Let’s take a fresh look at developing Toronto’s employment lands

Architect, Urban Designer, Urban Planner | B.Arch, OAA, RPP, MCIP
  • Aug. 18, 2021

The one-year Toronto city council-approved window to receive requests to convert lands designated Core Employment Areas or General Employment Areas for non-employment uses, pursuant to A Place to Grow: Growth Plan for the Greater Golden Horseshoe (2019) closed on Aug. 3.

Over the past year and a half, office buildings in Toronto have emptied out as the work-from-home movement has taken hold. This pattern may change as pandemic restrictions loosen, but there is speculation the future of work may incorporate a mix of at-home and in-office working.

At the same time, housing affordability in the City of Toronto has only gotten worse, in part due to a shortage of suitable and plentiful housing stock.

With these two things in mind, it’s hard to imagine why there would be such a push for more land dedicated exclusively to employment uses. Yet, this is the debate we find ourselves having in the City of Toronto.

Known as “employment lands,” these are areas dedicated strictly to business and economic activities like manufacturing, wholesaling, processing, offices, industrial trade schools and more. Other uses like small-scale restaurants, parks, and banks that serve employment lands are also generally allowed, but residential uses are not.

City, province protect employment lands

Both the city and the Province of Ontario like to protect their employment lands. These lands are sometimes seen as essential as they provide important spaces for economic activities.

Residential uses are usually more profitable, though, so new development catered to employment is not as common nor as widespread. Plus, once an employment zone is converted to something like residential and people start moving in, it is unlikely to ever change back to pure employment uses.

In the City of Toronto, there are two types of employment areas: core and general. They are similar, but core areas are located at the centre of employment areas and are often used for industrial activities.

General employment areas are more on the periphery of core areas and allow for a wider variety of uses, including restaurants, retail and other services.

In 2019, the province also introduced Provincially Significant Employment Zones. These are areas defined by the province in consultation with municipalities. They are strategically located to provide stable, reliable employment opportunities and are presented as crucial for job creation and economic development.

Because of their deemed importance, they are subject to a more stringent process for land use conversion than other employment areas.

Converting employment lands for other uses

There are many pockets of general and core employment areas in Toronto, including a few also designated as provincially significant. However, some of these employment areas are in very desirable, central locations with good transit connections, making them ideal candidates for mixed-use development.

So, what happens if you want to convert an employment area to another use? This can be quite tricky. For all the previously mentioned reasons, the province and city are hesitant to convert them.

However, tricky doesn’t mean impossible.

In the City of Toronto, requests for conversions must be made as part of a Municipal Comprehensive Review, or MCR. Conversion requests do, however, require the payment of a $20,000 fee, which was recently introduced to help the city manage the high number of these requests.

In addition to the fee, the city has recently made efforts to standardize submission requirements and recommend applicants meet with staff before submitting an application.

Reviews of conversions are subject to four major criteria:

1. The conversion must be seen as necessary in order to meet population forecasts;
2. The lands must not be required in the long term for employment purposes;
3. The conversion must not negatively affect the overall viability of the area;
4. The converted lands must not be near important transportation infrastructure (i.e. major highways).

If an application meets those criteria, conversion may be possible.

Conversion examples in Toronto

A good example of an approved employment land conversion is the former Christie cookies plant. In 2019, the site was rezoned from employment to regeneration following approval from the Toronto council and the Local Planning Appeal Tribunal (LPAT).

Plans for the 28-acre site include new streets; parks and open spaces; a mix of residential, commercial, and employment uses; and a new transit hub.

In the case of Christie cookies, conversion was approved in order to meet other provincial non-employment intensification goals. The new plans are projected to include 12,000 new residents and between 3,500 to 3,800 new jobs over the next 25 years.

The development will need to match the existing amount of employment GFA but can add residential GFA beyond that. This ensures sufficient employment opportunities are provided despite the more flexible land-use designation.

Another interesting example of employment land conversion is East Harbour, an area north of Lakeshore Boulevard and east of the Don Valley Parkway. It is considered an important employment area by the city and is even a Provincially Significant Employment Zone.

For a long time, the city was insistent the lands remain strictly for employment uses; there were fears allowing mixed-use development would make it hard to meet employment growth targets.

A new plan for the East Harbour lands

In 2018, council approved plans by developer First Gulf that would realize the city’s vision of the area as a vibrant and active office district, complemented by various retail and services. However, in 2019 First Gulf sold the entire East Harbour project and lands to Cadillac Fairview.

Now with plans for a major transit hub dubbed the “Union Station of the East,” the future of the employment area may be changing. The province recently announced its intention to partner with Cadillac Fairview on building a transit-oriented community in East Harbour.

Original plans by the city and First Gulf included 10 million square feet for employment uses. The new plans maintain this amount but add 3.25 million square feet of residential space, marking a significant departure from the city’s original vision for the area.

It won’t be long before more decisions are made regarding East Harbour. The city has even hinted a Minister’s Zoning Order (MZO) might be enacted by the province to allow the mixed-use proposal. An MZO cannot be appealed and would expedite the timeline for the project to align better with construction of the East Harbour transit hub.

Employment lands and the conversion of employment lands are a complicated planning matter. Recent trends toward working from home have added to that complexity and fuelled the debate about the uncertain future of employment zones.

What we do know is this: having space for people to work is important for job opportunities and economic vitality, but mixed-use, affordable and complete communities where everything is nearby are important, too.

Creating strict separations between different land uses is a practice of the past that urban planners have spent decades trying to move away from. Plus, as we become more open to a hybrid model of working from home, comfortable and affordable housing is going to be in even higher demand.

Land use decisions today must take into consideration society’s changing habits. In the midst of a housing shortage and the decline of the traditional office, perhaps it’s time to reimagine what employment lands should be.



Naama has a bold vision: to change the conversation about what good development can and should look like; with that in mind, she co-founded Smart Density. Naama’s professional work spans…

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Naama has a bold vision: to change the conversation about what good development can and should look like; with that in mind, she co-founded Smart Density. Naama’s professional work spans…

Read more




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