future. Thus, I ask that the City of Vaughan develop and implement a missing middle housing policy and action plan, prioritize infill development (including brownfield opportunities), and prioritize infrastructure spending that will not encourage sprawl. The bargain that I propose striking is not building on the Oak Ridges Moraine, Greenbelt and agricultural spaces in exchange for implementing these ideas.

Bill 23

Bill 23, or the More Homes Built Faster Act, incentivizes low-rise construction by reducing the role of conservation authorities (1) and making it easier to build on wetlands (2). It requires municipalities to use development charge (DC) reserve funds for infrastructure that will likely support more sprawling development (3). Future low-rise homes would be more expensive to service than mid and high-rise forms.

The more low-rise developments are built, the more upward pressure on property taxes. The maintenance of on-site infrastructure for these developments is paid for by property taxes. (4) In the long-term You have more kilometres of roads and sidewalks to salt in winter, but lower population densities. Thus, low-rise housing becomes harder to support financially over the long-term. Hence, high-rise condominiums are being built because higher population density yields higher property tax revenues. This helps to pay for services across the city, including low-density areas.

What is the Missing Middle?

Coined by Daniel Parolek, Missing Middle Housing (AKA the missing middle) is defined as “house-scale buildings with multiple units in walkable neighborhoods”. (5) They include duplexes, triplexes, quadplexes, and townhouses. It is the category of housing in between detached homes and mid-rise apartment buildings. (Figure 1) These can be rental or sale units. The City of Toronto has the Expanding Housing Options in Neighbourhoods program and a pilot in the Beaches. (6) The City of Vaughan’s Urban Design Guidelines continues to incorrectly consider the missing middle as mid-rise form (six to twelve stories). Vaughan should redefine the missing middle as housing less than six stories and allow it in low-rise areas called Community Areas, the yellow areas in Figure 2.

Figure 1 – An Illustration of the Missing Middle

Credit: Opticos,2020 via MissingMiddleHousing.com

Figure 2: City of Vaughan Urban Structure Map

Credit: City of Vaughan

Developing and implementing a missing middle housing plan would also address two considerations in the Ministry of Municipal Affairs and Housing’s Info Sheet attached to Item #13, Report #14. Specifically, “Strategies to encourage and promote gentle intensification to enable and expedite additional residential units in existing residential areas”. Following through on a missing middle housing policy and plan requires making it less costly to build multiplexes in existing neighbourhoods. That would satisfy this point in the Info Sheet: “Update zoning by-laws to permit a greater range of housing to be built without the need for costly and lengthy rezoning applications.”

The Missing Middle’s Use of Existing Infrastructure

A major benefit to Missing Middle Housing is that it takes advantage of existing infrastructure. Such compact development is more cost-effective (cheaper) to service than greenfield development over the long-term. (7) The City of Vaughan can mitigate the increasing costs of servicing new sewers, streetlights and parks by prioritizing construction in low-rise neighbourhoods to support the missing middle. This would help address the Director, Policy Planning and Special Programs’ concern on Section 6)a) (p.5) of her report (Item #13, Report #14) regarding additional servicing capacities required to meet the new housing target. Many properties in Vaughan’s low-rise neighbourhoods (Community Areas) are on sizeable lots with large setbacks (space between the sidewalk and the garage). These lots can support a duplex, triplex or quadplex’s square footage.

The Missing Middle’s Environmental Benefits

Building Missing Middle housing would put less development pressure on the Greenbelt and Vaughan’s increasingly scarce farmland. Since 2020, the fragility and costs of global food supply chains have been exposed. Restaurants like Toronto’s Momofuku location have prioritized sourcing locally. (8) Southern Ontario has some of Canada’s most fertile farmland, which includes Vaughan. See area to the north in Figure 2. Plus, one of the Greenbelt’s main goals is to protect farmland. (9) Proximity to urban areas also provides farms with opportunities to specialize and – potentially – thrive. (10) Allowing for duplexes, triplexes and quadplexes to be built in Vaughan’s existing neighbourhoods avoids having to build on the Greenbelt, the Oak Ridges Moraine and helps to preserve farmland. It also weakens the case for the proposed Highway 413.

The Missing Middle in Vaughan

The missing middle in Vaughan’s neighbourhoods would provide housing options for many situations. Elderly parents who want to downsize and live independently while being close to their families. People who do not want to have the carrying costs of homeownership, but still live in a (sub)urban area with proximity to amenities.

The missing middle could inject new life into neighbourhoods as it opens up who can afford to live in them. Small neighbourhood retailers would have new customers. Public transit would see higher ridership. Libraries and recreation services may have more usage, which translates into higher user fees revenues for the city.

I would advise consulting citizens about a missing middle housing policy and action plan. There are single-detached homes that are rented out to families and already represent hidden density in Community Areas. These homes should not be destroyed to make way for multiplexes that are do not provide affordable rental. This has been a criticism of the City of Vancouver’s missing middle program in existing neighbourhoods. (11) Vaughan’s missing middle housing policy should be designed in such a way that provides affordable rental units and opens up Community Areas (Figure 2) to those who cannot afford to buy there. 

Affordable Rental Housing Requirement in Mid-Rise and High-Rise

The City of Vaughan should follow the City of Toronto’s lead and implement a minimum percentage requirement of affordable rental units in new-build mid-rise and high-rise condominium buildings. This opens up who can afford to live in these buildings. It also ensures that mixed-income communities exist across the city. Bill 23 would help to facilitate this as it exempts affordable housing and inclusionary zoning units from DC, CBCs and parkland dedication. (12) What is the status of Vaughan’s Affordable Housing and Inclusionary Zoning policies?

City of Vaughan Housing Pledge

The “Completion of Secondary Plans for Key Areas of Growth” is noted in this document. What about area-specific policies? The City of Vaughan’s Official Plan includes a Dufferin Centre area-specific policy. However, I am unaware of the status of this policy or if there are opportunities for public consultation.

Brownfield Developments

The City should prioritize brownfield developments in lieu of greenfield ones. I am aware of certain brownfield remediation projects, e.g. northwest corner of Jane St. and Highway 7. However, Vaughan can look to the City of Hamilton’s ERASE Redevelopment Grant Program (ERG) as a model for brownfield development. (13)

A missing middle housing policy would help to make Vaughan open to individuals of all incomes. Instead of many young people and families being unable to afford living here, it would provide new housing options for them. Therefore, I call on the City of Vaughan to prioritize building housing through infill opportunities, including the missing middle. In the long-term, this will be a more financially sustainable growth strategy than encouraging sprawl. This would also mean not building in the Oak Ridges Moraine, the Greenbelt or in agricultural areas.



(1) https://www.osler.com/en/resources/regulations/2022/bill-23-more-homes-built-faster-act-2022-passed%E2%80%A6-fast

(2) https://ero.ontario.ca/notice/019-6160

(3) https://www.ola.org/en/legislative-business/bills/parliament-43/session-1/bill-23

(4) NRU TORONTO, Oct. 26, 2022

(5) https://missingmiddlehousing.com/about

(6) https://www.toronto.ca/city-government/planning-development/planning-studies-initiatives/expanding-housing-options/

(7) https://assets.nationbuilder.com/greenbelt/pages/14845/attachments/original/1666021200/GB_MunicipalFinancesandGrowth_REPORT_2022_E-ver.pdf?1666021200, p.27; https://www.planetizen.com/definition/greenfield-development

(8) https://www.theglobeandmail.com/business/article-amid-supply-chain-disruptions-canadian-restaurateurs-turn-local/


(10) Deaton, B. James, and Richard J. Vyn. “The Effect of Strict Agricultural Zoning on Agricultural Land Values: The Case of Ontario’s Greenbelt.” American Journal of Agricultural Economics 92, no. 4 (2010): 941–55. https://doi.org/10.1093/ajae/aap022.

(11) https://www.theglobeandmail.com/real-estate/vancouver/article-single-family-houses-multifamily-homes/

(12) https://www.osler.com/en/resources/regulations/2022/bill-23-more-homes-built-faster-act-2022-passed%E2%80%A6-fast

(13) https://investinhamilton.ca/tools-data/financial-incentives/municipal-programs/erase-redevelopment-grant-program/

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