Section 37 Review

Project Description

The City of Toronto retained GPA to examine the use of Section 37 with the aim of bringing greater clarity and understanding of when and how it applies to development projects. Our team reviewed the application of the policy throughout the city, addressed inconsistencies and recommended improvements for its implementation.

The study examined background data to create a clear picture of the monetary funds and other benefits secured through Section 37 agreements by ward since the year 2000 providing historical and current trends data that helped to identify issues around transparency and consistency. An extensive stakeholder consultation program provided valuable insights on the implementation of Section 37, which ultimately contributed to informing and shaping the recommendations.

Interviews conducted with 14 Councillors explored their experiences, priorities, and suggestions to improve the process. Discussions and workshops with City staff from various departments (Legal, Planning, Parks, Forestry and Recreation, etc.) examined opportunities and constraints to better utilise the funds available through improved coordination and communication and enhance the transparency of cataloguing benefits and implementation. Consultation with the Building Industry and Land Development Association (BILD) provided insights on how to improve clarity on estimating benefits by proposed development size and impact. Together, the many inputs received by stakeholders provided a clear path forward when drafting the recommendations.

Recommendations focused on the issues of establishing ‘a reasonable planning relationship,’ assessing community needs, standardizing valuation, determining base density, heritage conservation, flexibility of expenditure, and following up on the delivery of benefits.

GPA has also developed Section 37 strategies for Markham and Vaughan.

More Information


City of Toronto






City of Toronto Project Page


Planning Policy and Implementation