February 7, 2021
City Council
City of Edmonton
1 Sir Winston Churchill Square
Edmonton AB, T5J 2R7
RE: February 9, 2021 City Council Public Hearing Item
3.5: Charter Bylaw 19502 - Omnibus Text Amendments to Zoning Bylaw 12800
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
Secondary suites (basement suites) are desirable to help small scale infill projects get off the ground (get financing), and to add housing options to mature neighbourhoods (affordability and choice).
Secondary suites are currently allowed in single detached housing, semi-detached housing (two units attached side-by-side), duplex housing (two units attached up-and-down) and multi-unit housing in the form of row housing (three or more units attached side-by-side).
THE ISSUE
Small scale multi-unit housing includes more than just side-by-side row housing; two other common types of such housing include i) a configuration with two units in the front and two units in the rear (figure 1), and ii) a configuration with two units on the main floor and two units on the second floor (figure 2).
However, secondary suites are not allowed in either configuration 1 or configuration 2. This creates an unintended incentive for side-by-side row housing, which is a problem because:
There are known privacy concerns with side-by-side row housing. When side-by-side row housing on a corner lot faces the flanking side lot line, the rear windows of the row housing units face the neighbour’s backyard. This issue arises repeatedly during City Council Public Hearings for RF1 to RF3 rezoning applications. Yet, the Bylaw encourages the flanking situation by only allowing secondary suites in side-by-side row housing.
Side-by-side row housing requires that each unit be two levels, most commonly with the kitchen and living areas on the main floor and the bedrooms on the second floor. This requires residents to navigate stairs, which many older residents downsizing from a single detached dwelling do not want to do. The Bylaw is inadvertently excluding a key segment of the population that wishes to downsize to a new home in their neighbourhood, but does not want or have the ability to have to navigate stairs as they grow older.
THE PROPOSED SOLUTION
Make an amendment to the definition for secondary suite.
This will help to an even playing field when it comes to secondary suites for all forms of small scale multi-unit housing, rather than continue to incentivize side-by-side row housing, which has had a negative effect by alienate neighbours and older residents.
This proposed solution does not change the height, building envelope, or setbacks for developments.
THE REQUEST
We appreciate all the work that Administration has done on this omnibus amendment to date, and including this change aligns with City Plan and with creating inclusive communities.
We respectfully request that Council make and approve the following motion:
“That the first sentence of the Zoning Bylaw 12800 definition for Secondary Suite be amended as follows: ‘Secondary Suite means development consisting of a Dwelling located within, and Accessory to, a structure in which the principal Dwelling is in a building that is in the form of Single Detached Housing, Semi-detached Housing, Duplex Housing, or Multi-unit Housing in which no more than two principal Dwellings are vertically placed over the other in whole or in part.’”
THE COMMUNITY
IDEA has engaged with EFCL about our proposed amendment. They were generally suppotive as they have also heard the privacy concerns from residents. They did have questions regarding effcts on building code requirements which we analysized with Safety Codes and, Configuration 1 (figure 1) does not have Building Code implications. Configuration 2 (figure 2) would be considered a small apartment building under the Building Code and require the appropriate fire safety rating.
SAFETY CODES
IDEA has engaged with the Safety Codes section of Development Services regarding our proposed amendment to ensure that this could be feasible with regards to code requirements. In our conversations they noted that it is feasible how every they can’t dedicate reourses to creating that processes without it being included in this Omnibus today.
It is important to not that last year, Safety Codes released a document called Design Considerations for Duplexes, with or without Secondary Suite Development Permit approval. This document highlights several of the same considerations applicable to the structure in Figure 1 and 2. Should the definition be amended leading to development of suites in this build‐form, we have experinced builders who will continue work with Safety Codes to provide considerations for obtaining Building Permits if it is required.
We ask you to make this change now, because two years to wait for a new Zoning Bylaw is too long as we have demand for this housing type now. City Plan calls for focus and decisive action on infill, and this change is a quick, simple and cost free solution to help us not only meet our infill objectives but to make sure infill becomes more attainable for more people, sooner.
This change to the definition for secondary suites will create an environment where new forms of innovative, creative infill are possible; forms of infill that are good for neighbours, industry and future residents. This is a win-win-win.
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
Letter sent to Edmonton City Council, Deputy City Manager of Urban Planning and Economy and the Administration Team