CONCEPT 2 KEYS (C2K) – UPDATE #3
Since our last updates on the City of Toronto’s (the “City”) Concept 2 Keys (“C2K”) program in May and June, the City is now transitioning parts of the C2K pilot program into a permanent service, including the affordable housing priority application function and the online Application Submission Tool (“AST”). Details of these updates are outlined further below.
Since its timely creation in March 2020 amidst the start of the pandemic, the C2K program has attempted to streamline the City’s planning and development review, from pre-application consultation to occupancy, by changing its organizational structure, processes and technology.
The C2K program introduces new factors to the development review process, including the new AST; an expansion of the intake portal; and creating dedicated application review teams with members from various City divisions to streamline the application process.
Since January 2021, the City has now introduced two new application review streams: the Priority Application Stream (the “Priority Stream”) and the District Application Stream (the “District Stream”). On November 9, 2021, City Council directed the City Manager to start transitioning the Priority Stream to a permanent service and to report back to Council in Q1 2022 to expand the Priority Stream further. Council’s decision is found here.
- The Priority Stream
The Priority Stream identifies and evaluates high-priority affordable housing applications based on the following criteria:
- Number of affordable units (at or below Average Market Rent as defined annually);
- Depth of affordability;
- Length of affordability;
- Number of affordable units that will be allocated to priority populations (identified in the HousingTO 2030-30 Action Plan); and
- Projects with government investment in the form of land or approved capital or operating funding.
Under the Priority Stream, City staff attempt to minimize delay by maintaining a tightly coordinated schedule, jointly resolving interdivisional issues and minimizing file load to improve application wait times for review. This process has permitted an expeditated review of high-priority affordable housing developments, averaging around 3-6 weeks, compared to the 8-9 weeks required for most other development applications across the City. For example, the first C2K application submitted since the review teams were formed was the Thunder Woman Healing Lodge Society development, which has now received its Notice of Approval Conditions six months after the application was first submitted.
The City hopes to increase the scope of the Priority Stream to include, among other things, development related permits and approvals.
- The District Stream
The District Stream is being used to test the scalability of development review improvements across a range of application types in a typical review environment. Unlike the Priority Stream, the teams in the District Stream have a regular intake capacity and carry a typical file workload. Currently, it is being tested in the Etobicoke-York District to eventually standardize its processes in other areas of the City.
To date, the Etobicoke-York District has three interdivisional application review teams, one in each sub-district (North, South and Central), consisting of application reviewers from City Planning; Engineering & Construction Services; Transportation Services; Parks, Forestry and Recreation; and the C2K Office, all to ensure review teams have the appropriate resources in place to review applications efficiently. Each interdivisional review team also has an extended review team from other City divisions, including Solid Waste Management Services, Legal Services and Toronto Building. The interdivisional review teams are an attempt to enhance collaboration, development consistency and increase transparency. Although the interdivisional team structure is integral to the collaborative review approach, City Planning remains the sole department to make recommendations to City Council and make decisions within its delegated authority.
Review Process Changes
Also as part of the C2K program, and after 6 months of testing, the City has now indicated that its online AST will be available for all development applicants to use beginning December 6, 2021. The AST digitizes the applicant submission process and attempts to make it more user-friendly. While the tool is not widespread in its application yet, early reviews from applicants have been positive and staff will continue to work on refinements.
Further, a file circulation platform is being tested to streamline application submissions, improve internal review processes and enhance transparency. The platform is to be integrated with the Integrated Business Management Systems and the Application Information Centre to enable more efficient collaboration between City staff and applicants. The City will request proposals for the platform in Q4 2021, and select a vendor in Q1 2022. The City hopes to implement the new platform by the end of 2022.
Finally, an online mapping and analysis tool will be tested by planning staff to understand the feasibility of using it as part of the development review. The tool would allow staff to efficiently locate land parcels; create three-dimensional building renderings; and evaluate the development potential of any given property in the city. An initial data review of the pilot is anticipated in Q4 2021 and results will be provided in the next quarterly report.
An Issues Resolution function was launched in Q2 2021 on the City’s website to address application-specific concerns, enhancing customer service and identifying additional opportunities for improvement to the development review process. Upon reporting an issue, you will receive confirmation that your request has been received within 24 hours, and it is expected to be resolved or escalated for resolution within 10 business days. Relationship and issues coordinators support this function and will be the first point of contact for understanding the current status of applications, providing updates to applicants and escalating issues that are complex or systemic in nature.
Development Fee Review
In February 2021, City Council directed staff to undertake a review of the current activity-based costing development application fee model. This review, which is currently underway, intends to improve the City’s existing fee structures to recover the costs of service, including, the processing efforts of staff, internal and external support functions and capital replacement costs. Staff will bring forward a report to Council in Q1 2022.
C2K staff will continue to provide updates to the Planning and Housing Committee on a quarterly basis and Davies Howe will be here to assist you with navigating these new changes.