June 28, 2021
City of Edmonton
1 Sir Winston Churchill Square
Edmonton AB, T5J 2R7
RE: June 29, 2021 Urban Planning Committee Item 6.7: Glenora Heritage Character Area Rezoning
To: Urban Planning Committee and Administration
The Infill Development in Edmonton Association (IDEA) is the voice of the infill development community in Edmonton. Our purpose is to drive change toward people-centred communities, and we do so through education, research, information sharing and representing the voice of infill on many City committees and before City Council. Our diverse and expanding membership includes builders, developers, consultants, suppliers, and community members.
CURRENT SITUATION
Administration has proposed a DC1 covering a large area of Glenora with the stated intent of heritage preservation.
The DC1 eliminates nearly all opportunities for infill and densification in the area.
We believe Edmonton’s heritage is important and needs to be protected, but the DC1 is not an appropriate, objective, nor well informed approach to doing so.
THE ISSUES
City Plan Infill Target
The proposed DC1 is contradictory to the objectives of the City Plan, most notably the target of 50% of new net units added through infill, city wide, and throughout all residential neighbourhoods. If the City intends to welcome another million residents, individual mature neighbourhoods cannot, and should not be exempt from this vision. The DC1 permits up/down duplex, single detached houses, and secondary suites, with semi detached only permitted along 102 Ave. There is no consideration given to forms of multi-unit housing that do not require the subdivision of lots, such as “manor houses”, or the repurposing and adaptive reuse of existing buildings for multi-unit housing. This lack of flexibility in residential built form options reinforces the absence of missing middle housing types, which the City should be considering as a way to provide more affordable and diverse housing options. As Edmonton’s population grows, its housing needs grow as well.
Transit Oriented Development
The DC1 allows very little densification in close proximity to future LRT stations. LRT stations do not meet their potential to promote active transportation and move more residents from one place to another when more dense residential development is restricted in station areas. This is counter to the vision and objectives of City Plan, and also good transit oriented development. The sustainable buildout of services such as transit is contingent on having a population density that can support it.
Equity and GBA+
The DC1 also fails when examined with the GBA+ and Equity Toolkit. The toolkit is intended to help planners acknowledge assumptions and biases at the stage of writing regulations, to identify social inequities and identity factors, to listen to community perspectives and to explore equity measures. If the City is earnest in its vision to be a place where all are welcome and can thrive, the DC1 is not the path forward.
City Wide Heritage Strategy
The DC1 has been framed by Administration as balancing heritage preservation with other City goals and policies. In reality, the DC1 prioritizes the preservation of large lots and large single family homes at the expense of nearly all other City goals and policies. While heritage preservation is one valid land use objective, it is only one of many, and it should not take precedence over other critical objectives of building a sustainable city. The prioritization of heritage preservation over all other objectives is especially concerning given the lack of a coherent and updated heritage strategy in Edmonton. The existing Heritage Management Resource Plan is over 10 years old, and does not consider the diversity of heritage throughout the City; it continues to be solely focused on European settler history and perspectives. In 2021 it is increasingly imperative for the City to not only recognize the shortcomings of its policies, processes and places, but to also make changes that are system-wide, long lasting and meaningful, in order to minimize social inequity and biases, with their inherent negative consequences on various communities. We recognize that the history and heritage of Glenora has been based on large lots and exclusivity, however, to continue to prioritize this heritage type in 2021 lacks the contextual awareness, understanding, and inclusivity that is needed to align not only with the vision and spirit of the City Plan, but with our increasingly diverse population.
Public Engagement
We understand that Administration has worked on this proposal for the past 2 years, and in its stakeholder engagement, has only sought out feedback from the Old Glenora Conservation Society. While the Society is a stakeholder, this severely limited engagement contradicts good public policy development, and misses the mark on engaging with all those who are directly and indirectly affected by the DC1 proposal. This includes, but is certainly not limited to residents of Glenora, business owners, community leagues (Glenora and adjacent communities), Indigenous groups, not for profit organizations, and the Government of Alberta, and groups such as IDEA. This DC1 would see restrictions placed on existing residences and businesses, stifling future growth, adaptation, and flexibility. The DC1 more accurately seems to focus on preserving large lots under the guise of heritage preservation. There is more to the Garden City which inspired Glenora than large lots; other aspects, such as the street layout, could be maintained without limiting opportunities for housing diversity. This DC1 is not necessary to preserve the history of the Garden City, which is inherently preserved in the street pattern and block layout.
Effective Tools
We do not believe that the DC1 tool will have the intended outcome of preserving heritage buildings or even large lots in Glenora. Homeowners who have had their development rights curtailed by the DC1 are likely to apply to rezone their properties back, and will most likely have their applications supported by Administration because they will comply with overarching City policy. The DC1 will also not stop property owners from demolishing houses on the Inventory of Historic Resources and building new houses in their place.
THE PROPOSED SOLUTION
We strongly recommend putting this proposal on the shelf and redirecting resources in three ways:
Create a Heritage Strategy. Administration needs to determine how to approach heritage through a GBA+ and equity lens, in order to more accurately reflect the current context and needs of the City. The Heritage Strategy should explore up-to-date tools and processes to preserve and celebrate our diverse heritage, including adaptive reuse of buildings and the establishment of a heritage land trust(s).
Enshrine the Glenora Garden City layout in the District Plan policy for the neighbourhood.
Comprehensively figure out how to handle heritage regulations via Zoning Bylaw Renewal. The City’s answer to heritage preservation cannot continue to be a patchwork of inequitable regulations. Zoning Bylaw Renewal could be utilized to create a heritage modifier or overlay that could be applied more broadly in relevant locations throughout the City.
We also strongly recommend a broader scope of engagement on this proposal to more accurately reflect all the affected communities and better inform solutions going forward.
We suggest that the Old Glenora Conservation Society should be empowered to buy properties that they deem important to the neighbourhood so that they can be preserved and used by the community (ie; set up a land trust or similar structure).
We respectfully request that Committee make and approve the following motion:
That Administration’s resources be redirected from the Glenora Heritage Character Area Rezoning project toward i) creating a comprehensive, contemporary Heritage Strategy, ii) enshrining the Glenora Garden City layout in District Plan policy for the neighbourhood, and iii) integrating heritage-related regulations into the Zoning Bylaw Renewal project.
If you have any questions, please contact IDEA any time at mariah@infilledmonton.com or at 780-951-6926.
Sincerely,
Mariah Samji
Executive Director
Infill Development in Edmonton Association