Building More Mid-Rise Apartment Buildings

Hey All,

Welcome back to Middle Ground; this is the ninth newsletter of our 28 policies in the 28-day series ahead of the 2025 Ontario provincial election.

Today’s issue will discuss how to removing elevator requirements can increase the number of housing units available in downtown Toronto.

What is the current problem with zoning and elevator requirements?
The City of Toronto has recently been rezoning lands along major streets to allow for six story apartment buildings in an attempt to increase density and lower the cost of living downtown. 

The problem is that the Ontario Building Code requires an elevator for any residential building that has more than three stories. Given the cost of installing an elevator, it is often financially unfeasible to build 4-6 story buildings on regular 23-25’ lots that have been rezoned. 

The end result of this disconnect between the City of Toronto’s zoning and the Ontario Building Code is that despite efforts by the city to increase density in the downtown core, we remain in a situation where mid-rise buildings are not financially feasible. Instead, Toronto remains a city stuck with either low-rise (3 stories or less) or high-rise (20 stories or more) buildings. This phenomenon has been observed in countless major cities and has been termed “the missing middle.”

Why do elevator requirements exist?
The idea behind the existing elevator requirements is to ensure that buildings are accessible for those with disabilities. Without any elevator requirements, the city would risk building too many units that are not accessible, leaving a portion of the population without suitable accommodations. 

The problem with this logic is that all high-rise buildings are accessible. Every condo has elevators going to each floor, and very few feature any stairs at all. Therefore, the practical effect of the Ontario Building Code is not to make more accessible units but to remove entire units from existence, contributing to the shortage of housing supply in Toronto. 

Is there a compromise? 
The Ontario Building Code already requires that 15% of the units in a building must be accessible. This regulation alone is sufficient to ensure that there will not be a shortage of accessible units, even in new mid-rise buildings. Most of these buildings will be forced to have a design whereby all first-floor units are smaller and accessible so that the units on the 2nd and 6th floors can be larger but accessible only by stairs.

Onwards and Upwards,

Liam Gill

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