IDEA’s Position Papers

These letters are written and researched by our Policy Committee in response to upcoming changes at City of Edmonton or Government of Alberta. These are shared directly with Administration and Council.

 
 

July 2019 - Missing Middle Zoning Review & RA9 Amendments

On behalf of IDEA, we are writing in support of the above-referenced Zoning Bylaw amendments. These changes will begin the process of streamlining our zoning bylaw and better aligning it with sustainable City goals and medium scale infill development.

IDEA is a community of committed Edmontonians passionate about the positive transformation of our mature and existing neighbourhoods toward people-centred communities. Our diverse membership consists of individuals and businesses who share a forward-looking vision of an Edmonton that is vibrant, walkable, efficient, flexible, resilient, sustainable, and healthy. 

While we support the proposed “missing middle” and RA9 zoning changes, we do have some questions and requested additions to improve the overall chance of success of these amendments. We welcome the opportunity to have a conversation with you about these issues.

1. More Clarity on Purpose and Intent for Row Housing Zones

At present and despite the proposed “missing middle” changes, the circumstances under which rezoning to RF5 and UCRH for row housing would be supported by Administration and Council is unclear. Feedback our members receive from Administration in response to inquiries about rezoning applications consistently favours RF3, to the exclusion of RF5 and UCRH. When should these other zones be used? When and where are they as appropriate, or more appropriate, than RF3? This is an essential question to answer in order for the proposed amendments to be successful. RF3 is a great zone for starter homes, renters and first time home buyers, but in order for row housing to also appeal to a more mature segment of the market, the opportunities provided under the RF5 and UCRH are needed.

Please add clarity to the purpose statements of each of these zones, and especially what differentiates RF5 from RF3 when applying for a rezoning. At present, the sentence in the UCRH purpose statement that states that the zone is a transition zone to be used between low and high density housing is particularly problematic, as there are few sites large enough to allow for this sort of transition in core and mature neighbourhoods; sites are usually very small. If the transition sentence is not removed, we unfortunately do not believe that this zone will be useful in an infill setting.

2. Specific Regulations for Development on Corner Lots facing the Flanking Roadway

The MNO makes reference to the RF3 in some of its regulations to better allow for development on corner lots facing the flanking roadway, but this is not the case for the any other zone under which similar developments can occur. We currently have a member in the concept phase of developing row housing on a large corner lot, but because of the front and rear setbacks required by the MNO, and even in the RA7 zone under the proposed changes, there will be no option but to apply to rezone to DC2. We believe this is unfortunate given the significant work that has gone into the missing middle amendments. The fact is that most infill occurs on corner lots, most often facing the flanking roadway, but the regulations in the zoning bylaw treat this situation as an afterthought rather than the norm. As a result, many unnecessary variances and/or rezonings are required. We strongly request for you to reduce the front and rear setbacks that are required for development on corner lots facing the flanking roadway, in order to reduce barriers for infill to occur in such locations.

3. Gap Between RA8 and RA9

We believe it should be noted that there is currently a significant gap in height and development intensity between the RA8 and RA9 zones. For example, on sites greater than 1800 square metres, the maximum height in the RA8 zone is 23 m and in the RA9 zone it is 58 m, meaning that any building between 6 storeys and ~19 storeys essentially requires a DC2. This is a significant barrier for enabling missing middle development and we strongly recommend that the issue be addressed in a timely manner.


February 2019 - Parking Changes

IDEA’s position on the issue

We support the Open Option parking proposal that City administration is encouraging Council to adopt. 

What we like about the proposal

The Open Option will eliminate parking minimums in the zoning bylaw and allow builders, developers, businesses and homeowners the flexibility to build the parking that makes sense based on geography, other transportation options, cost, demographics, and market.

The Basis for IDEA’s Position on the Issue

Current Situation: Parking is over-supplied throughout Edmonton. Minimum parking requirements inhibit creative development, particularly for the various forms of infill including residential and missing middle housing, and mixed and commercial uses on small and medium-sized sites. Parking minimums increase the cost to build a project and thereby increase costs to home buyers, renters, and businesses.In addition, variances and rezoning to DC2 zones are often utilized to circumvent parking requirements, increasing the time and cost of the development for the City, Council, and developers. Rather than encouraging walkability and vibrancy, main streets and downtown remain fragmented by surface parking creating an undesirable pedestrian experience. There is currently no relationship between land-use, geography and the amount of parking supplied, meaning that parking requirements are not evidence-based or linked to overarching city-building objectives. 

Future Opportunities: As transportation evolves and our City grows and changes it makes sense to enable businesses, homeowners, and developers to make responsive, market-driven decisions for parking supply. Continuing to require and possibly expand parking maximums in key areas will ensure that as a City we can shift our growth toward more people-centered communities. Shared parking and requirements for accessible parking will ensure that those who require it are still able to move freely around our City.

Benefits to IDEA Members, Residents, Businesses and the City of Edmonton: The Open Option for parking will help make infill easier to build and bring down some costs by removing the need for variances or rezoning applications simply to reduce the need for parking.  Less parking in critical areas will help make housing more affordable for families, encourage more creative housing options and “drive change to more people-centered communities.”

Summary

We are excited about the Open Option parking proposal that City administration is encouraging Council to adopt. This option will:

  • Eliminate parking minimums in the zoning bylaw and allow builders, developers, businesses and home-owners the flexibility to build the parking that makes sense based on geography, other transportation options, cost, demographics, and market. 

  • Maintain and encourage regulations that require parking maximums.

  • Enable new regulations to ensure that accessible parking and bicycle parking is provided.

  • Make infill easier to build and bring down some costs by removing the requirement for minimum parking and/or removing the requirement for variances or rezoning applications due to parking design.

  • Help to use land for it’s best use. With the existing regulations, it has created scenarios where we have had to build parking in area’s that should have been used for housing or commercial. Which has subsequently driven up the cost of housing and doing business, which otherwise could have gone into the design, reducing end price or financing another project. 

  • Reduces the amount of time and significant costs we spend on creating spaces for car’s and shifting those resources to creating people-centered spaces.

IDEA would like to reiterate we are in full support of the purposed changes. It will drastically reduce barriers to residential, commercial and mixed-use infill developments.


November 2018 - Operating and Capital Budget

After a review of the Operating and Capital budgets, IDEA is concerned that important City initiatives are unfunded that are essential to moving forward on creating a more economically and environmentally sustainable City through infill and densification. The infill industry improves our financial sustainability, public health, ability to draw in talent from other cities, promotes small businesses, increases housing diversity and is environmentally efficient. The three items below are detrimental to ensuring the success of the development industry.

We strongly encourage City Council to fund the following packages:

  • Impacts of Growth in the City #11: Phase II/III Municipal Development Plan/Transportation Master Plan (MDP/TMP) & Zoning Bylaw Renewal

  • Impacts of Growth in the City #12: Urban Growth - Infrastructure Analysis

  • Impacts of Growth in the City #13: Planning & Development Business Model

Reviewing and renewing our zoning bylaw is essential for moving forward with the new City vision. Industry and communities already struggle with a zoning bylaw that does not meet current needs. As we work to create a more compact, sustainable City, we need bylaws and policy that is forward thinking and aligns with these goals. Without these mechanisms, infill will continue to experience additional hurdles and we will struggle to realize the new City Vision and City Plan.

The Urban-Growth - Infrastructure Analysis is also foundational to the City Plan and to moving forward on infill. If we do not understand the current strengths and weaknesses of our existing infrastructure, prioritizing investment becomes challenging. New tools to facilitate infill are needed, and work has started on this. This is an important priority for leveling the playing field for the infill industry.  

The work being done on the Planning and Development Business Model will help clarify and streamline processes for industry and communities. As of now timelines and uncertainty are stopping medium scale projects around Edmonton.

These three pieces of work are essential for aligning our Vision as a City with our strategic investments. They are all investments in creating a more economically and environmentally sustainable City.

We also encourage Council to invest in our core and mature neighbourhoods through infrastructure projects such as small recreation centers, complete streets, and active transportation infrastructure. These public investments will help drive private investment in the communities where we need to grow.


October 2018 – Garden Suites

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IDEA’s POSITION

What we like:
We appreciate that the data analysis and public engagement results were used to inform the recommended Zoning Bylaw Amendment for Garden Suites.

We support the recommended amendments for accessible design, though we believe it should be linked to an incentive for increased floor area. We also support changing the total building size from 120m2 to 130m2, and the removal of minimum lot size requirements for garden suites.

Our recommendations for improvement:
50 m2 limit on second storey floor area:
We strongly recommend that the 50 m2 limit on second storey floor area be reconsidered and increased. We believe this provision compromises the liveability of the space--if the living space were viable, garden suites could potentially be a family oriented housing option. This change has also effected the the financial viability of building Garden Suites. It substantially increases the cost to have living spaces on two levels and only doing the second floor does not attract a variety of tenants making the risk to high. Many interested homeowners are now walking away from building a suite because of this. In addition, it arbitrarily and unfairly targets infill and not greenfield development; infill is already more difficult--why are we making it more so? And finally, limiting floor area as a means to limit massing is redundant--building mass is already regulated via site coverage and detailed articulation regulations.

Minimum distance from principal dwelling:
This distance should be the same as other accessory buildings at 3m, otherwise this may limit the options in existing situations. This is also larger than a typical house-to-house relationship on 2 adjacent lots, which is usually 2.4m.

Height:
We suggest the removal of the slope requirement in regulation 87.2, as it is in direct conflict with the recently amended 52.1(b). We suggest that the maximum height should read: “The maximum Height shall be 6.5m”.  

Architectural Design:
We consider regulations 15-18 too prescriptive; these regulations place a higher design standard on garden suites than all other forms of housing, including a single detached house on the same lot. This is a double-standard that increases costs for no apparent gain: ie, the suite is behind the house, it is not the focal point on the lot. The rear of a house is often more plain and less imposing than the front. Why are we holding accessory structures to a higher standard than the principal building?

Inclusive Design:
Regulation 93.1.(e) is not in alignment with the Alberta Building Code Section 3.8; and 93.1.(f) may be creating situations where (c), (d), and (e) are not necessary to achieve the desired result.

Summary:
We appreciate the thorough and focused analysis that was completed to develop the proposed garden suite amendments to the Zoning Bylaw. However, we believe key aspects of the proposed amendments need to be revisited in order to ensure that this new housing form is viable in our City.

As it stands, garden suite viability is compromised because:
■      50 m2 is too small
●      Not liveable for a couple or family
●      Not enough return on investment to justify building it--very little market demand for this size
■      Architectural details far exceed what is required for a house. This drives up cost.
■      Site size and coverage regulations are complicated and confusing to try to decipher; these regulations need to be streamlined/simplified. Complicated, hard-to-understand regulations inevitably lead to rework, which drives up the cost of a project.
■      The timeline for approvals is very long, which drives up the cost of a project.  


Our members can attest that there is interest and desire to build garden suites in Edmonton. One industry member has indicated to us that in the last year, of the twelve clients they had who had wanted to build a suite, roughly 25% chose not to proceed (uncertainty with regard to cost/feasibility), 25% are in design phase (with one on hold due to cost), 25% completed design (though one may not apply, one has been a very tough permit, another needed a variance), and roughly 25% of projects were cancelled.

This is a very unfortunate track record. As City builders, we believe we can do better. Can we work together to improve these results?


July 2018 - Semi-detached Housing in RF1 and RF2                       

About IDEA
IDEA promotes and advocates for high quality infill development in Edmonton. Increasing options for housing options —with a strong focus on walkability and local business—is a top priority for our membership.

IDEA’s position on the issue
In 2015 when the City reduced minimum site widths for single detached homes, IDEA advocated that the purposed changed by admin today be made. We are extremely excited to see this come to fruition.

What we like about the proposal

·       That duplex and semi-detached houses are being changed from discretionary to permitted uses.

·       The removal of locational restrictions on semi-detached and duplex housing

·       Allowing multiple subdivisions to increase options for home ownership  

Our recommendations for improvement
In the public engagement section of the report it shows that 19 people are in support, 10 are maybe, and 3 are in non-support, however, the comments read as though the majority are in non-support. Suggest reflecting the amount of comments to mirror the answers.


Review the general purpose statement. We are not sure what the difference is between single detached housing and “infill on narrow lots” both are single family homes. We suggest taking out infill on narrow lots to reduce confusion and the stereotyping that narrow lot homes are different than single family homes.  
              The purpose of this Zone is to allow for Single Detached Housing, infill on narrow lots, Semi-detached Housing, Duplex Housing, Secondary Suites and Garden Suites.

Summary
Statistics show that only allowing semi-detached/duplexes as a permitted use in RF3 lots has barely scratched the surface in our density and infill goals. These purposed changes help support Edmonton’s goals in increasing housing choice in mature and established neighbourhoods. IDEA fully supports these changes and is excited to see options open up for Edmontonians.