Onah Jung is a Toronto-based architect, urban designer, and founder of Studio Jonah.
The City of Toronto recently revealed plans for more housing around Toronto’s 120 transit stations, including subways and LRTs. The goal of creating more housing around transit makes sense at first glance. Being close to stations would encourage people to use transit and reduce the need for parking. There are many benefits, in theory.
I have seen this theory fail in real life.
In the early 2000s, I lived in Manhattan, the city that never sleeps, the city where, if you can make it there, you can make it anywhere. New York is also a city with an abundance of transit connections, including to routes going out of the city.
Spanning a decade, my graduate school and subsequent work life taught me that being near public transit costs a lot. Most people I met during there did not live near their work or near transit. They drove or took other transportation modes (regional buses, trains, ferries) to get into the city, leaving their cars near commuter stations. Multiple transfers were involved.
I was one of those people, though in a more comfortable setting. But living in Brooklyn near a subway station came with a price: first, an exorbitant fee to a rental broker for finding an apartment, then paying much higher rent than my coworkers who drove in or took the train from farther locations.
Being near transit is a convenience everyone wants, including drivers. The convenience is especially important for people without cars. Yet the City’s strategy to build more housing near Toronto’s transit stations is disingenuous because those plans don’t tell us about the type of housing envisioned or whom the housing is for. The elephant in the room is affordability.
Building more housing near transit may bring in more residents, but it will not help the people who need affordable housing the most.
WHO PAYS TO LIVE CLOSE TO TRANSIT?
People pay for convenience. I have seen it throughout my adult life, both in New York and in Toronto. The trade-off sounds reasonable: to get the convenience of living near public transit, it seems fair that one should pay for such convenience.
This trade-off exists everywhere in our society. Buying a better computer costs more. Paying for a gym membership rather than exercising outdoors in harsh weather costs more. These are examples of what some of us will pay for and what some of us cannot afford.
However, when it comes to housing, the options analysis goes out the door.
Accessible transit is not a luxury for renters; it is a requirement. Other than a select few who choose to rent, most tenants have to rent and also tend to rely on public transit to get from one place to another: work, grocery shopping, medical appointments.
The affordable housing discussion tends to focus on one aspect of housing: ownership. However, there is an even more important discussion missing in this overall housing conversation: rentals.
Renters do not have the option to live far from transit and drive. They need the access, which means they end up paying premium prices for those locations. Building more housing near transit without addressing this price premium does nothing for affordability. It just creates more expensive housing in convenient locations.
Here is where the disconnect becomes clear. Developers receive multiple incentives to build near transit, but renters receive none of the affordability benefits those incentives were supposedly designed to create.
In construction, excavation is a huge cost. It can take up as much as 40 percent of overall construction costs. Transit-oriented developments often eliminate parking requirements, which saves developers significant sums.
The land itself becomes more valuable because of transit proximity. Developers are essentially receiving multiple layers of financial benefit: reduced construction costs from no parking requirements and higher land values from transit access.
Where do these savings go? Not to renters.
The City of Toronto has implemented Inclusionary Zoning as part of the requirement for new buildings in Major Transit Station Areas. Starting in August, 2025, developers have to provide up to five percent of the units they build as affordable housing, and these units must stay affordable for 25 years. The official goal of Inclusionary Zoning is creating affordable housing in new developments while supporting mixed-income communities.
It is the right starting point, but the reality is far weaker than it sounds.
First, five percent is sadly low compared to other jurisdictions. Toronto Mayor Olivia Chow has been pushing for 20 to 30 percent affordable housing requirements, recognizing that five percent does almost nothing to address the scale of the affordability crisis. When a development has 200 units and only 10 of them are affordable, we are not solving an affordability problem. We are creating a token gesture.
Second, Inclusionary Zoning only applies to 89 of Toronto’s 120 Major Transit Station Areas. Not even all these TOD areas are covered by this already weak policy.
Third, the affordable units only stay affordable for 25 years. After that, they can go to market rate. This means the limited affordable housing we do create near transit is temporary, not a long-term solution.
Fourth, and most critically, the province has paused Inclusionary Zoning implementation until July, 2027. On January 29, 2026, Ontario filed a regulation suspending the policy, citing concerns from industry stakeholders that affordable housing requirements could result in the pause or cancellation of projects. The province said it has heard from developers that these requirements make projects financially unfeasible.
Meanwhile, the city is still required to complete zoning updates for all 120 transit station areas by spring 2026. We are building the entire planning framework to allow more housing near transit while simultaneously suspending the only policy tool that could make any of that housing affordable.
Liberal housing critic Adil Shamji noted that the opportunity to build around new subway lines and stations really only exists once. As the Finch West LRT, the Eglinton Crosstown and the Ontario Line open, the opportunity to have affordable housing along those corridors may disappear forever without concrete remedies.
The NDP estimates that pausing Inclusionary Zoning will block at least 3,000 affordable homes from being built each year in Toronto alone. Planning and Housing Committee chair Gord Perks described the proposed change as cruel.
This creates a policy framework that encourages development near transit through financial incentives but suspends any requirement for those financial benefits to translate into affordable rents. The more valuable the location (i.e., being near transit), the higher the rents can be. The more incentives developers receive, the higher their profit margins become.
We have designed a system that makes it financially attractive to build rental housing near transit while making it financially optional to keep that housing affordable. That is not a housing affordability strategy. That is a developer profit strategy that happens to produce housing. (In fact, developers received two more financial incentives last week — a break on HST for homes under $1 million, and reductions in development charges thanks to $8.8 billion in federal and provincial contributions to the city’s infrastructure budget.)
A focus on building more housing is the right step. The difficulty lies with what type of housing and for whom, not just more. With many stakeholders and competing financial interests, planning and building more housing will may only produce more unaffordable housing.
The central issue when it comes to building more housing near transit is not just the numbers, but also who will benefit. Without considering this issue, we will produce lots of housing near transit. Whether people will be able to afford to buy or rent, there is an entirely different discussion.
As my old New York City friends’ favorite dinner party topic indicated, Torontonians will have those the same discussions. The difference is that in Toronto, we still have time to make sure the answer to those questions does not determine who gets to live in this city.
Onah Jung, OAA, AIA, LEED AP, is a Toronto-based architect, urban designer and founder of Studio Jonah. She teaches at OCAD University. Her project experience includes MoMA’s expansion in New York and World Trade Center Tower 4. She writes about how design ambition meets regulatory reality at onahjung.com.
