I noticed the same logic on a much smaller scale a few years ago, working on the interior renovation of an existing commercial building.
The tenant space needed a full fit-out, new partitions, new finishes, the usual scope of that kind of job. But past a certain point, the renovation triggered something I hadn’t fully accounted for.
Once the scope of work crosses a certain threshold, the building’s main entrance and path of travel have to be brought up to current barrier-free requirements too. Keep the renovation smaller, and that same entrance can remain exactly as it is, “grandfathered in” untouched by a code that would otherwise require it.
Nothing was broken. Nothing had failed inspection. The only question was scope, how much work was actually being done, and that single answer decided whether an entrance that had functioned fine for years suddenly needed upgrading.
It’s a strange kind of logic once you notice it clearly. The code is not stating whether the building meets the requirement; It is pointing out how much attention you’re drawing to it.
Midrise projects run on a version of that same logic, except the scale and the stakes make it much harder to see clearly. And this isn’t really about midrise as a building type. It’s about the moment midrise is having right now.
Between sixplex zoning changes, the Avenues Policy Review, and a design guideline that got rewritten in 2024 and is already being revisited, there’s more policy in motion under this building type than almost any other right now.
That much movement makes reviewers less certain about which standard will still apply by the time a project breaks ground, and uncertainty tends to produce caution, not clarity.
That’s why a file can be delayed even when the drawings are clean, the code is met, and the engineer has stamped everything.
The comments coming back don’t cite a code section. They’re vague, almost defensive, the kind of language that asks for more justification without saying what it’s justifying against.
Once you notice that pattern, something else becomes obvious too: the developers who move fastest through the building department right now are rarely the ones with the cleanest drawings. They’re the ones who understand what the department is actually afraid of.
What if the pushback isn’t really about your drawings?
Here’s something worth considering, not as established fact, but as a possibility.
Under Ontario’s Building Code Act, a building official acting in good faith carries personal immunity if something goes wrong later, the liability sits with the municipality instead.
That protection exists for a reasonable purpose, reviewers make judgment calls on ambiguous code sections constantly, and nobody could do that job well while personally exposed to every possible outcome.
But protection on paper doesn’t remove the discomfort of interpreting a grey area and putting your name on the decision. So it makes sense that a reviewer facing genuine ambiguity might lean toward the more conservative read, not out of self-interest, but simply because caution is the safer route when a code section doesn’t offer a clear answer.
I don’t know this with certainty, and no reviewer has ever told me this outright.
But it’s worth considering the next time a comment comes back asking for “additional justification” without a code citation attached.
It might not be a technical objection at all. It might be someone working through an ambiguous situation carefully, the way most of us would in their position.
Once you consider that possibility, the conversation can shift. Instead of only arguing a code interpretation, you’re also helping give the reviewer confidence in the decision they’re being asked to make.
That’s a different skill than drafting a good response letter, and it’s one most architecture firms never think to develop, because they assume permitting is purely technical. It isn’t. Not entirely.
Toronto’s 2024 guidelines cleared things up. They also didn’t.
In December 2024, the City of Toronto adopted its consolidated Mid-Rise Building Design Guidelines, replacing the old Performance Standards and addendum. The intent was clarity, one document, applied city-wide, meant to give consistent direction on how mid-rise buildings should be designed and evaluated.
What it gives you is a strong general framework. What it doesn’t give you is case-by-case specificity, and that gap is where things get interesting.
A guideline written to apply across every avenue in the city cannot possibly anticipate every lot condition, every rear transition, every reviewer’s personal read of “appropriate.”
Worth noting too, the city itself hasn’t stopped adjusting. The Avenues Policy Review is still working through its phases, and there’s already talk of revisiting height allowances on certain deep sites.
A document meant to bring consistency is being revised again before most firms have even fully absorbed the first version.
So the real variable in a mid-rise application often isn’t whether you followed the guideline. It’s whether you understand how a specific division, sometimes a specific reviewer, has been applying that guideline in practice over the last year or two.
That knowledge is not in any document you can download. It is in relationships and pattern recognition, which is a nicer way of saying it lives in experience that most firms haven’t bothered to build.
Approving you means answering for the next twenty applicants.
This one is easy to miss if you assume the building department is only judging your building on its own merits.
A reviewer looking at your project isn’t only asking, is this building safe and compliant. They’re also asking, what happens if I approve this and ten other developers point to it next year asking for the same thing.
That question has nothing to do with your specific site, but it shapes how carefully, and how slowly, your file gets handled.
This is why a slightly unconventional but fully compliant design, an alternative stair configuration, a reduced parking ratio, can sit in review far longer than something more conventional, even when both meet every applicable standard.
The hesitation isn’t really about your building. It’s about the department managing what happens after your building. Designs that make it easy for a reviewer to say yes without feeling like they’ve opened a door tend to move. That is worth knowing before you finalize a design, not after you’ve submitted it.
Back to that commercial renovation
My project went ahead with the full fit-out, new partitions, new finishes, and yes, an upgraded entrance to match.
Once I knew the trigger, the path was clear. Do the work, meet the requirement, move on.
Midrise permitting rarely offers that kind of clarity, and pretending it does is probably why so many developers end up frustrated by delays they can’t explain with their own eyes on the drawings.
The honest version is this. Some rejections are about your building. Some are about a reviewer protecting their name, a department protecting its precedent, or a guideline that was never meant to answer every question it raises, especially one still being rewritten under your feet.
Most firms are good at the first kind. Fewer spend much time on the other two, which is probably why some projects glide through review and others face delay for reasons nobody puts in writing.
That renovation taught me something I didn’t expect from what should have been a straightforward fit-out, that code compliance sometimes has less to do with the thing itself and more to do with how much you’ve disturbed around it.
Midrise buildings run on the same principle, just with more zeros attached and a lot less patience for finding it out the hard way.
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