Infill Roadmap Initiative - 2022 Update & Infill Compliance Team Annual Report

April 25, 2022

City Council

City of Edmonton
1 Sir Winston Churchill Square
Edmonton AB, T5J 2R7

RE: April 26, 2022, Urban Planning Committee  

6.1 Infill Roadmap Initiative - 2022 Update
6.2 Infill Compliance Team Annual Report


To Urban Planning Committee, Mayor and City Council: 

The Infill Development in Edmonton Association (IDEA) is an educational and advocacy nonprofit, non-partisan association that represents over 180 city builders and city shapers. Our purpose is to drive change toward people-centred communities within Edmonton’s mature neighbourhoods. The vast majority of our members are small and local businesses, passionate about executing Council’s City Plan goals.

Infill and urban redevelopment helps Edmonton achieve City building goals by creating more attainable housing options in core areas, reusing critical infrastructure, and reducing the high financial, environmental and social costs of long commutes in single-passenger vehicles.

6.1 Infill Roadmap Initiative

In 2014 Edmonton recognized the citywide benefit of infill for our city and undertook its first infill roadmap, focused on low-density residential infill. In 2018 we as a City took steps forward again to reduce barriers and create processes and systems that benefited all stakeholders of infill development, this time focused on small to medium-sized residential development.

Fast forward to today, and we’re certainly seeing the roadmap outcomes in action on the ground, with some mature neighbourhoods receiving an influx of new residents, supporting schools as well as local shops and services. However, there is still so much work to be done.

Every week new and significant site-specific and citywide issues arise for medium-scale residential, mixed-use and local commercial projects. These barriers mainly revolve around infrastructure and servicing issues, a legacy of the fact that for 100 years we built a suburban, car-oriented city. If we do not address these barriers we will not achieve our energy transition targets nor our density goals. 

In the post-roadmap era, we ask that you double down on your support for infill and urban redevelopment by prioritizing a holistic infill infrastructure and servicing strategy in the upcoming municipal budget and in your day-to-day decision making.

6.2 Infill Compliance Team Annual Report

In 2019 IDEA, in partnership with the City of Edmonton, created and deployed the first installment of the Builder Education Program. To date the program has been delivered five times. This program was designed to be a win-win-win scenario for the community, industry and the City. This program is a five day education certification program that includes courses on Design 101, Development Permits, Building Permits, Infill Best Practices for Construction, and Communication and Community Relations. Successful participants qualify for expedited permits for certain Class A, small scale infill projects. 

The Builder Education Program supports the community by having more educated builders in their neighbourhoods, the infill industry by reducing permit timelines by more than 50%, and creating certainty in the process. The program also supports the City by improving the quality of applications and increasing the number of complete applications. Since 2019 over 60 companies have gone through the Builder Education Program and complaints have decreased by over 50%.

IDEA is supportive of increasing education and having more staff for inspections, enforcement and compliance. Infill and urban redevelopment has increased and will continue to increase, and with it, so should our educational resources. We are moving in the right direction.

Thank you to Administration for their hard work over the past decade to bring us to this point.  

Thank you for your time. If you have any questions please contact IDEA via Mariah Samji at mariah@infilledmonton.com or 780-951-6926.

Sincerely,

Letter sent to Edmonton City Council, Deputy City Manager of Urban Planning and Economy and the Administration Team

IDEA Letter to Urban Planning Committee - Zoning Bylaw Renewal and District Planning April 2022

April 8, 2022

City Council

City of Edmonton
1 Sir Winston Churchill Square
Edmonton AB, T5J 2R7

RE: April 12, 2022, Urban Planning Committee 

6.2 Zoning Bylaw Renewal Report #4 - Proposed Zones, Initiative Update and Next Steps
6.3 District Planning Authorization and Engagement Approach


To Urban Planning Committee, Mayor and City Council: 

The Infill Development in Edmonton Association (IDEA) is an educational and advocacy nonprofit, non-partisan association that represents over 180 city builders and city shapers. Our purpose is to drive change toward people-centred communities within Edmonton’s mature neighbourhoods. The vast majority of our members are small and local businesses, passionate about executing Council’s City Plan goals.

IDEA has spoken previously about the need to update and retire old, inequitable policies and regulations that do not align with City Plan. The Zoning Bylaw renewal and District Planning Project are essential to this work.

Zoning Bylaw Renewal

IDEA’s objective is to help facilitate equitable infill development that meets the needs of Edmontonians. Today's zoning bylaw, processes and technology do not support the redevelopment of our City. As we are still at the early stages of this project, we ask that Council monitor and ask constructive questions about the following: 

  • How will new zones be providing housing options that meet the needs of different user groups, including families (with and without children), single people, and the elderly?

  • How will commercial uses be integrated into neighbourhoods, in order to create 15 minute communities?

  • How will infrastructure data be made public so that those investing in our communities have an understanding of costs, upfront?

  • How will these new zones prioritize changes that allow for sustainable development?

  • How do the new zones support future-oriented vibrant nodes and corridors through vertical and horizontal mixed-use projects with community-oriented uses?

  • How can we automate non-complex permits for both infill and greenfield to create equitable building processes and timelines

  • How is the GBA+ and Equity Toolkit being used in this renewal to support diverse stakeholder needs as we build a City for everyone?

  • Do these zones support simpler regulations and processes for infill development, in alignment with City Plan?

  • What will the education for all those affected by a new zoning bylaw look like: community, industry and internal City staff?

  • How will this support the creation of vibrant communities that bring Edmontonians together

District Planning
The District Planning project is an incredibly important step to retiring completed policies that no longer serve the needs of today's and tomorrow's communities.

How to support:
Please support the preparation of district plans and the district general policy as required by The City Plan Policy 2.3.2.2

IDEA wants to thank the Zoning Bylaw Team and the District Planning Team for all of their work to date and everything that is to come. These are milestone projects for Edmonton and need support if we are to achieve the goals in City Plan. The changes may feel uncomfortable, however, the results will bring Edmonton’s diverse communities together. 

Thank you for your time. If you have any questions please contact IDEA via Mariah Samji at mariah@infilledmonton.com or 780-951-6926.

Sincerely,

City Council Item 6.9, Multi-Unit Strategy - Alternative Business Model

March 30, 2022

City of Edmonton
1 Sir Winston Churchill Square
Edmonton AB, T5J 2R7

RE: April 4, 2022, City Council Item 6.9, Multi-Unit Strategy - Alternative Business Model


To Mayor and City Council: 

The Infill Development in Edmonton Association (IDEA) is an educational and advocacy nonprofit, non-partisan association that represents over 180 city builders and city shapers. Our purpose is to drive change toward people-centred communities within Edmonton’s mature neighbourhoods. The vast majority of our members are small and local businesses, passionate about executing Council’s City Plan goals.

We are excited to see proposed options for achieving our 25-year goals with a 90 percent waste diversion target across all sectors. IDEA’s values center around building a sustainable City and we believe that waste management plays a large role in achieving those goals.

Background
In 2019 City Council decided to move away from collecting any commercial waste in the City of Edmonton. At that time IDEA was not involved in the conversation around the effects of that change on mixed-use and small multi-unit sites. The City currently collects all residential waste and no commercial waste.

Context and Concerns 

  • Mixed-use buildings contain both residential and commercial uses. Because of the City’s waste pick-up standards, such buildings require two separate waste pick-up operations: bins/carts and pick-up schedule for the residential use (which the City picks up) and separate bins and pick-up schedule for the commercial use (which a private contractor picks up). This creates both an operational challenge—to coordinate separate pick-up schedules—as well as a site planning challenge, with additional land that must be set aside for waste storage, rather than being used for housing or amenities. This is an unnecessary barrier for those who are looking to build in on small lots in nodes and corridors in alignment with City Plan.

  • Some of Edmonton’s small and medium-sized multi-unit sites do not have lane access, creating operational challenges for pick up, in that turning maneuvers for the City’s fleet of large-sized waste vehicles must occur on site. This is almost always impossible to achieve on a small site. This issue is related to Developer Standards.

Potential Solutions

1) Remove barriers to mixed-use developments through a review of the 2019 ICI policy 

What is needed on small sites is flexibility in waste storage and pick-up, as such sites are already difficult to design and build (hence the missing middle). Please review the 2019 ICI (Industrial, Commercial and Institutional) policy to review whether separate residential and commercial waste storage and collection are really necessary for small and medium-sized mixed-use sites. We believe it poses an unnecessary barrier to mixed-use development.  

2) Prioritize the update of the Developer Standards  

Concerns around site planning, waste storage, and waste pick up may be able to be mitigated through an update to the Developer Standards to align its priorities with City Plan.  

City Plan Alignment
4.2 Edmontonians live closer to what they need and are supported by walkable communities, active transportation networks and greater connectivity across all travel modes.

4.2.1.3 Adapt City operations, equipment and infrastructure to contribute to intensification.

IDEA would like to see Edmonton move to a three-stream communal collection system with a priority set on facilitating mixed-use and small-scale infill sites as outlined in Edmonton’s City Plan. We believe this three-stream system will help us better take care of our environment and we thank Administration and Council for their commitment to our future. We believe this objective can and must be achieved in tandem with facilitating mixed-use and multi-unit development on small and medium sized infill sites. Please prioritize the review of the ICI policy and the Developer Standards.

Thank you for your time. We request a meeting with you prior to April 4, 2022 to discuss the issues surrounding infill and waste collection. If you have any questions please contact IDEA via Mariah Samji at mariah@infilledmonton.com or 780-951-6926.

Sincerely,

IDEA Letter - Omnibus Text Amendments to Zoning Bylaw 12800 - Feb 2021

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

Multi-Unit Waste Strategy - Alternative Business Model

March 21, 2022

City of Edmonton
1 Sir Winston Churchill Square
Edmonton AB, T5J 2R7

RE: March 25, 2022 Utility Committee Item 6.2, Multi-Unit Strategy - Alternative Business Model


To Members of Utility Committee: 

The Infill Development in Edmonton Association (IDEA) is an educational and advocacy nonprofit, non-partisan association that represents over 180 city builders and city shapers. Our purpose is to drive change toward people-centred communities within Edmonton’s mature neighbourhoods. The vast majority of our members are small and local businesses, passionate about executing Council’s City Plan goals.

We are excited to see proposed options for achieving our 25-year goals with a 90 percent waste diversion target across all sectors. IDEA’s values center around building a sustainable City and we believe that waste management plays a large role in achieving those goals.

Background
In 2019 City Council decided to move away from collecting any commercial waste in the City of Edmonton. At that time IDEA was not involved in the conversation around the effects of that change on mixed-use and small multi-unit sites. The City currently collects all residential waste and no commercial waste.

Context and Concerns
City Plan contains policy to support mixed use development in nodes and corridors throughout the City, and the Zoning Bylaw Renewal team is currently creating mixed-use zones to implement City Plan policy. 

However, our current waste and transportation standards present an operational barrier to facilitating mixed-use and multi-unit development on small and medium sized infill sites. 

  • Mixed-use buildings contain both residential and commercial uses. Because of the City’s waste pick-up standards, such buildings require two separate waste pick-up operations: bins/carts and pick-up schedule for the residential use (which the City picks up) and separate bins and pick-up schedule for the commercial use (which a private contractor picks up). This creates both an operational challenge—to coordinate separate pick-up schedules—as well as a site planning challenge, with additional land that must be set aside for waste storage, rather than being used for housing or amenities. This is an unnecessary barrier for those who are looking to build in on small lots in nodes and corridors in alignment with City Plan.

  • Some of Edmonton’s small and medium-sized multi-unit sites do not have lane access, creating operational challenges for pick up, in that turning maneuvers for the City’s fleet of large-sized waste vehicles must occur on site. This is almost always impossible to achieve on a small site. This issue is related to transportation standards.

Potential Solutions

1) Remove barriers for mixed-use development on infill sites

What is needed on small sites is flexibility in waste storage and pick-up, as such sites are difficult to design and build (hence the missing middle). We are not certain at this time that the proposed cart system will provide the flexibility needed for site planning, nor the agility and frequency needed for pick up, as updated standards have not yet been developed (see point #2, below). We recommend leaving the door open for local waste companies being a part of the collection solution, as they can potentially pick up garbage more frequently and with smaller vehicles. We understand that a fee may still need to be paid to the City to account for waste education, diversion and processing. 

2) Prioritize the update of the Waste Storage Guidelines 

Concerns around site planning, waste storage, and waste pick up may be able to be mitigated through an update to the Waste Storage Guidelines and Access Management Guidelines. However, our understanding is that work on this update has not yet begun. Until this work is complete, our request to Committee is to hold off on making a final decision on who picks up waste for mixed-use and multi-unit buildings on small and medium sized infill sites.  

City Plan Alignment
4.2 Edmontonians live closer to what they need and are supported by walkable communities, active transportation networks and greater connectivity across all travel modes.

4.2.1.3 Adapt City operations, equipment and infrastructure to contribute to intensification.

Proposed Motion

“That Administration, with engagement from stakeholders, facilitate mixed use and medium scale residential development through a comprehensive update to the Waste Storage Guidelines and Access Management Guidelines, which may include private fee-for-service for mixed use and/or multi-unit collection, with the aim to achieve three stream collection and diversion rate targets as set out in the March 25, 2022, City Operations report CO00581rev and return to Committee in Quarter 1, 2023.”

IDEA would like to see Edmonton move to a three-stream communal collection system with a priority set on facilitating mixed-use and small-scale infill sites as outlined in Edmonton’s City Plan. We believe this three-stream system will help us better take care of our environment and we thank Administration and Council for their commitment to our future. We believe this objective can and must be achieved in tandem with facilitating mixed use and multi-unit development on small and medium sized infill sites.

Thank you for your time. We request a meeting with you prior to the meeting to discuss the issues surrounding infill and waste collection. If you have any questions please contact IDEA via Mariah Samji at mariah@infilledmonton.com or 780-951-6926.

Sincerely,

Letter sent to Edmonton City Council, Deputy City Manager of Urban Planning and Economy and the Administration Team

Enterprise Land Development Program & City Plan Implementation

Edmonton City Council

1 Sir Winston Churchill Square
Edmonton, AB T5J 2R7

February 4, 2022

Dear Mayor and Council,

RE: Enterprise Land Development Program & City Plan Implementation

ABOUT IDEA

The Infill Development in Edmonton Association (IDEA) is an educational and advocacy nonprofit, non-partisan association that represents over 180 city builders and city shapers. Our purpose is to drive change toward people-centred communities within Edmonton’s mature neighbourhoods. The vast majority of our members are small and local businesses, passionate about executing Council’s City Plan goals. 

THE ISSUE

IDEA is currently working with Administration on multiple City Plan implementation projects including Zoning Bylaw Renewal, District Planning, the Energy Transition Strategy and the Growth Management Framework. IDEA is interested in the Enterprise Land Development Program specifically because of the opportunities that divestment can create for supporting City Plan implementation. 

IDEA is concerned that the City doesn’t have a financial plan or dedicated funds for implementing City Plan’s goal of shifting 50% of new development to mature neighbouhoods. Most infill builders and developers are small, local businesses ready to execute City Plan, and they need your help. Reinvesting in mature neighbourhoods is a wise move from a fiscal and environmental perspective—reusing existing infrastructure reduces the tax burden on all of us and helps create a more compact and climate resilient city.

Administration recently completed an infrastructure capacity review that estimates the cost of City Plan implementation for water, drainage and shallow utilities in the range of $500,000,000 - $600,000,000. The EPCOR Infill Cost Share Program has shown that dedicated infrastructure funding works: it allows for missing middle projects to proceed that would otherwise be stalled due to the high cost of required infrastructure upgrades. However, we still do not have a holistic solution to the ongoing challenge of infrastructure deficiency in mature neighbourhoods.

PROPOSED SOLUTION

IDEA asks that City Council maintain the decision to divest from suburban residential development and redirect proceeds from the land sales to addressing the very real barriers to achieving City Plan infill objectives, including the infrastructure deficiency. Proposed motion:

That Administration i) proceed with the sale of Aster, Schonsee and Goodridge Corners and simultaneously ii) put together a City Plan infrastructure implementation plan that includes how proceeds from the sale of Aster, Schonsee and Goodridge Corners will help to address infrastructure deficiencies within nodes and corridors.

Thank you for your time. If you have any questions or wish to discuss any of the contents of this letter, please contact IDEA via Mariah Samji at mariah@infilledmonton.com or 780-951-6926.

Sincerely, 

Letter sent to Edmonton City Council, Deputy City Manager of Urban Planning and Economy and the Administration Team

Proposed Amendments to RA7 and RA8 Zone - Missing Middle Zones

Edmonton City Council

1 Sir Winston Churchill Square
Edmonton, AB T5J 2R7

December 2, 2021

 

Dear Mayor and Council,

 

RE: Proposed Amendments to RA7 and RA8 Zones 

 
Thank you for taking the time to hear from the Infill Development in Edmonton Association (IDEA). IDEA is an education and advocacy nonprofit, non-partisan association that represents over 180 city builders and shapers who are passionate about creating people-centred communities within Edmonton’s mature neighbourhoods. 

BACKGROUND

In 2019 IDEA worked closely with Administration on proposed amendments to the RA7 and RA8 zones in what was known as the “missing middle” amendments to Zoning Bylaw 12800. The purpose of these amendments was to update our medium scale zoning tools so that they would be usable in a modern, infill context. The amendments were very successful and since being approved by City Council in 2018 we have witnessed a proliferation of rezoning and development permit applications for medium scale zones, in alignment with City Plan objectives. The RA7 zone allows for four storey buildings and the RA8 zone allows for six storey buildings.

ADMINISTRATION’S PROPOSED AMENDMENTS

The current proposed amendments to the RA7 and RA8 zones are led by Administration to increase side setbacks from the property line for development on RA7/8 lots that are beside single detached dwellings. The larger setbacks would apply in all locations, regardless of whether the area has been identified for redevelopment (such as within nodes or along corridors). 

We understand that the proposed amendments are Administration’s response to the growing pains that we are beginning to experience as we start to implement City Plan and transition to a city of 15 minute communities. However, we do not believe that additional side setbacks will solve the deeper problem of discomfort with change: that problem can only be addressed over time, through leadership and clear communication about the benefits of infill as it relates to climate change, health, social wellbeing, and many other factors.

GBA+ AND EQUITY

Reviewing the proposed amendment through an equity lens, we note that the increased setbacks are only being required for sites that are located next to low-density residential development. This appears to prioritize existing single-detached housing (and the people who live in that housing) at the expense of denser forms of housing. As mentioned, this is the case even in nodes and corridors, where the housing form is envisioned to shift to medium scale housing over time. 

IDEA recognizes the importance of equitable zoning and is pleased that all new regulations proposed in the Zoning Bylaw Renewal project will be created using the GBA+ and Equity Toolkit.

IF CHANGES ARE DEEMED TO BE NECESSARY 

IDEA believes that the RA7 and RA8 zones as approved in 2018 do not require further amendment at this time. However, as the RA7 and RA8 zones are crucial tools in the medium scale toolkit, it is imperative that Administration feel comfortable supporting applications for these zones, and that Council feel comfortable approving missing middle applications. 

 

As a result, IDEA worked closely with Administration to reduce the impact that larger setbacks would have on the feasibility of small to medium scale development on small and medium sized sites (sites consisting of approximately one to three lots). 

 

If Council deems that changes are necessary, we have two requests:

  1. That the impact of the larger setbacks be monitored and that a report be returned to Council in Quarter 3 of 2022, and

  2. That the required building stepback in the RA8 zone be reduced from three metres to two metres or less to allow for more livable space. 

 

PROPOSED RA8 REFINEMENT

With regard to the RA8 refinement suggested above, we make this request because the difference of one metre will not make a notable difference in the aesthetic or impact of the building from the exterior, but the one metre will have a significant impact on unit sizes and livability of the interior living spaces for residents. You can see the minimal visual difference that a smaller stepback would make in figures 1 and 2 below.

Figure 1: 23-metre high building with 3 metre stepback at 14.5 metres in height 

(Current Proposed)

Figure 2: 23-metre high building with 2 metre stepback at 14.5 metres in height 

(Suggested Refinement)

This change could be made through the following motion:

That the proposed minimum Side Setback from the Abutting Lot line for any portion of the building over 14.5 m in Height in Section 220.4.6.b be changed from “6.0 m” to “5.0 m.”

To conclude, we appreciate the effort to create viable standard zones. We look forward to continuing to work together as your city-building partners to help realize the goals of City Plan.



Sincerely, 




Chelsey Jersak
President 
Infill Development in Edmonton Association 

 

Mariah Samji
Executive Director
Infill Development in Edmonton Association 


This letter was sent to Edmonton’s Honourable Mayor and City Council - Dec 2, 2021

Enterprise Land Development Program Q4 2021

Edmonton City Council

1 Sir Winston Churchill Square
Edmonton, AB T5J 2R7

December 2, 2021

Dear Mayor and Council,

RE: Enterprise Land Development Program

Thank you for taking the time to hear from the Infill Development in Edmonton Association (IDEA). IDEA is an education and advocacy nonprofit, non-partisan association that represents over 180 city builders and shapers who are passionate about creating people-centred communities within Edmonton’s mature neighbourhoods. Collectively our industry members generate more than 2,500 jobs in Edmonton. 

IDEA is currently working with the city on multiple City Plan implementation projects including Zoning Bylaw Renewal, District Planning, the Energy Transition Strategy and the Growth Management Framework. We are interested in the Enterprise Land Development Program specifically because of the opportunities that divestment can create for supporting ongoing city building work aligned with City Plan.

IDEA recommends that City Council maintain the decision to divest from residential

development and redirect proceeds to vital City Plan objectives. For example, densification of nodes and corridors requires significant upgrades to our city’s infrastructure capacity—this is a major challenge, and a challenge that requires a holistic solution: infrastructure upgrades cannot be funded long term on a piecemeal basis if we hope to achieve the objectives of City Plan. We strongly recommend that the City maintain its decision to move away from land development and focus instead on its role to create systems, processes and policies to facilitate high quality development in alignment with City Plan objectives.

We look forward to continuing to work together as your city-building partners to help realize the goals of City Plan.


Sincerely, 



Chelsey Jersak
President 
Infill Development in Edmonton Association 

 

Mariah Samji
Executive Director
Infill Development in Edmonton Association 


This letter was sent to Edmonton’s Honourable Mayor and City Council - Dec 2, 2021

2021 Edmonton City Budget Adjustment

Edmonton City Council

1 Sir Winston Churchill Square

Edmonton AB, T5J 2R7 


November 21, 2021 

Dear Mayor and Council,  

RE: Edmonton 2022 Budget;  Infill Issues and Opportunities

The Infill Development in Edmonton Association (IDEA) looks forward to working with you over the next four years to drive change toward people-centred communities. IDEA is proud to have been an active collaborator with the City on a number of infill-related projects over the past many years, including the Builder Education Program and Expedited Infill Pilot, as well as the Infill Cost Share Program. We look forward to continuing to work together as we collectively implement the ambitious objectives of City Plan.

ABOUT IDEA

The Infill Development in Edmonton Association (IDEA) was founded in 2013 with a mission to promote and advocate for high-quality infill development within Edmonton. Our vision is for Edmonton’s existing neighbourhoods to flourish as complete communities with diverse housing and healthy lifestyle choices. Our diverse and growing membership is made up of builders, developers, planners, architects, engineers and suppliers, in addition to dedicated community members. We are a nonprofit, non-partisan, volunteer-driven organization supported by one full time employee.

 

THE BUDGET

The 2022 budget presents a huge opportunity to align fiscal priorities with City Plan. Many City Plan objectives will be largely implemented through infill and urban redevelopment, including the intensification of nodes and corridors. However, the primary mechanism of intensification--medium scale development--remains challenging for a variety of reasons. As City building partners, we request that you keep the following matters in mind as you deliberate the budget.

  1. Water Infrastructure 

    • At project inception, infrastructure upgrade costs are often unknown and unpredictable.

    • Infrastructure in mature neighbourhoods is outdated, and upgrades for individual projects can range from tens of thousands of dollars to millions. These infrastructure upgrades often provide benefits to the broader community, but the cost is shouldered solely by the new residents.

    • The City needs a mechanism to holistically and systematically deal with infrastructure upgrade needs across the City in order to achieve the type of densification envisioned in City Plan. The Infill Cost Share Program is an important step in the right direction, but it is limited in funding and scope.

  1. Waste Collection

    • Most infill sites are small sites; City Plan calls for mixed use development in nodes and corridors. The complicating factor is that the city mandatorily collects residential waste but does not collect commercial waste. This means that commercial/residential mixed use developments must accommodate separate bins and separate service for the collection of residential and commercial waste, resulting in unnecessarily complicated site planning and site servicing. We need to update the Waste Strategy in order to allow for flexible solutions for waste collection, which may include acquiring smaller waste collection vehicles, as the current system has an undue impact on small and medium sized infill sites.

3. Fees 

  • Tree Permits: IDEA firmly supports tree protection. We believe that tree protection should be accomplished through a tree protection bylaw and through public education, rather than a new and unwieldy permitting process. However, the city has demonstrated its preference to have a permit. As a result, we request that the city attach no new fees to this permit. Tree protection is a partnership: industry already pays to protect city trees; the city should cover the fee for its desired permit. We do not support new permit fees.  

  • Land Development Application fees: The proposed 2022 fee increases for land development applications are substantial, as City Administration has acknowledged. As opposed to a flat fee increase, we request your consideration of fee increases scaled to minimize the impact on small and medium sized infill projects, which are typically located on small sites in mature areas and face numerous other financial challenges.

Thank you for the opportunity to highlight some of our priorities for this budget; we look forward to working closely with you in the future as we build our city together.

Please feel welcome to contact IDEA any time at mariah@infilledmonton.com or at 780-951-6926.



Sincerely,

 

Chelsey Jersak

President 

Infill Development in Edmonton Association

This letter was sent to Edmonton’s Honourable Mayor and City Council - Nov 21, 2021



IDEA Letter - Glenora DC1 2021

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,

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Mariah Samji
Executive Director 
Infill Development in Edmonton Association

IDEA Letter - Infill Fire Protection Program

1 Sir Winston Churchill Square
Edmonton AB, T5J 2R7
City of Edmonton

June 24, 2021


Re: Infill Fire Protection Program 

Dear Mayor and Utility Committee,

Infrastructure deficits and costs are some of the biggest barriers to medium-scale development projects in North American cities. Over the past two and a half years, the City of Edmonton, EPCOR and IDEA have worked together to pilot and collect data in an innovative way to rebuild our public infrastructure. Through the Pilot Program, we were able to help fund seven missing middle projects that help to diversify neighbourhoods, better utilize existing infrastructure and create a program that would help distribute costs fairly to all users.

Recap of the Pilot Program: Thirty-four development projects were submitted to the Pilot project for review and the seven highest-ranking projects were selected for funding. Six development projects for low-rise apartment buildings and one row house style development (112 units of housing in total) were supported with funding from the Pilot project. The Pilot project was not able to support more projects due to funding constraints. Projects that ranked highly were typically missing middle style developments near transit priority corridors as defined by the Bus Network Redesign and transit/LRT stations. Costs of fire protection upgrades eligible for Pilot project funding ranged from $60,000 to $475,000 per development project.

At the beginning of the Pilot Program, we did not know how many projects were unable to move forward because of deficient water main infrastructure, and high costs. Through this pilot, we were able to gain a better understanding of future infrastructure demands to support what the infill industry is building. After the pilot, we surveyed those who applied for the funding and 50% of the applicants that followed up through a survey said that the reason the project didn’t move forward was because of high infrastructure costs.

We wanted to take this opportunity to say thank you to City Council for taking the bold move and funding the pilot. We want to thank EPCOR and City Administration for working with us over the past years to get us to this point. We ask that Utility Committee approve the creation of a permanent Infill Fire Protection Program with $20 million in funding over the next five years as it will without a doubt help to achieve our City Plan goals.

Sincerely,

mariah signature.PNG

Mariah Samji
Executive Director
Infill Development in Edmonton Association 

Zoning Bylaw Workbooks - June 2021

July 8 2021

Zoning Bylaw Renewal Team

10111 104 Ave NW

Edmonton AB, T5J 0J5



RE: Zoning Bylaw Renewal June 2021 Workbooks

To: Zoning Bylaw Renewal Team

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 is made up of small businesses and includes builders, developers, consultants, suppliers, as well as community members.

IDEA continues to support the overall approach to Zoning Bylaw renewal and the prioritization of GBA+ and equity considerations. Our feedback on the June 2021 Zoning Bylaw Renewal Workbooks and our priorities, which have been shared with your team throughout the engagement process, are below.

APPROACH FOR ZONES 

Overall we are supportive of the approach for zones. We believe that a large reduction in the number of zones is necessary to provide more flexibility in the uses and built form of our city’s neighbourhoods. It will be important that the new zones are not too broad, as this could create a push for some development to be done under direct control zoning or to introduce new overlays to create more certainty for Council and communities. Having the right number of zones will help to provide this certainty and reduce resistance to change from the community.

We also support the hybrid approach with form-based and use-based zoning and look forward to the increased diversity and mix of uses it can create. We feel that a key element in the success of this approach will be ensuring that Development Officers are well trained in the nuances of form-based zoning and that they are empowered to confidently make decisions under this new framework.  

APPROACH FOR USES 

We also support the approach for uses, as the current separation of uses with similar activities and impacts creates unnecessary bureaucratic hurdles. This is also consistent with the notion of creating complete neighbourhoods that provide a broad range of housing, work, educational and recreational opportunities for the local residents. The new uses will need to be clearly defined without being overly prescriptive. Conditional uses should not merely become replacements for discretionary uses and the conditions under which they are allowed must be clear.  A large part of the work in reducing the number of uses will need to be around how we get the public and Council to embrace more uncertainty about what can be built in a neighborhood.  

APPROACH FOR RESIDENTIAL AREAS

Our membership is also supportive of having fewer residential zones and only one residential use, as we do not believe that different building configurations constitute different uses. Uses should be based on activities rather than built form. Again, it will be crucial to create the right number of zones to reduce reliance on direct control zones. We are curious about how up-zoning and down-zoning will work, and how that will be communicated to the public and property owners, and would like to see some examples about how these practices have been implemented in other cities.


DATA AND STORYTELLING

IDEA is optimistic about the direction this project is taking. We believe that communicating to the public through data and storytelling about how the new zoning bylaw will help to implement the City Plan vision is also essential. Relevant information on the way that more diverse housing, connected communities and mixed-use development contribute to prosperous neighbourhoods can be drawn from organizations such as the Chamber of Commerce, ETS, the Public and Catholic School boards, and the BIAs. We would be happy to discuss this further with you if you have any questions.


Please feel welcome to contact IDEA any time at mariah@infilledmonton.com or at 780-951-6926.

Sincerely,

mariah signature.PNG






Mariah Samji
Executive Director
Infill Development in Edmonton Association


Draft Bylaw for Tree Preservation and Protection

1 Sir Winston Churchill Square
Edmonton AB, T5J 2R7

City of Edmonton


May 21, 2021


Re: Bylaw for Tree Preservation and Protection


Dear Mayor and Council,

Thank you so much for taking the time to hear from IDEA and its members today. IDEA has been engaging with the City of Edmonton on this draft bylaw since 2017. We have attended numerous engagement sessions, worked with the consultant to provide examples of real-world situations, and helped to create and share with our members the current tree protection and preservation plans the City of Edmonton uses. We have also had Forestry present at every iteration of our Builder Education Program, to share in detail why mature trees are important and how to protect trees in our City. This is all to say that we are heavily invested in protecting Edmonton’s trees.

IDEA is in full support of having a tree bylaw to help create consistency in protection practices. A bylaw will also help to create more educational material for both industry and homeowners to become informed.

However, we are asking that Council direct Administration to put resources into bylaw education and move entirely away from creating a new permit.

As stated in Administration’s presentation, there have been 196 work sites in poor condition, and with tree damage, between January 2019 and April 2021. In this time period over 9500 building permits were approved for residential construction alone. That is 2% of sites. This relates to the conversation at Urban Planning Committee we had in January of this year, where we all acknowledged that there is a very small percentage of bad actors. Instead of focusing our resources on that issue, the proposed permit will penalize everyone with a new permit we don’t have the resources to fund or enforce.

The bylaw will be applicable to not just developers but also other users like homeowners and small contractors; there will be an initial learning curve for all users on what the expectations are. We need to dedicate resources to creating educational materials and campaigns to ensure awareness and the bylaw’s ultimate success. Without this, homeowners working on their front lawns won’t know when they are in violation of the bylaw.


IDEA also suggests that we take this opportunity to make more efficient use of the resources we already have. At present, there are on average 12 site inspections for residential projects. We suggest that training be offered to inspectors to look for violations to the bylaw. We would also like to note for Council that anyone who is currently applying for a building permit must provide a tree protection plan and needs to apply for an OSCAM permit when crossing a boulevard within five metres of a city tree.

We thank Administration for their efforts on this bylaw, however, we do believe that starting with a Bylaw and education will lead to the outcomes Edmonontians are looking for without creating new processes and permits that cost homeowners extra fees, as well as builders extra fees on top of the costs of tree protection and all of the other fees that are currently associated with infill, including development permits, building permits, OSCAM permits, infrastructure upgrade requirements, etc. 


Let’s work together to build beautiful people-centred communities that people can afford and trees can flourish.

Sincerely,

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Hani Barzagar
President of Infill Development in Edmonton Association

 
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Mariah Samji
Executive Director
Infill Development in Edmonton Association

This letter has been shared with the Mayor, City Council and Administration

Top Barriers to Infill Development

The Infill Development in Edmonton Association (IDEA) was founded in 2013, with a mission to promote and advocate for high-quality infill development within Edmonton. Our vision is for Edmonton’s existing neighbourhoods to flourish as complete communities with diverse housing and healthy lifestyle choices.

Our membership is made up of builders, developers, planners, architects, engineers, community members, suppliers, and other professionals that work within the development industry. We currently have over 180 members and are growing every year. 

Top Barriers to Infill Development

  1. Infrastructure 

    • At project inception, infrastructure upgrade costs are unknown and unpredictable. The City and utility providers do not share information that would allow infill builders to clearly understand the costs and test those costs in their pro formas. Water main upgrades for fire protection range from $40,000 - $2.4 million. Relocation of power services can cost between $45,000 - $2 million. Laneway renewals can cost between $250,000 - $450,000. Asbestos remediation costs can cost between $30,000 - $45,000. 

    • Further, we do not have a mechanism to holistically and systematically deal with infrastructure upgrade needs across the City, so it is up to infill builders and developers to pay to upgrade City infrastructure on an ad hoc, piecemeal basis. 

    • Utility hook-ups are unnecessarily expensive. Industry should be able to use contractors.

  2. Permits and Process 

    • The City of Edmonton does not currently have permit approval targets for each of their development permit application types. 

    • The City of Edmonton’s online portal gives little information to applicants once permit applications are submitted, which could be used as an effective communication tool, increasing transparency and reducing frustration.

  3. Land Use Policy and Regulations

    • Our current regulations are outdated; it is widely accepted that we need to move forward to align our land use planning and regulatory framework with City Plan. City Plan implementation via Zoning Bylaw Renewal and District Planning should be top priorities. 

  4. Fees 

    • A comprehensive review of how much in fees each style of development project costs. Those who are building should predictably know what fees and carrying costs they can expect beforehand.

  5. Financial Incentives 

    • Medium-scale development from 4 units to 8 stories is incredibly difficult to finance and has high risk brought on by contradictory planning policy, and uncertainty in approval processes and infrastructure upgrade costs. Medium-scale developments need creative financial assistance, such as but not limited to property tax relief until a new project is occupied.

This letter was shared with Andre Corbould, City Manager, City of Edmonton - March 2021

Enterprise Land Development Program

April 23, 2021

1 Sir Winston Churchill Square
Edmonton, Alberta
T5J 2R7


To Executive Committee of Council,

RE: Enterprise Land Development Program Update

IDEA is writing this letter today to urge Executive Committee to stand by its motion to sell  Goodridge Corners, Schonsee, and Aster, and direct the proceeds to align with strategic building goals that are outlined in the City Plan. Council’s downtown construction incentive grant is successfully demonstrating how targeted action and investing in specific areas helps to stimulate development and bring long-term consistent returns. 


Our recommendation is:

  • Sell Goodridge Corners, Schonsee, and Aster, as is, today. The market has been strong over the last year with low interest rates. We are missing the prime selling opportunity for this land.

  • Use revenue from the sale to assist Exhibition Lands and River Crossing, as they are identified as investment areas within the first two population horizons in The City Plan. These projects are moving into the implementation phase of redevelopment, and require significant capital investments.

  • Create a partnership with private infill developers to spur investment in River Crossing and Exhibition Lands. The City does not have a great track record in developing infill sites on its own.

  • At this time we do not support directing the funds raised from the land sale to Heritage Valley Town Centre as the area does not require market and political support for its development.

  • Allow for the industry to develop the land in Goodridge Corners, Schonsee, and Aster, as the industry does follows Municipal and Provincial regulations, standards and guidelines. We do not see any data that shows a large gap between private and public standards, and we have confidence that those in the private sector who purchase the land can service and develop it to standards set by the City and Province

  • We are very concerned with the City’s stance as articulated in Attachment 4. Many of the goals the City is looking to achieve regarding Healthy City, Urban Places, Climate Resilience, Regional Prosperity and Overall Alignment with The City Plan will be achieved through the infill redevelopment projects that would come out of the infrastructure investments made from the revenue of the land sales. This attachment implies that the only way development can align with City Plan is if the City itself is the developer. Both residential and commercial infill has proven to achieve many of City Plan goals and is reviewed and approved against City Plan by City Council at public hearing. Also, The City Plan informs multiple other critical decisions including zoning bylaw renewal, plans repeals, and infrastructure investments.

  • We would also like to note that IDEA is the leading organization for urban infill redevelopment. We have an in-depth understanding of the infrastructure and investment needs for redeveloping areas. However, we were not engaged on this project. Further, the “What We Heard” reports do not showcase which groups were consulted in alignment with GBA+ lens.

  • The Reserve Fund Study suggests that Option 2 could potentially generate more income for the city in the long term. However, there are near-term capital needs and strategic priorities for the City to consider. Moreover, time is subject to external forces that can derail plans, as we have seen in the past 18 months. Outcomes such as the tax uplift from infill, more efficient utilization of existing infrastructure, social and environmental benefits, and the time horizon on City Plan Goals being realized are not factored into the Option 2, 30 year (approx.) investment horizon. 

The Enterprise Land Development Program is an opportunity that will help Edmonton create a long-term, holistic, and strategic system to invest money in areas that present a higher investment risk and thus need a boost to redevelop and help us achieve our city-building goals. Please support the sell-as-is strategy and push the conversation forward on creating a more holistic reserve fund to help invest and leverage opportunities to see The City Plan realized.


Sincerely,

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Hani Barzagar
President
Infill Development in Edmonton Association
HIBCO Construction

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Mariah Samji
Executive Director
Infill Development in Edmonton Association 

Edmonton's City Plan

City Council
1 Sir Winston Churchill Square
Edmonton AB, T5J 2R7

September 11, 2020

Dear Mayor and Council, 

RE: City Plan

The Infill Development in Edmonton Association (IDEA) is the voice of the infill development industry in Edmonton. Our purpose is to drive change toward people-centred communities, and we do so through a committed volunteer board and diverse membership, including builders, developers, consultants and community members. 

We strongly support City Plan’s vision to accommodate two million people within our current boundaries; this is an ambitious goal that we are willing, able and excited to tackle as partners in city building. IDEA was a key stakeholder throughout the plan creation process, and we are pleased to see the new plan come to fruition.

IDEA supports City Plan’s six guiding values; Belong, Thrive, Live, Access, Preserve and Create, and we believe these values are shown consistently throughout the plan. However, to successfully carry out these values, how we execute the plan is critical. To that end, we believe there must be a clear and focused intention on the following matters.

Key Steps:

Infrastructure Funding Plan

 City Plan calls for continued infill growth and intensification along nodes and corridors. These goals will not be achieved without commensurate resources dedicated to improving the infrastructure in these critical areas. Infrastructure deficiency is currently the top barrier facing medium scale residential and commercial infill, and until the issue is holistically addressed, we will continue to hamper growth in these key areas, and City Plan will simply remain words on paper. We request immediate action on addressing the infrastructure deficiency by i) reviewing and updating Volume 4 of the City’s Engineering Design and Construction Standards (Water), ii) creating a predictable fee structure for contributions to system upgrades as a whole, rather than piecemeal, one-off fees where infill residents and small businesses are wholly responsible for upgrading deficient infrastructure in an existing neighbourhood.

Retire Contradicting Plans and Policies

Many of our planning policies are currently outdated and/contradictory, and unnecessarily confuse and complicate achieving our City’s stated infill objectives. These contradictions will only become more extreme under the new City Plan unless immediate action is taken. We request Council’s support for creating new district plans and for reviewing and retiring outdated plans that no longer align with the City Plan’s intentions.

Financial Impact Study

The “City Plan Growth Scenarios Relative Financial Assessment” shows that the City Plan Land Use Concept is anticipated to result in growth-related City services capital cost savings of about 10%, or $30 billion, as compared to “Business As Usual”. These cost savings only relate to items such as roads, transit, parks, police, and waste management, and do not include cost savings on linear infrastructure such as underground utilities (pipes, hydrants). However, without a financial assessment that includes this critical infrastructure, Council cannot make truly informed decisions about the maintenance and operating costs they will inherit. We request that future studies include all information pertinent to the financial equation in order for us, as a City, to confidently create growth plans and direct infrastructure investment to priority areas.

Clear Intentions

City Plan is clear about its intention for the City to grow to two million people within our current boundaries, and we have ample space, underutilized lots and surface parking lots on which to accomplish this. However, setting the infill target at only 50% sends the message that we have the will, resources and ability to continue to grow outward in the manner of business-as-usual while at the same time, successfully growing inward. In fact, we do not have this ability.

Now more than ever, due to COVID-19 and lacklustre oil prices, we must focus on our values and priorities and make decisions accordingly. We request that the target to reinvest in our City be set at 55%. Infill is difficult to do, but we need it at all scales, and we need Council’s support to do it. More and better infill will provide more diverse housing options, reduce capital costs, protect the environment and provide a more efficient transit system. 

Thank you for your time and attention, we appreciate your ongoing leadership.

Sincerely, 

Mariah Samji,

mariah signature.PNG
 

Executive Director, IDEA

DC2 Site Specific Development Control Provision Assessment Report (2019 -2020) - IDEA Research

Background

DC2s are site specific, custom zones created to allow for developments that could not otherwise be accommodated under a standard zone. Due to the complexity of creating DC2s, as well as their site specificity, DC2 rezonings take additional time and money (in the form of consulting fees for planning and design, consultation, the application fee, etc). Additionally, any updates to a DC2 require a full rezoning process and Council approval.

Since the ostensible purpose of DC2 districts are to allow for unique developments, the permitted uses, height, density, FAR and setbacks provided in DC2s should be significantly different from the regulations of any conventional zone. IDEA investigated the 195 DC2 zones created from October 15, 2015 (DC900) to January 22, 2020 (DC1095) to find out the extent to which that is in fact the case.


Key Research Questions

  • What patterns did DC2s create over this period?

  • Are DC2s often very similar to Standard Zones?

  • What are the costs associated with DC2s for developers and the City of Edmonton?

  • Are there ways to reduce the number of DC2s created?


Methodology

IDEA created a database to record the location, purpose, height, density, FAR and setbacks of 195 Direct Control 2 zones adopted between October 15, 2015 and January 22, 2020. Only the DC2s with a residential-related purpose were considered for this study.
The parameters of the selected residential (or mostly residential) DC2s were then compared against the regulations of conventional zones. The observations that did not resemble any conventional zone in a reasonable way were discarded. These observations are assumed to be cases in which the adoption of a DC2 is indeed granted. The rest of the observations were classified according to the closest-related conventional zone.
Measures of spread were tested for each class to determine the most suitable one to achieve the purpose of this study. Standard deviation was selected as the statistical test to analyze the dispersion of the observed parameters.

Results
From the total 195 DC2s that were recorded in the database, 119 (61%) had a stated purpose of providing for residential or mostly residential development. The other 76 observations were recorded in the database but excluded from the statistical analysis.

From the total 119 residential-focused DC2s, 39 (33%) did not resemble any conventional zone. This means that only 33% of the DC2s that were examined make a strong case to grant a direct control zone. The remaining 80 (67%) were closely related to one of the conventional zones in terms of parameters such as height, density, FAR and setbacks. These observations were classified accordingly. The resulting classes in order of predominance were RA9, RA8, RA7 and RF5.

For the statistical analysis, measures of central tendency and dispersion were performed for the aforementioned parameters in each class. However, the values recorded in the database for density had inconsistent measurement units and were left out of the final statistical analysis to avoid bias (though they were still recorded and observed for patterns).

The final analysis was based on the measures of mean and standard deviation. The mean was calculated as the statistical average of the observations for each parameter, and then compared to the values of the corresponding conventional zone. The standard deviation, in this case, has the purpose of demonstrating the dispersion of the observations vis à vis the corresponding conventional zone regulations and not in relation to each other. Thus, for the purpose of calculating the standard deviation, the assumed mean was the value for each parameter as stated in the Zoning Bylaw for the corresponding conventional zone.

The results for each of the resulting classes are presented below.


1. RA9

28 of 80 observations (36.25%) were deemed comparable to the RA9 zone in the Zoning Bylaw, 23 had ground floor commercial and 5 had ground floor residential. The Zoning Bylaw 12800 for High Rise Apartment Zone (RA9) was amended in June 2018. Relative to this study, the FAR and height were changed. Prior to June 2018, FAR was 3 and the maximum height was 45 m. The amendments categorized height and FAR based on site area. This accounts for site constraints with modest high rise buildings and more flexibility on larger sites to achieve a high rise development with a lower FAR. Site areas thresholds are less than 1800 m2, 1800-7500 m2, and greater than 7500 m2, and corresponding FAR are 2.2, 5.2, and 4.3, respectively. Maximum height ranges include towers from 15 m to 58 m, and podiums or other built forms a maximum of 15 m. These regulations can be found in Table 1 in the RA9 Zone.

For the purpose of this analysis, the observations associated with the RA9 district were divided into two groups according to whether they were adopted under the previous or new regulations. This study found 12 DC2 observations between October 2015 and June 2018, and 16 DC2s between June 2018 and January 2020.

a. Before June 11, 2018

A total of 12 DC2s were approved and are deemed comparable to the RA9 district between October 2015 and June 2018. The Zoning Bylaw set a maximum height of 45 m and the calculated average and minimum height for the 12 DC2s was 80.8 m and 23 m, respectively. Height had a standard deviation of 49.2. The calculated average FAR was 6.63 which is 3.63 greater than the FAR prescribed in the Zoning Bylaw (3) prior to June 2018. FAR has a standard deviation of 3.04. Front setbacks in the Zoning Bylaw was set to 6 m. The calculated average front setback for the 12 DC2s is 3.05 m with a standard deviation of 2.81. The average rear setback is 7 m and the standard deviation is 3.23 compared to the 7.5 m rear setback value prescribed at the time in the Zoning Bylaw. The RA9 side setback was also set at 7.5 m, the average calculated value was 4.81 m with a standard deviation of 3.29.

Of these observed 12 DC2s, 2 have a maximum height greater than 100 m and the total range was from 23 m to 280 m. The uses listed in these DC2s were refined lists of the discretionary and permitted uses listed in the RA9 zone. The main needs addressed in the DC2s that are not provided for in the Zoning Bylaw are the provision of mixed uses and TOD design/features.

b. After June 11, 2018

A total of 16 DC2s were approved and are deemed comparable to the RA9 district between June 2018 and January 2020. The Zoning Bylaw outlines setbacks according to three height classes (above 15m, 15 m or below with ground floor residential, and 15 m or below with ground floor commercial), and assigns FAR based on site area. Due to this categorical classification in the Zoning Bylaw, standard deviations for height and FAR were not calculated. The average and minimum height for the 16 DC2s was 107.5 m and 35 m, respectively. The calculated average FAR was 10.5. Front setbacks for structures greater than 15 m in the Zoning Bylaw is 6 m. The average front setback is 4.39 m with a standard deviation of 2.96. The average rear setback is 4.39 m and the standard deviation is 3.46 compared to the 7.5 m rear setback value in the Zoning Bylaw. The RA9 side setback is also set at 7.5 m, the average calculated value was 2.79 m with a standard deviation of 4.09.

Of these observed 16 DC2s, 8 has a maximum height greater than 100 m and the total range was from 35 m to 170 m. The uses listed in these DC2s were refined lists of the discretionary and permitted uses listed in the RA9 zone. The main needs addressed in the DC2s that are not provided for in the Zoning Bylaw are the provision of mixed uses and TOD design/features.

2. RA8

Out of 80 DC2 observations, 16 (20%) were classified most comparable to the RA8 zone. On August 26, 2019 the Zoning Bylaw was amended to introduce more flexibility to 5 different zones in order to allow for more diverse multi-unit housing options to be built in neighbourhoods across the city. The Medium Rise Apartment Zone (RA8) was one of those five districts part of the Missing Middle Zoning Bylaw Review. Maximum FAR changed from 2.5 to 3.0. Minimum front setbacks changed from 6 m to 4.5 m. Minimum side setbacks changed from 1 m/storey or 2 m minimum, to 1.2 m or 3 m where building height is greater than 10 m. Where a lot is adjacent to a street the side setback changed from 4.5 m to 3 m. Rear setbacks did not change from 7.5 m unless the maximum height of the development was 6.5 m then the minimum rear setback changed to 1.2 m.

For the purpose of this analysis, the observations associated with the RA8 district were divided into two groups according to whether they were adopted under the previous or new regulations. This study found 15 DC2 observations between October 2015 and September 2019, and 1 DC2s between September 2019 and January 2020.

a. Before August 26, 2019

There were 15 DC2s deemed comparable to RA8 that were adopted between October 2015 and August 2019. The average height was 19 m with a standard deviation of 5.38, compared to the allowed maximum height of 23 m for the RA8 zone in the Zoning Bylaw. The FAR in the Zoning Bylaw for RA8 is 2.5 and the calculated average FAR for the DC2s was 2.27 with a standard deviation of 0.62. The front setback value for an RA8 zone is 6 m and the observed average value for this DC2 was 5.27 m with a standard deviation of 1.65, a difference of 0.73 m from the conventional zone. The average rear setback distance was 6.22 m with a standard deviation of 2.01, compared to the 7.5 m distance in the Zoning Bylaw. The side setback was more scattered. The side setback average distance and standard deviation was 4.09 m and 2.30 respectively.

Permitted and discretionary uses for this observed DC2 was not examined in detail for this quantitative analysis, though there are considerable similarities to the conventional RA8 zone. The main needs addressed in the DC2s that are not provided for in the Zoning Bylaw are the provision of mixed uses and TOD design/features.

b. After August 26, 2019

There was one DC2 deemed comparable to RA8 that was adopted between August 2019 and January 2020. The height was 23 m with a standard deviation of 0, compared to the allowed maximum height of 23 m for the RA8 zone in the Zoning Bylaw. The FAR in the Zoning Bylaw for RA8 is 3.0 and the FAR for the DC2 was 3.2 with a standard deviation of 0.05. The front setback value for an RA8 zone is 4.5 m and the observed value for this DC2 was 2.5 m with a standard deviation of 0.5, a difference of 2 m from the conventional zone. The rear setback distance was 6 m with a standard deviation of 0.36, compared to the 7.5 m distance in the Zoning Bylaw. The side setback was more scattered. The side setback distance and standard deviation was 1.5 m and 0.09 respectively.

Permitted and discretionary uses for this observed DC2 was not examined in detail for this quantitative analysis, though there are considerable similarities to the conventional RA8 zone. The main needs addressed in the DC2s that are not provided for in the Zoning Bylaw are the provision of mixed uses and TOD design/features.


3. RA7

13 out of 80 observations (16.25%) were deemed most comparable to the RA7 zone. On August 26, 2019 the Low Rise Apartment Zone (RA7) was one of those five districts that were amended as part of the Missing Middle Zoning Bylaw Review. The maximum FAR changed from 1.2 to 2.3. Minimum front setback was 6 m and is now 4.5 m. For developments up to 6.5 m in height the minimum rear setback was not defined prior to August 26, 2019, but now has a minimum rear setback of 1.2 m. For developments greater than 6.5 m their rear setbacks did not change from 7.5 m. Minimum side setbacks changed from 1 m/storey or 2 m minimum, to 1.2 m or 3 m where building height is greater than 10 m.

For the purpose of this analysis, the observations associated with the RA7 district were divided into two groups according to whether they were adopted under the previous or new regulations. This study found 9 DC2 observations between October 2015 and September 2019, and 0 DC2s between September 2019 and January 2020.

a. Before August 26, 2019

A total of 9 DC2s in the RA7 category were adopted between October 2015 and August 2019. The Zoning Bylaw allows a maximum height of 14.5 m, while the average height of the subject DC2s was 14.63 m, with a standard deviation of 0.5, which is significantly low. Moreover, the FAR prescribed in the Zoning Bylaw (1.2), the calculated average FAR was 2.3 with a standard deviation of 3.20. There were more variation in the values observed for the front, rear and side setbacks. The smallest dispersion was observed in front setbacks, with a mean of 3.83 m and a standard deviation of 7.05, a difference of 2.17 m under the required 4.5 m setback. Side setbacks have an average value of 3.70 and a standard deviation of 2.4, which is 0.80 under the minimum requirement of the Zoning Bylaw by 4.5 m on average. Rear setbacks, however, had an average of 5.58 m, 1.92 m below the 7.5 m required by the Zoning Bylaw, with a standard deviation of 6.25 (considerably scattered).

Even though the permitted and discretionary uses were not subject to the same rigorous quantitative analysis, there were considerable similarities between the observed DC2s and the Zoning Bylaw regulations for the RA7 zone. The main needs addressed in the DC2s that are not provided for in the Zoning Bylaw are the provision of community supportive services, mixed uses, and TOD design/features.

b. After August 26, 2019

No DC2s in the RA7 category was adopted between August 2019 and January 2020. This may be due to the method used to classify existing DC2s based on the selected regulations and observed uses.


4. RF6

The Medium Density Multiple Family Zone (RF6) was not included in the Missing Middle Zoning Bylaw Review. Therefore, the DC2s observations deemed comparable to the RF6 zone are from October 2015 to January 2020.

9 of the 80 observations (11.25%) were most similar to the RF6 zone. The average height and standard deviation for the listed DC2s were 13.44 m and 2.15, respectively. This is 1.06 m away from the given 14.5 m for the RF6 zone in the Zoning Bylaw. The standard deviation was not calculated in this analysis as the FAR for the RF6 is dependent on lot area. The calculated average front setback was 4.42 m with a standard deviation of 1.14, only 0.83 m away from the conventional zone’s front setback regulation (4.5 m). The rear setback for the RF6 zone, and the average value for these DC2s was 5.64 m with a standard deviation of 2.38. The average side setback was 2.55 m with a standard deviation of 2.37, this is 0.55 m away from the RF6 conventional zone side setback of 2 m. The flanking setback is 4.5 m in the Zoning Bylaw, the observed average was 3.11 m with a standard deviation of 1.39. Generally, the observed regulations for these 9 DC2s were within a maximum distance of 1.86 m from the RF6 regulations outlined in the Zoning Bylaw.

Some discretion was used when comparing these DC2s to the RF6 zone. The regulations and description of each DC2 were used to assess whether they best fit within the RF6 or RF5 conventional zones. The uses listed in these DC2s were refined lists of the discretionary and permitted uses listed in the RF6 zone. The main needs addressed in the DC2s are that 3 DC2s provided FAR details and there was significant variability in the format of data delivery.


5. RF5

11 out of 80 observations (13.75%) were deemed comparable to the RF5 zone. The Medium Rise Apartment Zone (RA8) was one of those five districts part of the Missing Middle Zoning Bylaw Review on August 26, 2019. The maximum height changed only for developments under the Mature Neighbourhood Overlay (MNO) from 8.9 m to 10 m. The minimum rear setback for buildings less than 6.5 m in height changed from 7.5 m to 1.2 m. Rear setbacks for those buildings under 6.5 m in height and the MNO changed from being 40% of the site depth to 1.2 m.

For the purpose of this analysis, the observations associated with the RF5 district were divided into two groups according to whether they were adopted under the previous or new regulations. This study found 11 DC2 observations between October 2015 and September 2019, and 0 DC2s between September 2019 and January 2020.

a. Before August 26, 2019

A total of 11 DC2s in the RF5 category were adopted in this timeframe. A height of 10 m is given in the Zoning Bylaw for the RF5 zone, the calculated average of the observed DC2s was 10.91 m with a standard deviation of 0.91. The standard deviation was not calculated as the FAR for the RF5 is dependent on lot area. The calculated average front setback was 4.11 m with a standard deviation of 1.55, this is 0.39 m away from the 4.5 m regulation in the Zoning Bylaw. The average rear setback of 4.61 m was less than the RF5 zone (7.5 m) and the most scattered regulation with a standard deviation of 3.40. Side setbacks in the RF5 are set at 1.2 m, the observed setback average for these 11 DC2s was 2.8 m with a standard deviation of 2.70.

Some DC2s used to assess the RF5 zone were also included in the RF6 and RF3 zone. The observed DC2 uses refined lists of the discretionary and permitted uses listed in the RF5 zone. None of the 11 DC2s included FAR, and there were inconsistencies with how regulation data was provided; some were outlined in the Zoning Bylaw and others were retrieved from plan appendices.

b. After August 26, 2019

Based on our study, between August 26, 2019, and January 2020, there were no new RA7s approved. This may be due to the method used to classify existing DC2s based on the selected regulations and observed uses.


6. RF3

Out of 80 observations, 12 (15%) were comparable to the RF3 zone in the Zoning Bylaw. Although part of the Missing Middle Zoning Bylaw Review, the RF3 development regulations that changed did not pertain nor affect this study. Therefore, the DC2s observations deemed comparable to the RF3 zone below are from October 2015 to January 2020.

The average height for these 12 DC2s was 10.47 m with a standard deviation of 1.37, this is 0.47 m away from the listed RF3 height of 10 m. Only one DC2 provided FAR details, so the standard deviation was not calculated. Front setbacks for the RF3 zone are set to 4.5 m, the calculated average was 4.13 m with a standard deviation of 1.60. Rear setbacks were the most scattered with a standard deviation of 3.64 with an average of 5.59 m. This is 1.91 m away from the 7.5 m rear setback regulation in the RF3 zone. Flanking and side setbacks produced similar average values in the observed DC2s with 2.99 m and 2.61 m, respectively. However, flanking setbacks had a lower standard deviation of 1.61 compared to the side setback observations (2.45). On average, flanking setbacks were closer (by 0.99 m) to the conventional regulation of 2 m, whereas the side setback is a greater distance (1.41 m) away from the RF3 regulation of 1.2 m. Some of the DC2s used in this RF3 analysis were also included in the RF5 study given their similarities in purpose, uses, height, and setback regulations.


7. RMD

5 DC2s of 80 observations (6.25%) were comparable to the RMD conventional zone in the Zoning Bylaw, though only two provided data on regulations and it was exclusive to front setbacks. The Zoning Bylaw prescribes 4.5 m for the RMD front setback. The calculated mean for these two observed DC2s was 4.75 m with a standard deviation of 1.77.


8. RF1

4 of 80 observations (5%) were deemed comparable to the RF1 zone in the Zoning Bylaw. The average height was 9.33 m with a standard deviation of 1.83, this is similar to the Zoning Bylaw’s 10 m height regulation. There were no recorded FAR values. Front setbacks in the RF1 zone are set at 4.5 m, this is 0.9 m away from the calculated average of 3.6 m with a standard deviation of 1.56. Only one DC2 provided a rear setback, it was 6 m which is 1.5 m away from the RF1 value of 7.5 m in the Zoning Bylaw. Two DC2s gave a flanking setback value for an average of 2.25 m with a standard deviation of 1.94, which is half the value listed in the RF1 zone (4.5 m). Two different DC2s provided side setback regulations with an average of 1 and a standard deviation of 0.28, compared to the 1.2 m regulation in the Zoning Bylaw.


9. RSL

Five observations were recorded to be comparable to the RSL zone, however, only 2 out of 80 (2.5%) DC2s were used in the analysis. The average height was 8.5 m with a standard deviation of 2.12, this is a 1.5 m difference to the 10 m height regulation provided in the Zoning Bylaw. None of the observations provided FAR, rear or side setback data, and only one DC2 offered front setback regulations which were identical to the 4.5 m front setback regulation in the RSL zone. The average flanking setback was 2.25 m, half of the RSL value of 4.5 m, with a standard deviation of 2.37.

summary of findings DC2.PNG


Results/Analysis
Based on the sample analyzed in this study, only about a third of the approved DC2s are unique enough to grant a site-specific zone.

25% of the total 195 DC2s recorded in the database provide a different set of regulations for different sub-areas or sub-districts within the same site. In these cases, it is more cost-efficient for a developer to go through the direct control route. The Zoning Bylaw could potentially adopt mechanisms to make it easier and more economical for developers to adopt conventional zones even in sites that would need more than one (a single application per site and not per zone/district).

Most of the DC2s analyzed in this study could be adopted under conventional zones provided more flexibility in the Regulations of the Zoning Bylaw, especially in the following cases:

  • Allowing mixed uses along main corridors regardless of the zone.

  • Providing for more supportive community services in residential districts.

  • Provide for higher densities and a more pedestrian and transit-oriented design in existing medium and high-density zones.

The vast majority of analyzed residential DC2s were classified under the RA7, RA8 and RA9 conventional zones. This could be an indicator of poor performance or functionality of the conventional regulations to build low, medium and high rise multifamily housing. Given that the densities that the City Plan strives for are contingent upon this type of development, it is critical to consult with stakeholders to address this issue.

The most significant differences between these DC2s and conventional zones were found in setbacks, especially when the site was adjacent to a transportation corridor or institutional uses. Not only the average setbacks of the DC2s were somewhat distant from the required setbacks in the conventional zones, but a high dispersion was also observed. This indicates that the DC2s do not show a clear pattern in terms of setbacks.

An important observation is that in most cases the minimum setbacks required in the DC2s are actually lower than those required in the conventional zones, especially the DC2s classified under the RA7 class. This could indicate that the setbacks required in the conventional zones are unrealistic on impractical for a significant percentage of multi-family housing developments (which get built with lower setbacks anyway).

The closest similarities between the DC2s and conventional zones were found in height and FAR. Not only the average height and FAR of the DC2s were somewhat close to the required maximum height and FAR in the conventional zones, but a low dispersion was observed. This indicates that even in cases where these parameters are dissimilar from the conventional zoning regulations, they are still within a reasonable range.

A key observation of this analysis is the impact of the changes introduced by the Zoning Bylaw amendments from June 2018 affecting the RA9 zone, and from August 2019 affecting the RF5, RA7 and RA8 zones:

  • Changes to the RA9 zone: these changes didn’t seem to have a positive impact in reducing the use of DC2s. Before the changes, a total of 12 comparable DC2s were adopted in a span of 32 months, while this number rose considerably after the changes were implemented, with a total of 16 comparable DC2s being adopted in a span of 7 months. The required setbacks of these DC2s did seem to differ further from the new RA9 setback requirements. Monitoring this trend could be useful to determine the impacts of the regulations in the longer term. These findings are not conclusive due to the biases implicit in the classification method utilized in this study, but it is indicative that there needs to be a more thorough reevaluation of the flexibility provided by the regulations of this zone, even after the June 2018 changes.

  • Changes to the RA7 and RA8 zones: these changes had a positive impact in reducing the use of DC2s. After the changes came into effect, only 1 DC2 comparable to the RA8 zone and no DC2s comparable to the RA7 zone were adopted. The same disclaimer described above applies for this finding.

In terms of single-family housing, the parameters of the analyzed DC2s were found to be very similar to the requirements of the zoning bylaw. Most of these developments went through the DC2 route to provide for small scale commercial uses(including office and professional services), a range of low and medium-density, single-family housing (semidetached, row, stacked, apartment), or ensure compatibility with adjacent uses.

The main differences between these DC2s and conventional zones were the listed permitted uses. Usually, DC2s have a shorter list of permitted uses than their conventional zone counterpart. Minor differences in setbacks were also found.

In addition to the analysis of the aforementioned parameters, there are a few observations applicable to the overall set of DC2s that were studied:

  • Landscaping requirements are a prominent component of most DC2s and are very site-specific.

  • There were a few DC2s with conditional development permit regulations, and some that carry over most of the regulations from conventional zones but only exist to provide for a particular use that is not listed as either permitted or discretionary, or to assign different purposes/uses to different areas within a development site.

  • Even though podiums with medium to high rise buildings are popular, the regulations for this type of development are not entirely clear and/or functional in the conventional zones.

Considering that the purpose of the Direct Control zone is to provide special regulations for a specific site where any other Zone would be inappropriate or inadequate, it is safe to conclude that DC2s are being overused and issued for developments that should and could perfectly happen under conventional zoning. This is one of the manifestations of the City’s over prescriptive approach to planning.

There is a general feeling among the development industry that the City is not only permitting this over use of DC2s but encouraging developers to seek permit approval through this route. This gives the City much more control over development, but comes at a high cost. The City invests a great deal of resources working with developers through the process of discussing, writing and approving the permit. In some cases a permit goes back to Council (15 of the studied DC2s went back to Council once and 1 went back to Council twice). On the other hand, the overuse of DC2s undermines and defeats the purpose of conventional zoning, which is in place to create certainty.

The overuse of the Direct Control zone is likely a result of the inefficacy of conventional zones, but the solution should be redirected to identifying the issues and creating a more responsive and flexible regulatory framework.





Final disclaimer: the methodology used in this study is not exhaustive, therefore the results are indicative but not absolute. More research and consultation with stakeholders is highly encouraged.


Upcoming Parking Changes Summary - City of Edmonton Requirements

To IDEA Membership: 

The City of Edmonton recently shared their upcoming report and supporting documentation going to Council regarding the move from the current Zoning Bylaw parking regulations to an Open Option Parking system. This report is still scheduled to go to Public Hearing on June 23, 2020.  

While the overarching result is a major decrease in parking requirements, it does not mean full  elimination of parking requirements. The documentation distributed by the City is incredibly detailed and populated with technical information leaving the full impacts of the proposed changes unclear to some members. As such, this letter will serve as a summary of the changes being proposed, and how they impact the infill industry in Edmonton. If there are additional questions, IDEA’s membership includes Professional Planners that can further help interpret regulations for specific circumstances. 

The major changes to the regulations are as follows: 

  • Minimum parking requirements have been eliminated for all uses. However, in accordance with the Alberta Building Code, builders are still required to provide barrier-free parking stalls. 

  • Minimum bicycle parking requirements have increased for multi-family and non-residential developments (multi-family: 1 space/2 dwellings or 1 space/140m2 floor area for non-residential – none for low density residential)

  • Loading space requirements have a maximum of 2 spaces required (multi-family/commercial)

The following chart illustrates the proposed changes: 

Capture.PNG

*ABC refers to Alberta Building Code**Example reflects minimum requirements under proposed regulations and Alberta Building Code

As stated in the Draft Report from City Administration: 

Open Option Parking is one of the most influential Zoning Bylaw amendments that can be made to ensure the urban form envisioned by the emerging City Plan policy is achieved. It improves choice for Edmontonians, reduces barriers to economic development, supports climate resilience, and has the potential to transform Edmonton’s urban form through gradual, incremental change toward a more compact, urban environment.

IDEA has been a major proponent and supporter of these proposed changes, and the paragraph above speaks directly to the infill industry. The proposed changes eliminate some of the barriers that infill builders face, and shows the commitment of Administration to supporting our industry.

IDEA is also currently working with the City of Edmonton to create clear expectations for when  a Transportation Demand Management plan is needed, what it will look like, and what information an applicant should expect to provide. This will be extremely important to reduce uncertainty and delayed timelines. 

If there are any additional questions about the information found in this summary report or the circulated documentation, please contact one of IDEA’s many Professional Planners. They are here to help.

Date: April 28, 2020

Prepared by: IDEA Policy Committee 

Ministerial Order No. MSD 022/20 and Essential Services - April 2020

April 7, 2020

Honourable Jason Kenny
Office of the Premier
307 Legislature Building
10800 - 97 Avenue
Edmonton, Alberta 
T5K 2B6

Sent via Email: premier@gov.ab.ca

Dear Premier Kenney, and Minister Madu,

RE: Ministerial Order and Essential Services

The Infill Development in Edmonton Association (IDEA) is a non-profit association with a diverse membership of construction and development industry professionals and community members. IDEA was formed seven years ago to help shape urban development policy specifically around residential and commercial infill in Edmonton. Over the past seven years, we have provided expert research to municipalities, built an education-based expedited permit program to fast track permits, and created infrastructure cost-share programs with EPCOR and the City of Edmonton. 

On behalf of IDEA, we are writing to share the infill industries' perspectives on development during this crisis and request that you rescind or amend Order No. MSD: 022/20. We are facing unprecedented times. These times require a multipronged approach that recognizes the layered impacts of decisions. To ensure we are successful as a province, we must do everything we can to minimize immediate effects but must also set a strong foundation for economic recovery.

We have outlined below key points for you to consider as you make important decisions to ensure Albertans come out of this pandemic as successfully as possible.

Ministerial Order No. MSD: 022/20

Ministerial Order No. MSD: 022/20 has consequences that are creating significant uncertainty and significant red tape for our industry.

By extending decision timelines to October 1, 2020, this halts all new development between now and October 22, 2020. A conservative estimate based on 2019 data shows that 1300 permits will be stalled, and we will miss our already very short construction season. Not only does it affect future developments, but the way that this Order is currently written, it also retroactively impacts all decisions from March 5 onward, adding significant uncertainty to an industry that is working hard to weather the storm to keep people employed and projects moving forward. This Order needs to be revised to allow development to move forward. If this is not done, the majority of development companies will not be able to keep employees on payroll, continue working with their suppliers or construct residences or places of work for Alberta families.

Essential Services

We also want to stress the importance of the construction industry in the Alberta economy. Companies of all scales are implementing safety and health practices into their daily business operations to reduce the spread of COVID-19. They are taking this very seriously. They represent 10% of Alberta's total employment, and they want to ensure they are staying healthy and are able to continue to operate and whether the impacts of these challenging times. This is also an industry that does not have significant contact with the public and where physical distancing is not too difficult to enforce. It is an opportunity for continued investment, jobs and economic growth during a time when so many other sectors are unable to work.

If construction is downgraded to a non-essential service and told to shut down, it will impact the entire industry supply chain, magnifying the negative economic impact on our province due to this pandemic. Multiple small and medium companies currently investing in Alberta will go under if they lose a construction season. They will need to lay off more tradespeople, and other skilled workers and this talent may not be retained in Alberta. It will take multiple years for our province to recover from this crisis; this decision will exacerbate these impacts and have ripple effects on suppliers, communities, Albertans and all industries that rely on the trades.

Projects in the queue are homes for families and spaces for new businesses. Many individuals have put their personal investments into homes in order to have a place to raise their families, or accommodate the needs of a family member, or to build a growing business. Most of these are built by small and medium scale companies. Those companies and the thousands of Albertan families who have hired them could quickly be bankrupted by a decision that deems construction non-essential.

As you are aware, Alberta is adversely affected not only by COVID-19 but the oil and gas sector. Residential and commercial construction are vital sectors that allow for more diverse employment options for our trades, which keeps people working when our resource industries are struggling.

You continue to express the importance of supporting our economy during this health crisis. To ensure that we are able to rebuild after this crisis, we need to support industries that are in a position to continue their work and continue to invest in our province. We understand the need to make adjustments in order to accommodate physical distancing and avoid the spread of COVID-19. There are ways to do this that doesn't shut down an entire sector (and all its suppliers) until Spring 2021.

We look forward to hearing how you will be addressing this issue and appreciate your consideration at this challenging time.

 

Sincerely,

Hani Bargazar
President, IDEA
hani@hibco.ca

Mick Graham,
Past President, IDEA
mick@singletree.ca

Chelsey Jersak,
Vice President, IDEA
chelsey@situateinc.ca

CC: Honourable Kaycee Madu Minister of Municipal Affairs, Rachel Notley MLA for Alberta, Joe Ceci MLA, Paul Wynnyk Deputy Minister Municipal Affairs