IDEA Feedback Letters

These letters are written by our policy team in response to upcoming changes at City of Edmonton or Government of Alberta.


October 2018


Zoning Bylaw Amendment – Garden Suites


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.

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.

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?