Form-Based Zoning Could Change How Canada Builds Housing
Standardizing zoning rules could make it easier to build more homes across Canada and stop battles over multiplexes in Toronto and Calgary.
Canada needs more homes, but building them in existing neighbourhoods often sparks fierce opposition. Could “gentle density” be the compromise?
Cara Stern and Mike Moffatt explore how smaller-scale infill, form-based zoning, and streamlined condo rules could create more family-friendly housing while addressing concerns about height, parking, infrastructure, and neighbourhood character. They discuss the battles over multiplexes in Toronto and Calgary, and why standardizing zoning rules could make it easier to build more homes across Canada.
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Below is an AI-generated transcript of the Missing Middle podcast, lightly edited.
Cara Stern: Canada’s population growth is experiencing a temporary pause, but it is set to resume in 2028, when the number of non-permanent residents plateaus. This, along with pent-up demand from a generation of young people who have been locked out of the housing market, drives the need for more family-friendly housing. Building additional housing in existing neighbourhoods has long been seen as part of the solution. Still, strong local opposition has really made it challenging to build the quantity of homes needed to address the shortage.
Gentle density, a way of building infill that’s designed to minimize opposition and maximize the benefits for existing residents, is increasingly being seen as part of the solution.
Mike Moffatt: Cities have followed three basic paths to allow for more housing to be built. First, they can build out, which many have been hesitant to do over the last couple of decades on both environmental grounds and the cost of building new infrastructure. Second, they can build way up by allowing taller and taller apartment buildings downtown, which cities have done, and this has helped—but the economics and layouts of high-rises make them unable to fill every family need. Or, they can add housing to existing neighbourhoods, which often ends up in an acrimonious political fight.
Cara Stern: The idea behind gentle density is to allow for housing to be added to existing neighbourhoods in a way that reduces local opposition, so it focuses on smaller housing forms such as secondary suites and tiny homes, among others, to create more housing options—particularly ones that work for families.
Mike Moffatt: We wrote a report about this a few months ago called Cornerstone to Capstone, with support from our friends at the Cornerstone Association of Realtors, and we’ll link to that report in the show notes. We were motivated to write the report on how to make it easier to build infill housing because, these days, it’s hard to scroll through housing news without seeing some new dispute about infill. For example, a few weeks ago in our group chat, we were discussing one of those projects, which is an eightplex on Station Road in Toronto. Now, I’m in Ottawa, but Cara, you’re in Toronto—that’s your neck of the woods. What’s going on with that dispute?
Cara Stern: There are lots of multiplexes that have caused controversy in Toronto. The City of Toronto famously agreed to allow sixplexes right across the city as part of their agreement with the federal government under the Housing Accelerator Fund, but then they backtracked on that deal and only allowed it in nine wards. Sometimes plans come up where someone says, “We want to build this kind of multiplex in this area,” and even if it fits what the city says they want, there often is local opposition.
The one on Station Road is in Etobicoke. They approved it as a fourplex, and the developer built the base of the home as a fourplex. Then partway through construction, the developer said something like, “Actually, we want to change this to an eightplex, but we’re not going to change how big the home is or how much of the lot it takes up.” It’s going to be the same footprint, but changed from four to eight units, and that caused a lot of controversy. A lot of local neighbours were not happy with it. They’re going from 11 bedrooms to 13 bedrooms, so when you think of how many more people it will be or how much denser it will be, it’s not a ton. It means smaller units, which changes who lives there. That shouldn’t really affect neighbourhood support in my mind, but obviously it does—people look at family-sized homes differently than they do one-bedroom units.
The main thing people are upset about with this one is that they see it as a bit of a bait-and-switch. They see it as, “Look, they got approved under the fourplex as-of-right, but they always intended it to be an eightplex.” That’s the allegation. I don’t know if that’s the case—the developer says that is not the case and that they’re responding to changes in the market, but that’s what’s happening there.
It is really close to Mimico GO station, so it’s one where you think, “Well, we should have density around a train station.” It’s a very good train station where you can get to downtown Toronto really quickly, and it comes fairly often as far as GO trains go. But I think it caused controversy really because of how much they changed from the proposal. It’s also a weird one where you look at it and they’re taking up almost the entire lot, so I understand the neighbours’ frustration, even if I feel like we need more homes, that more homes are good.
Mike Moffatt: We’re seeing these fights play out all over the country, sometimes at the individual project level, but sometimes at the citywide zoning level. We had a similar situation in Calgary where, in 2024, city council enacted citywide upzoning, in part to comply with their Housing Accelerator Fund agreement. That upzoning really didn’t sit well with many residents, so after the 2025 municipal election, the new council decided to roll back those rules. The vote wasn’t even close—12 members voted to repeal the blanket rezoning, and only three wanted to retain the upzoning rules. As the City of Calgary pulls back on it, that’s going to lead to less infill housing, and it’s also probably going to lead to the city losing some of its funding from the federal government, though it’s not quite clear how that’s going to play out yet.
Cara Stern: It’s weird because the idea behind gentle density is that you would reduce opposition. People often get upset if a big high-rise is going up in their neighbourhood—of course, I understand that. There’s one at Pape and Danforth in Toronto where the new subway interchange will be, and it’s so much bigger than anything there. People get upset about that. I can understand that when people think about their homes and then think, “Oh, I’m going to be near a high-rise,” why that gives them a visceral response, even if it’s just an initial response before they think about whether it makes sense.
When you think about gentle density, the whole point is that this is so minor that neighbours shouldn’t really complain, but they still do. The Station Road project is a bit of a weird example because of the process it went through, but we have an episode on one on Craven Road in the east end of Toronto that was just about garden suites, and neighbours were still upset about garden suites. You can look around at all the multiplex applications in the city, and you’ll often find neighbours getting really upset.
These fights from existing residents make it difficult to build infill, which has led to the increased popularity of a school of thought called gentle density, designed to reduce, if not eliminate, the aspects of infill that local residents are most opposed to.
So I’m going to give you some of the common objections to intensification, and, Mike, can you walk me through how gentle density reduces these objections?
Mike Moffatt: Absolutely, let’s do this.
Cara Stern: The first objection we have is that intensification allows buildings to be too tall, causing them to be out of proportion with the rest of the neighbourhood.
Mike Moffatt: I hear this a lot. Low-rise neighbourhoods already have height limits, though those can be uneven across neighbourhoods or even within the same neighbourhood. In my neighbourhood here in Ottawa, there are parts that have a height limit of 10 meters and parts that have 11 meters, and even on the same street, there’s an invisible line creating these disparities. What gentle density does is retain height limits in this general range, but it standardizes them through something called form-based zoning so you don’t get uneven height limits all over the place.
Cara Stern: How does form-based zoning work?
Mike Moffatt: In a typical community, zoning rules for low-rise neighbourhoods lay out a set of rules around how tall buildings can be, how you measure the height of a building (because there are a bunch of different ways of doing it), how large a home can be, what the setbacks are, and so on. But for a lot of those rules, the building code essentially does the same thing. In Canada, building codes distinguish between large buildings, which are governed by Part 3 of the code, and small buildings, which are governed by Part 9. A typical suburban house is governed by Part 9, which has height and size limits on that structure.
Cara Stern: What is the height limit?
Mike Moffatt: It’s pretty much the same as my neighbourhood in Ottawa—essentially three stories, which gets you into that 11-meter range. But if you think about it, it’s kind of weird that there are two sets of rules for height for a low-rise building: one set in the building code and another set in zoning. Not only are they different, but they can actually measure height differently, creating a lot of red tape for no good reason. We can get rid of that red tape through form-based zoning by aligning our zoning rules with our building code rules.
Cara Stern: It makes sense that standardization would be pretty valuable. At The Missing Middle, we’ve talked a lot about how all the different rules between cities make it harder for a builder to sell homes in one city and then expand to another because they have to learn a whole bunch of new rules, which adds time and process to the project. I kind of think of it as inter-city trade barriers.
Mike Moffatt: That’s a great way of putting it—sometimes even inter-neighbourhood trade barriers, because the rules can differ between one side of the street and another. That standardization is one of the big benefits of form-based zoning. If height requirements and other requirements are consistent among low-rise neighbourhoods, it’s a lot easier to design and factory-build housing because you don’t have to have different units for different municipalities. You’re not saying, “Okay, I can sell this in Brampton, but I can’t sell it in Mississauga.” You create one standard, and that allows you to build homes everywhere.
Cara Stern: Has anywhere in Canada actually adopted form-based zoning?
Mike Moffatt: You’re starting to see this. One example is back in February, Cambridge, Ontario adopted a version of form-based zoning, which reduced the number of overall residential zones from 16 to four, with two of those zones covering low-rise residential. They really tried to live up to the spirit of form-based zoning, though they backed off a little bit from implementing full form-based zoning. They still have a four-unit maximum per lot, which doesn’t appear in the building code, and they still have two low-rise zones instead of one. But in other respects, such as height limits and some of the other rules, they acted in the spirit of form-based zoning by saying it doesn’t make sense to govern something under zoning when it’s already governed under the building code.
Cara Stern: That seems to cover the second item on my list of objections: the size of buildings. Specifically, we hear that buildings are just too large, look out of place with the rest of the neighbourhood, or crowd out existing homes, even if they aren’t actually any taller than existing homes.
Mike Moffatt: Exactly. In the case of form-based zoning, Part 9 of the building code sets out a limit of 600 square meters for the structure, which rules out building short but very large housing structures. You can’t just build a big townhouse complex in the middle of a single-family neighbourhood because you have to comply with Part 9. That really limits the size and types of homes that can be in a single-family neighbourhood.
Cara Stern: One big objection that comes up over and over—and it did in the Station Road fight—is how intensification leads to strain on infrastructure, particularly parking, though there’s other infrastructure as well. When that project went from a fourplex to an eightplex, people got worried.
Does gentle density reduce that?
Mike Moffatt: Yes, it does, because it limits how dense these neighbourhoods can get through height limits, setbacks, and lot coverage rules. You want to make sure you have adequate green space for residents and permeable area to prevent flooding, so there are limits to how dense these neighbourhoods can get. Of course, that limit on density is a double-edged sword because it also limits how many families can live in that neighbourhood. That’s where the “gentle” part comes in: these neighbourhoods can only get so dense, which prevents some of these disputes around parking and strain on infrastructure.
Cara Stern: Another frequent objection to infill housing is that there are no benefits to existing residents, only costs. An investor buys an existing home, knocks it down, builds a multiplex, and a bunch of new residents move in—and the people living there beforehand aren’t so happy about it. How does the concept of gentle density change that?
Mike Moffatt: That’s one of the big benefits. In traditional infill, an investor buys a small strawberry-box home, knocks it down, and puts up a multiplex. The benefit of gentle density zoning is that you get away from thinking in terms of unit counts—whether you can have four or five units in a building—and instead focus on choice and giving existing residents more freedom in how they use their land. It could be building a multiplex, but it can also be adding tiny homes or creating a “pocket neighbourhood,” where you have four or five smaller units on a lot around a central courtyard.
For example, if you’re a homeowner and want to add a couple of tiny homes onto your lot to give your university-aged kids more privacy, you can do that. It creates more flexibility and creativity for existing homeowners, rather than traditional infill, which is all about taking a single structure and subdividing it into a certain number of units. That actually advantages existing residents.
Cara Stern: One final objection I hear all the time is that intensification only creates homes for rent and not for ownership opportunities. An infill developer comes in, builds an eightplex, and rents out all eight units—or maybe at best, they live in one and rent out the other seven. Does gentle density create homeownership opportunities and not just rentals?
Mike Moffatt: This is an objection I hear a lot: that intensification leads to neighbourhoods going from ownership-based to rental-based, and I think there’s something to that. The concept of gentle density allows for infill that is still ownership-based. Everything I’ve talked about so far with gentle density has been zoning-based, but this is one area where we’re talking about other rules—specifically condo regulations. Under current rules, to create ownership housing for anything beyond a duplex, it falls under condo regulations. If you want to build a fourplex or four units on a single lot in a pocket neighbourhood, you normally have to treat it as a condo and go through all the paperwork and expense of condo regulations.
The thing is, those rules weren’t designed for small multiplexes or small forms of infill; they were for townhouse complexes of 80 or 90 people or high-rises for 300. They don’t scale—you do as much paperwork for a four-unit condo as you do for a 400-unit condo. In theory, you can build multiplex infill and make it ownership-based, but in practice, it’s prohibitively expensive, so nobody really bothers.
Cara Stern: How can you fix that?
Mike Moffatt: Jurisdictions across North America have taken a few different approaches.
In British Columbia, for example, they introduced what they call a small-scale, multi-unit housing system. They retained condo rules, but made a streamlined version of them so you’re not filling out the same paperwork and incurring the same expense for four units as you would for 400.
In Oregon, for gentle density housing that isn’t stacked on top of each other—like a ground-level fourplex or a few tiny homes—they made it much easier to subdivide the land between units. You can take an existing lot, divide it four ways, and when you buy a quarter of that fourplex, you’re not just buying the structure, but also the underlying land. That creates opportunities for ownership because you can buy the underlying land and subdivide it. If you have units that are stacked, BC has streamlined the regulations.
There are different ways of doing it, but they all fall within the philosophy of gentle density: giving existing residents options and allowing infill without letting density get to a point where existing residents are uncomfortable.
Cara Stern: I do think concerns about renters are overstated. You’ll often hear objections to projects where people say, “Oh, well, renters are moving into the neighbourhood and that’s not what this neighbourhood is.” I don’t really get that, especially with how the housing crisis has gone—I don’t get the stereotype that renters are going to bring property values down. But despite the current market, homeownership is still seen as how you set roots and grow wealth in Canada, so a lot of people want to own even if they might be happy renting for other reasons.
Mike Moffatt: I absolutely agree. Concerns about a neighbourhood becoming “too much of a rental neighbourhood” are overstated. But at the same time, you need to meet people where they are. Is this the hill we want to die on? If there’s a way to address those concerns and still get more housing built, we should do it. We shouldn’t let the perfect be the enemy of the good. If we have to meet people halfway, let’s do it rather than trying to convince people that a 40%, 50%, or 60% rental neighbourhood is fine. I just don’t think it’s a fight worth having.
Cara Stern: It’s funny—right now I’m renting in a neighbourhood, and when I meet neighbours and mention we’re renting the home on the corner, their faces fall. They’re like, “Oh, okay, I guess I won’t invest in this friendship because you’re just a renter here.” I mean, I’m here for a defined period of time, so I understand that to a degree, but they look disappointed before I even finish explaining. It’s really weird and doesn’t make any sense to me. Anyway, if we were going to adopt true gentle density, it sounds like several things need to change, like zoning rules and condo regulations. How do we get there from where we are right now in our cities?
Mike Moffatt: Let’s start with the zoning piece. The first place to start is having the province set a gentle density minimum for low-density areas across the board, but I would actually make those rules apply only to greenfield development—brand-new lands in the outer suburbs. Start there because it’s a much easier lift. You could introduce gentle density without starting this whole system of reforms with a massive fight.
Cara Stern: That makes sense. If there are no neighbours to object to it, it’s much easier to get through. I can certainly see the value of that because you’d eliminate a lot of red tape by having standardized zoning across the province, making it much easier to create factory-built homes given that companies would be building to a single standard. But if the point of gentle density is to make it easier to build infill, then applying it only to greenfield doesn’t let it reach its full potential, right?
Mike Moffatt: It’s absolutely a compromise, but applying it to greenfield allows us to work out the bugs, like whether maximum lot coverage ratios should be 40%, 45%, or 50%. It’s easier to work those things out first, and it allows the general public to get comfortable with the idea. They can look at those neighbourhoods after five or ten years and see that they look really nice. That creates the political conditions where the province could then start rolling out those rules in infill neighbourhoods, either by mandating it or by giving municipalities incentives—like offering additional infrastructure funding if they adopt it across two-thirds of neighbourhoods.
Cara Stern: I don’t like the idea that you have to build these homes and then wait five to ten years for other people to be okay with them in existing neighbourhoods. Is that necessary?
Mike Moffatt: Ideally, I’d prefer five to ten months over five to ten years, but it’s a difficult lift across the province. If an enterprising provincial politician gets that done, I’ll be the first to congratulate them, but I’m worried that going full head of steam on this might end in tears.
Cara Stern: Do you think it will actually happen then?
Mike Moffatt: I am cautiously optimistic because it makes too much sense from a red-tape reduction point of view to harmonize zoning and building code rules across municipalities. The industry can support that, and the general public can see that it makes sense. Limiting it to greenfield developments reduces opposition enough that it could get passed, and governments can frame it as preventing neighbourhoods from over-densifying.
The term “gentle” is important because you can frame it as listening to public concerns and setting limits. Because of that, opposition is actually more likely to come from YIMBYs than NIMBYs, who might see it as being too mild, catering to existing homeowners, and waving the white flag.
Cara Stern: That’s funny. If they were at least making it match where you’re allowed sixplexes in Toronto or eightplexes in Edmonton, taking it to the maximum amount allowed as-of-right to make it easier to build, that would be great. But when I hear city councilors talk about wanting more “gentle density,” what I hear as a YIMBY is, “We only want small changes, let me fight for the NIMBYs here.” I always think it’s code for that. Hopefully, politicians will start taking what you’re saying seriously and actually make it easier to build, rather than using it to limit development.
Mike Moffatt: Exactly. Once you move to form-based zoning, you get away from disputes around unit counts altogether. So much of our discourse is focused on four versus six versus eight units, whereas if we say we’re limiting the size of the building structure and however it gets laid out is fine, it avoids that fight. Pulling away from arbitrary unit counts allows us to focus on creating density that works in existing neighbourhoods.
Cara Stern: Thanks so much for watching and listening. Our producer is Meredith Martin, and our editor is Sean Foreman.
Mike Moffatt: And if you have any thoughts or questions about form-based zoning, a term we’ve used 37 times in this episode, please send us an email to [email protected].
Cara Stern: And we’ll see you next time.
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