H O U S I N G

I S S U E S
R E P O R T
55 & 61-63 CHARLES
STREET EAST
CITY OF TORONTO

P R E PA R E D F O R : April
M OD D E V E L O P M E N T S 2018
(C H A R L E S ) LP
 TA B L E O F C O N T E N T S
[ 1 .0 ] I N TR OD U C T I O N 1
[ 2 .0 ] E X I ST I NG R ENTAL B U I L D I NG S 3
[ 3 .0 ]P R O POSAL 5
[ 4 .0 ] A P P LI C A B L E P O L I CY A N D
R E G U L ATO RY CO NT EX T 8
4.1 PROVINCIAL POLICIES 8
4.2 TORONTO OFFICIAL PLAN 9
4.6 ZONING 10
Zoning By-law 438-86 10
Zoning By-law 569-2013 10

[ 5 . 0 ] A N A LY S I S AND O PI NI O N 1 1
5.1 G E N E R A L A N A LY S I S 11

T OC 5.2 A N A LY S I S O F P O L I C Y 3 . 2 . 1 ( 6 )
Policy 3.2.1(6)(a): Analysis of Unit Affordability
Policy 3.2.1(6)(b): Rental Replacement
11
11
13
Te n a n t R e l o c a t i o n a n d A s s i s t a n c e 15

[ 6 .0 ] CO N C LU S I O N 1 6
A P P E N D I X A: MEASURED DRAWINGS A1
 [1.0]
I N T R O D U C T I O N
This Housing Issues Report has been prepared in support of an application by MOD
Developments (Charles) LP (“MOD”) to amend the City of Toronto Zoning By-law
438-86, as amended, and the new City- Zoning By-law 569-2013, as amended, with
respect to lands located on the south side of Charles Street East, just west of Church
Street and approximately 200 metres east of Yonge Street, municipally known as 55
and 61-63 Charles Street East (the “subject site”) (See Figure 1).

The subject site is an assembly of two properties which are currently developed with
residential apartment buildings. 55 Charles Street East is developed with a 9-storey
rental apartment building known as ‘The Charlesview’. This building contains 76
residential units, with 38 parking spaces provided in an underground parking
garage and 17 surface parking spaces. 61-63 Charles Street East is developed with a
3-storey rental walk-up apartment building known as ‘Star Mansions’. This building
contains 24 residential units and no parking. MOD is proposing to redevelop the
subject site with a 55-storey mixed-use building, including 648 residential units. Of
the proposed units, 100 will be rental units to replace those that currently exist on
the subject site (the “proposal”).

BLOOR ST E
SUBJECT
SITE
RD
S A NT
LEA
P
MT

CHARLES ST E

MACY DUBOIS LN

ISABELLA ST
CHURCH ST

JARVIS ST
YONGE ST
BAY ST

Figure 1 - Aerial of Subject Site and Surrounding Area

HOUSING ISSUES REPORT

55 & 61-63 CHARLES STREET EAST 1
 Section 111 of the City of Toronto Act gives the City authority to protect rental
housing in the city. In accordance with the provisions in that Section, the City of
Toronto prohibits the demolition and conversion of any rental housing on properties
that contain six or more related units, unless a permit has been issued under
Chapter 667 of the Municipal Code. As the proposal will result in the demolition of
all 100 existing rental units on the subject site, a Request for Rental Demolition and
Conversion application under Section 111 of the City of Toronto Act is being submitted
concurrently with the rezoning application for the subject site.

Additional housing policies are set out in the City of Toronto Official Plan (the
“Official Plan”) which apply to the proposal. Policy 3.2.1(5) relates to significant new
development on sites containing six or more rental units, where existing rental units
will be retained and Policy 3.2.1(6) applies when new development would have the
effect of removing all or part of a private building(s) resulting in the lot of six or more
rental units. For the purposes of the proposal, only Policy 3.2.1(6) is applicable.

This purpose of this Housing Issues Report is to provide information regarding the
existing rental units on the subject site and to evaluate the proposal against Section
111 of the City of Toronto Act and the housing policies of the Toronto Official Plan. In
our opinion, the proposal meets the applicable requirements.

2
 [2.0]
E X I S T I N G R E N T A L B U I L D I N G S
As noted, the subject site is currently occupied by the building. This underground parking level
two rental apartment buildings: 55 Charles Street contains 38 parking spaces. There are 17
East and 61-63 Charles Street East. A further surface parking spaces on the property, for a
description of each building is provided below: total of 56 parking spaces.

• 55 Charles Street East is a 9-storey Beyond the open space located at the front of
rental apartment building known as ‘The the building and the lobby and laundry room
Charlesview’. This building was constructed located on the first floor, there is no further
in the late 1950’s and although it was formal indoor or outdoor amenity space
originally designed with 75 units, currently associated with this building.
contains 76 residential units. The current
unit mix of this building includes 17 bachelor • 61-63 Charles Street East is a 3-storey rental
units and 59 one-bedroom units. Overall, the walk-up apartment building known as ‘Star
existing building has a gross floor area of Mansions’ that was designed by architect
approximately 5,150 square metres and a lot Herbert C. Roberts and was constructed
coverage of approximately 50 percent. in 1931. This building currently contains 24
residential units and the unit mix includes
At grade, the existing building at 55 Charles 5 bachelor units, 15 one-bedroom units
Street East is setback approximately 6.7 and 4 two-bedroom units. Overall, the
metres from the north property line, with the existing building has a gross floor area of
space between the street and the building approximately 1,543 square metres and a lot
façade provided as landscaped open space. coverage of approximately 67 percent.
This open space features two mature trees,
various shrubs and planting beds and a At grade, the existing building at 61-63
wide walkway to the building entrance. The Charles Street East is setback approximately
first floor of the building contains the main 4.9 metres from the north property line. The
entrance and lobby, as well as a mail room to area between the building façade and the
the immediate left of the main entrance, and a street is provided as open space with minimal
laundry room off a corridor to the right of the landscaping and a pathway connecting the
residential lobby. There are three residential front entrance to the sidewalk. This area
units located on the ground floor, as well as a contains three trees near the streetline and
large locker/storage room at the rear of the some small shrubs directly abutting the
building. façade of the building. The first floor of the
building contains the main entrance and
Along the west side of the existing building residential lobby and is otherwise made up of
at 55 Charles Street East is a driveway that residential units.
provides access to a small parking area at
the rear of the building. This driveway is There are no parking spaces located at-
connected to Macy DuBois Lane, which runs grade or underground in association with
east-west along the rear of 45, 55, and 61-63 the existing building at 61-63 Charles Street
Charles Street East. Along the east side of the East. In addition, there are no formal indoor
building is a ramp that provides access to the or outdoor amenity spaces associated with
one-level of underground parking that serves this building.

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55 & 61-63 CHARLES STREET EAST 3
 Measured drawings of the units comprising 55 Charles Street East and the first two
floors comprising 61-63 Charles Street East are provided in Appendix A to this report.
Measured drawings of the third floor of 61-63 Charles Street East are currently being
prepared and will be submitted for consideration as part of this application under
separate cover in the near future.

Table 1 below summarizes the unit mix of the existing residential buildings on the
subject site. Greater detail on the subject site and its surroundings is included in our
Planning and Urban Design Rationale (submitted under the same cover).
Table 1 - Existing Unit Mix at 55 and 61- 63 Chales Street East

Unit Type 55 Charles Street East 61-63 Charles Street East

Bachelor 17 5
1-bedroom apartment 59 15
2-bedroom apartment 0 4
Total 76 24

4
 [3.0]
PROPOSAL
The proposal is for a 55-storey residential building consisting of a 6-storey podium
base building and a 49-storey tower element above. The building will be 169.25
metres tall, excluding the mechanical penthouse, and has a total gross floor area
of 44,073 square metres, of which 43,756 square meters is residential. At grade,
317 square metres of non-residential gross floor area is proposed in the form of a
community space. The proposed overall density is 19.30 FSI.

A total of 648 residential units are proposed, 100 of which are rental units which
replace the same number of rental units currently on the subject site. Additionally,
seven 2-storey grade-related townhouses units are located along the portion of the
podium base, accessed by a walkway connected to the Charles Street public sidewalk.
These townhouses are a mix of two- and three-bedroom units. The intent is that the
community space noted above and some of the residential condominium units be
provided in conjunction with a future non-profit entity. The amount and types of
units associated with the future non-profit entity are subject to further discussion
with the Ward 27 Councillor and City Planning Staff as part of the potential Section
37 agreement associated with the rezoning application being submitted to permit
the proposal.

The unit mix for the condominium component of the proposal comprises 66 studio
units (12%), 291 one-bedroom units (53%), 128 two-bedroom units (23%) and 63
three-bedroom units (11%). The condominium units will be located on Levels 8
through 55 in the tower element. The unit mix for the rental replacement component
of the proposal is generally similar to the rental unit mix that currently exists on the
subject site. In this regard, the proposed rental replacement includes: 20 bachelor
units (20%), 75 one-bedroom units (75%) and 5 two-bedroom units (5%). The rental
replacement units will be located on Levels 2 through 6 within the base building,
along with rental-related amenity space, which includes storage lockers and laundry
and lounge facilities. It is intended that the 100 rental replacement units will form
a separate condominium corporation owned by the owner/operators of the two
existing apartment buildings on the subject site. Rental replacement units will
feature air-conditioning and barrier-free layouts.

The residential entrance to the building is located at the north end of the building
and is directly accessible and visible from the public sidewalk. The double-height
lobby, which is shared by rental and condominium residents, is glazed along its north
wall, creating an inviting and transparent relationship with the street and providing
views into and from the lobby space. New trees and landscaped areas will flank the
entrance doors to the residential lobby within the Charles Street public realm. At the
northeast corner of the building is a grade-related, double-height Community Space
with an area of 317 square metres and an entrance that is clearly visible and directly
accessible from the public sidewalk along Charles Street East. This community

HOUSING ISSUES REPORT

55 & 61-63 CHARLES STREET EAST 5
 space is potentially to be affiliated with a future non-profit entity. The space is non-
residential in nature and is intended to be a public benefit, supportive of community-
related programming that has yet to be determined.

The indoor amenity space provided totals 938 square metres and consists of a meeting
room, media room, lounges, party room with kitchen and gym. 358 square metres of
indoor amenity space is also provided for the rental component, comprising storage
lockers and a laundry facility. Indoor amenity spaces for rental units are located on
Levels 2 through 7. The provided outdoor amenity space, which is shared by both
condominium and rental residents, totals 855 square metres and includes a roof
garden, barbeque and dining area and several outdoor lounge areas. The outdoor
amenity space wraps entirely around the indoor amenity space located on Level 7.
With respect to private outdoor space, the majority of rental and condominium units
have access to private patios, terraces or balconies from each unit.

Vehicular access to the proposed parking and loading spaces will be provided from
Macy Dubois Lane, off of Charles Street East. A two-way ramp will be located at the
south end of the building, running in a north-south direction and leading to four
levels of underground parking. The underground parking garage will include 154
parking spaces. Of these parking spaces, 130 will be for residents at a rate of 0.20
spaces per unit, two will be for car-share and 22 will be for building visitors at a rate
of 0.035 spaces per unit. The visitor parking spaces are planned to be operated as
a commercial parking garage located on levels P1 and P2. The two car-share spaces
will be located on level P1 and parking for residents will be located on levels P2
through P4. A total of 649 bicycle parking spaces are proposed at a rate of 1.0 per
unit, including 584 spaces for residents, located on levels P1 through P4, and 65
spaces for visitors, located on level P1.

6
Figure 2 - Site Plan (Source architectsAlliance)

HOUSING ISSUES REPORT

55 & 61-63 CHARLES STREET EAST 7
 [4.0]
A P P L I C A B L E P O L I C Y
A N D R E G U L A T O R Y
C O N T E X T
This Housing Issues Report outlines the applicable housing policies that apply to
the proposal. Further policy detail is included in our Planning and Urban Design
Rationale.

4.1 Provincial Policies

The 2014 PPS provides overall policy direction on matters of provincial interest
relating to land use planning and development. The PPS is intended to promote
efficient development and land use patterns to support strong communities, to
protect the environment and public health and safety, and promote a strong economy.
With respect to housing, Policy 1.4.3 of the PPS requires provision to be made for
an appropriate range and mix of housing types and densities to meet projected
requirements of current and future residents by, among other matters, permitting
and facilitating all forms of residential intensification and redevelopment, promoting
densities for new housing which efficiently use land, resources, infrastructure and
public service facilities and support the use of alternative transportation modes and
public transit.

The Growth Plan for the Greater Golden Horseshoe (the “Growth Plan”) came into
effect on July 1, 2017 and any municipal decisions made after this date will need to
conform with this new plan. The subject site is within a Strategic Growth Area as
defined by the Growth Plan, due to its location within the Downtown Toronto Urban
Growth Centre and within a Major Transit Station Area (i.e. located within 400 metres
radial distance of the Bloor-Yonge subway station).

Section 2.2.6 of the Growth Plan (2017) sets out the housing policies. Policy 2.2.6(1)
directs municipalities to develop housing strategies that support the achievement of
minimum intensification and density targets by identifying a diverse range and mix
of housing options and densities and establishing targets for affordable ownership
housing and affordable rental housing. Policy 2.2.6(2) provides that notwithstanding
Policy 1.4.1 of the PPS, municipalities will support the achievement of complete
communities by planning to accommodate forecasted growth, achieving the
minimum intensification and density targets, considering a range and mix of housing
options and densities, and planning to diversify overall housing stock across the
municipality. In accordance with Policy 2.2.6(3), municipalities are to consider using
available tools to require that multi-unit residential developments incorporate a mix
of unit sizes to accommodate a diverse range of household sizes and incomes.

8
4.2 Toronto Official Plan
With respect to the City of Toronto Official Plan, the subject site is designated Mixed
Use Areas on Land Use Map 18. The policies set out in Section 4.5 of the Official Plan
recognize that Mixed Use Areas will absorb most of the anticipated increase in retail,
office and service employment in Toronto in the coming decade, as well as much of
the new housing. Development proposals in Mixed Use Areas are subject to a series
of development criteria set out in Policy 4.5(2).

Section 3.2.1 of the Official Plan contains a number of policies related to the provision
of housing, in particular, the need to establish a healthy balance between high rise
ownership housing and other forms of housing, including purpose-built rental
housing, affordable rental housing and affordable low-rise ownership housing for
large households with children and multi-family households. The housing policies
relevant to the subject site and the proposal are as follows:
• Policy 3.2.1(1) provides that a full range of housing in terms of form, tenure and affordability
will be provided to meet the current and future needs of residents. A full range of housing
includes: ownership and rental housing, affordable and mid-range rental and ownership
housing, social housing, shared and/or congregate-living housing arrangements,
supportive housing, emergency and transitional housing for homeless people and at-risk
groups, housing that meets the needs of people with physical disabilities and housing
that makes more efficient use of the existing housing stock.
• Policy 3.2.1(2) indicates that the existing housing stock will be maintained and replenished.
New housing supply will be encouraged through intensification and infill that is consistent
with the Official Plan.
• Policy 3.2.1(5) provides that significant new development on sites containing six or more
rental units, where existing rental units will be kept in the new development will secure as
rental housing, the existing rental units which have affordable rents and mid-range rents,
and may secure any needed improvements or renovations required to the existing rental
housing, without pass-through of such costs in the rents to the tenants.
• Policy 3.2.1(6) provides that new development that would have the effect of removing all
or part of a private building or related group of buildings, and would result in the loss of
six or more rental housing units will not be approved unless:
a. all of the rental housing units have rents that exceed mid-range rents at the time of
the application; or
b. in cases where planning approvals other than site plan are sought, the following are
secured:
i. at least the same number, size and type of rental housing units are replaced and
maintained with rents similar to those in effect at the time the redevelopment
application is made;
ii. for a period of at least 10 years, rents for replacement units will be the rent at
first occupancy increased annually by not more than the Provincial Rent Increase
Guideline or a similar guideline as Council may approve from time to time; and
iii. an acceptable tenant relocation and assistance plan addressing the right to
return to occupy one of the replacement units at similar rents, the provision
of alternative accommodation at similar rents, and other assistance to lessen
hardship, or
c. in Council’s opinion, the supply and availability of rental housing in the City has
returned to a healthy state and is able to meet the housing requirements of current
and future residents, based on a number of factors.

As discussed in detail in Section 5.0 below, it is our opinion that the proposal
conforms to the applicable Official Plan housing policies.

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55 & 61-63 CHARLES STREET EAST 9
 4.6 Zoning
The in-force Zoning By-law applying to the site is By-law 438-86, as amended, of
the former City of Toronto. The new City-wide Zoning By-law 569-2013 was enacted
by City Council on May 9, 2013. However, By-law 569-2013 is subject to numerous
appeals to the Ontario Municipal Board and is therefore not yet in force.

Z O N I N G B Y- L AW 4 3 8 - 8 6
In-force Zoning By-law 438-86, as amended, designates the subject site CR T2.0 C1.0
R2.0 subject to a maximum height of 30.0 metres and a maximum overall density
of 2.0 FSI. The CR zone permits a broad range of commercial and residential uses;
however non-residential uses are restricted to 1.0 FSI and residential uses restricted
to 2.0 FSI on the subject site.

Z O N I N G B Y- L AW 5 6 9 - 2 0 1 3
Under the new city-wide Zoning By-law 569-2013, the subject site is designated CR
2.0 (c1.0; r2.0) SS1 (x1454), which is effectively an updated version of the zoning
regulations contained within the former City of Toronto Zoning By-law 438-86.
Similar restrictions in terms of maximum height and density are provided, with a
height limit of 30.0 metres and a maximum density permission of 2.0 FSI.

10
 [5.0]
A N A L Y S I S A N D O P I N I O N
5.1 General Analysis
The proposal is supportive of the policy directions set out in the Provincial Policy
Statement 2014, the Growth Plan for the Greater Golden 2017 and the City of
Toronto Official Plan, as it will provide a range of unit sizes at a density similar to the
surrounding area in Downtown Toronto and will add to the overall stock of housing in
the City. The 1 to 1 rental replacement included in the proposal will ensure there will
be no net loss of rental units in the neighbourhood.

The proposal conforms to Section 3.2.1 of the Official Plan as the proposal will
contribute to a range of housing in terms of both form and tenure. Although the
redevelopment will have the effect of completely removing the existing rental
apartment buildings on the subject site, it is our opinion that the proposal is in
keeping with Policy 3.2.1(2), as the new building will include both rental replacement
units (100 units) as well as 548 new condominium units, thereby maintaining and
replenishing housing stock in the City. In terms of Policy 3.2.1(5), we have determined
that the proposal is not subject to this policy, as none of the existing rental units will
be kept in the new development. Further analysis on the proposal’s conformity with
Policy 3.2.1(6) is set out below.

5.2 Analysis of Policy 3.2.1(6)

P O L I CY 3 . 2 . 1 ( 6 ) ( A ) : A N A LYS I S O F U N I T
AFFORDABILITY
As indicated in Section 4 of this report, Policy 3.2.1(6)(a), provides that new
development that would have the effect of removing all or a part of a private building
or related group of buildings and would result in the loss of six or more rental
housing units, will not be approved unless all of the rental housing units have rents
that exceed mid-range rents at the time of the application.

The Official Plan defines “affordable rents” as housing where the total monthly
shelter cost (gross monthly rent including utilities but excluding parking and cable
television charges) is at or below one times the average City of Toronto rent, by unit
type, as reported annually by the Canada Mortgage and Housing Corporation. “Mid-
range rents” is housing where the total monthly shelter costs exceed affordable
rents but fall below one and one-half times the average City of Toronto rent. “High-
end rent” is housing where the total month shelter cost exceeds the mid-range
threshold. The applicable 2018 rent limits by relevant unit type are included in Table
2.

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55 & 61-63 CHARLES STREET EAST 11
 Table 2 - 2018 Average Rent Thresholds

Unit Type Affordable Rent Mid-Range Rent

Bachelor $1,019 $1,528
1-bedroom apartment $1,202 $1,802
2-bedroom apartment $1,426 $2,138

The current unit affordability analysis for the rental apartment buildings on the
subject site is set out in a separate confidential enclosure. The analysis is based on
the April 2018 rent rolls for each building (also included in the confidential enclosure).
Tenants pay separate rates for parking spaces and cable internet (if desired), and
this cost has not been added to the gross monthly rent. In terms of utilities, water
and gas costs are currently incorporated within the monthly rent paid by the tenants
and hydro costs are currently paid separately by each tenant directly to the hydro
provider. As gross monthly rent is to be inclusive of all utility costs, in the case of 55
Charles Street East the rents for all tenants have been adjusted to reflect an average
of the actual monthly hydro cost for each unit type in March 2018, and in the case of
61-63 Charles Street East the rents for all tenants have been adjusted based on an
estimated monthly hydro cost based on a sample hydro bill provided for each unit
type within the building.

As of April 1, 2018, there were four vacancies in the apartment building at 55 Charles
Street East (1 bachelor unit and 3 one-bedroom units) and no vacancies in the building
at 61-63 Charles Street East. In terms of staff occupied units, there is one unit at 61-
63 Charles Street East that is occupied by staff (a two-bedroom unit) and one unit
at 55 Charles Street East that is occupied by staff (a one-bedroom unit) with one
bachelor unit at 55 Charles Street East being utilized as a building office. In addition,
there is 1 one-bedroom unit at 55 Charles Street East that is currently rented as
a commercial office (unit 104). However, as this unit was previously renovated to
function as a rental dwelling unit, it has been included in the rental unit count and
considered for replacement.

A summary of the affordability analysis is set out in Table 3 below. In total, inclusive of
vacancies and staff occupied units (see further details below), there are 3 affordable
units and 97 mid-range units between the two existing apartment buildings, all of
which will be removed as part of the proposed development. There are no existing
high-end units in either of the buildings on the subject site.
Table 3 - Summar y of Rents at 55 and 61- 63 Charles Street East (April 2017)

Affordable Mid-Range
Unit Type High End Units
Units Units
55 Charles Street East
Bachelor unit 0 17 0
1-bedroom unit 2 57 0
2-bedroom unit 0 0 0
Total 2 74 0

12
 Affordable Mid-Range
Unit Type High End Units
Units Units
61-63 Charles Street East
Bachelor unit 0 5 0
1-bedroom unit 1 14 0
2-bedroom unit 0 4 0
Total 1 23 0
Overall Total 3 97 0

As previously mentioned, there are currently four vacancies in the apartment building
at 55 Charles Street East (1 bachelor unit and 3 one-bedroom units) and no vacancies
in the building at 61-63 Charles Street East. In addition, there is one unit in 61-63
Charles Street East that is occupied by staff (a two bedroom unit) and there are two
units at 55 Charles Street East that are utilized for staff/office purposes (1 bachelor
unit and 1 one-bedroom unit). In most cases, there is no rent data available for each
of these vacant/staff units, and as a result, their affordability was determined based
on an evaluation of the relationship between unit type and size, and the analysis
completed for the rents for occupied units in each building. Excluding the units with
unknown rents, approximately 97% of the units in 55 Charles Street East and 96%
of the units in 61-63 Charles Street East were classified as mid-range, with only 3%
and 4% respectively classified as affordable. Given this consideration and the fact
that the sizes of the unknown units were generally consistent with those of mid-
range classified units for each unit size in each building, it is our opinion that it is
reasonable to classify these unknown units as mid-range.

As set out above, as none of the units on the subject site are high end the requirement
set out in Policy 3.2.1(6)(a) has not been met. Accordingly, the following section
will evaluate the proposal against Policy 3.2.1(6)(b) to determine if the alternate
requirement set out therein has been achieved.

P O L I CY 3. 2 . 1 (6) ( B) : R E N TA L R E P L AC E M E N T
Where new development will result in the loss of six or more rental housing units that
are available at affordable or mid-range rents at the time of application, and in cases
where planning approvals other than site plan area sought, Policy 3.2.1(6)(b) requires
the replacement of existing rental units with “at least the same number, size and
type” of rental housing units. In considering the intent of this policy, it is observed
that there is no definition of either “size” of “type”. However, based on a full reading
of the Official Plan and an understanding of how the policy has been applied in the
past, the terms should be understood as follows:
“Size” refers to the actual square footage of the units, but with reasonable
allowances to take into consideration modern design efficiencies.
“Type” refers to the number of bedrooms, rather than to building form. In
the definition of “affordable rents”, the Plan refers to “unit types (number
of bedrooms)”.

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55 & 61-63 CHARLES STREET EAST 13
 Policy 3.2.1(6)(b)(ii) further establishes certain requirements in terms of rents for
the replacement rental units. In this regard, it requires the rents for the replacement
units to be “similar to those in effect at the time the redevelopment application is
made” and that, for a period of at least 10 years, the rents be increased annually “by
no more than the Provincial Rent Increase Guideline or a similar guideline as Council
may approved from time to time” and a one-time increase of 4% for new construction.

MOD is committed to replacing all existing rental units that will be demolished as
part of the proposal. Based on the April 2018 rent rolls, 100 rental replacement units
are required. It is intended that through the Section 37 and 111 Agreements, these
replacement units will be secured as rental for 20 years and maintained at similar
rent levels in a range of unit types that closely approximate the existing rental units
for 10 years. Any replacement unit vacated and re-rented within the 10 years of the
date of initial occupancy would have an initial rent equal to the greater of the last
rent charged for that unit or the then-current rent threshold.

The replacement units are proposed to be located on Levels 2 through 6 of the

new building and have generally been provided as the same unit type, and in some
instances have been replaced with a larger unit type. In this regard, it is proposed
that two of the existing bachelor units will be replaced with one-bedroom units,
and one of the one-bedroom units will be replaced with a two-bedroom unit. In our
opinion, it is a desirable condition to increase the number of bedrooms available
to returning tenants, while providing a broad mix of unit types. A summary of the
propose rental replacement units is been included in Table 4 below.
Table 4 - Comparison of Existing and Proposed Rental Replacement Units

Unit Type Existing Proposed Replacement

Bachelor 22 20: Bachelor units
2: 1-bedroom units
1-bedroom 74 73: 1-bedroom units
1: 2-bedroom units
2-bedroom 4 4: 2-bedroom units

As illustrated by Table 5 below, the overall rental floor area will be increased slightly
(approximately 13%) in the new building. This is generally a result of maintaining unit
sizes while significantly increasing the provision of shared indoor amenity spaces,
as neither existing building has any formal indoor amenity space beyond the laundry
room within 55 Charles Street East.
Table 5 - Comparison of Existing and Proposed Rental GFA

Measure Existing Proposed

Total Units 100 100
Total GFA Approx. 6,693 m 2
Approx. 7,602 m2
Change 13.6% increase

14
Furthermore, although Policy 3.2.1(6)(b) only speaks to the replacement of the same
number, size and type of rental housing units, MOD further intends to include a number
of dedicated rental parking stalls in their proposed development, albeit at a reduced
number than what currently exists at 55 Charles Street East (no parking currently
existing at 61-63 Charles Street East). In this regard, the proposed development will
be replacing 25 of the existing 56 parking spaces. As of April 1, 2018, only 30 of the
56 existing parking spaces are rented, a number which has fluctuated significantly
over the past few years. In consultation with the existing owners of the buildings at
55 and 61-63 Charles Street East, it has been determined that 25 new rental parking
spaces will be sufficient to meet the demands of the 100 rental replacement units
within the proposed development.

Overall, it is our opinion that the proposal meets the requirements set out in Section
111 of the City of Toronto Act and Chapter 667 of the Municipal Code, as well as the
intent of the housing policies set out in the Official Plan, specifically Policy [Link](b).

T E N A N T R E LO CAT I O N A N D AS S I S TA N C E
Policy 3.2.1(6)(b) also requires an acceptable tenant relocation and assistance
plan, addressing the right to return to occupy one of the replacement units at
“similar rents”, the provision of alternative accommodation at “similar rents” and
“other assistance to lessen hardship”. No specific terms are set out for the tenant
relocation and assistance plan and it is understood that such terms are intended to
be negotiated on a development-by-development basis.

The Residential Tenancies Act, 2006 requires that, if notice of termination of tenancy
is given for the purposes of termination where the landlord requires possession of
the rental unit in order to demolish it, the date of termination shall be at least 120
days from the day on which the notice is given. If a tenancy is terminated for the
purpose of the demolition, the Act requires that the landlord shall either:
• Compensate a tenant in an amount equal to three (3) months rent; OR
• Offer the tenant another rental unit acceptable to the tenant.

MOD intends to develop a tenant relocation and assistance plan in negotiation with
the City, potentially in a manner that goes beyond the minimum RTA requirements.
This may include assisting tenants in securing new rental accommodations through
a dedicated rental agent. MOD intends to hold an initial information meeting and
open house for existing tenants living in both apartment buildings prior to the formal
submission of the rezoning application to permit the proposed development. MOD
will continue to have conversations with existing tenants to best determine the
overall relocation and assistance plan.

Section 111 of the City of Toronto Act prohibits the demolition or conversion of any
rental housing unit on properties that contain six or more related units unless a permit
has been issued under Chapter 667 of the Municipal Code. Accordingly, a permit to
demolish 100 units will be applied for through a Rental Demolition and Conversion
Application Form. It is our understanding that this application will proceed through a
process that is delegated to City Staff.

HOUSING ISSUES REPORT

55 & 61-63 CHARLES STREET EAST 15
 [6.0]
C O N C L U S I O N
It is our opinion that the proposal incorporates a rental replacement element that
meets the intent of the Provincial policies regarding housing and the housing
policies of the Toronto Official Plan, in particular, Policy [Link](b). In this regard, the
proposed development will replace the existing rental units with the same number
of units with rents at similar rent levels (i.e. affordable or mid-range) and at least
with the same mix of unit types, if not larger. Additionally, the rental replacements
units will be higher quality than those that currently exist on the subject site, with
new finishes and appliances, the introduction of air conditioning, indoor and outdoor
amenity space, and fully accessible unit layouts. The tenants of the rental units will
also have access to the concierge in the building lobby, a secure mail room and parcel
area and building elevator. MOD intends to have ongoing discussions with the City
and the existing building tenants in order to secure an appropriate tenant relocation
and assistance plan.

Based on the foregoing, it is our opinion that the application for rental housing
demolition and conversion in accordance with Chapter 667 of the Municipal Code
is appropriate and desirable and is consistent with Section 111 of the City of Toronto
Act and, accordingly, should be approved.

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A P P E N D I X A

MEASURED DRAWINGS
55 CHARLES STREET EAST &
61-63 CHARLES STREET EAST
55 CHARLES STREET EAST

A2
 HOUSING ISSUES REPORT
55 & 61-63 CHARLES STREET EAST A3
55 CHARLES STREET EAST

A4
 HOUSING ISSUES REPORT
55 & 61-63 CHARLES STREET EAST A5
55 CHARLES STREET EAST

A6
 HOUSING ISSUES REPORT
55 & 61-63 CHARLES STREET EAST A7
55 CHARLES STREET EAST

A8
 HOUSING ISSUES REPORT
55 & 61-63 CHARLES STREET EAST A9
55 CHARLES STREET EAST

A10
FIRST FLOOR PLAN
 SECOND FLOOR PLAN

N.B.: Measured plans for the third floor of 61-63 Charles Street East are currently in progress and will be submitted under separate cover in
the near future.

A12