The following letter was sent from OSCA to the City of Ottawa Zoning & Interpretations Team regarding the Residential Fourth Density Zoning Review.
Tim J. Moerman
Zoning and Interpretations Team Ottawa City Hall
110 Laurier Ave W Ottawa, ON K1P 1J1
Re: Residential Fourth Density (R4) Zoning Review
Dear Mr. Moerman:
I am sending the following comments in regard to the Zoning By-law R4 Zoning Review Discussion Paper #3 on behalf of the Old Ottawa South Community Association. Most R4 parcels in our neighbourhood are already developed; our comments reflect our interest in the future development of multi-unit housing and other, larger planning issues.
The City has indicated that substantial zoning changes are planned to follow approval of a new official plan within the next year. Our view is that any changes to R4 zoning need to happen as part of that process, for two reasons. First, we are concerned that the R4 zoning changes may become a precedent for future changes to other zones and to Old Ottawa South. Matters in the proposed R4 zoning related to parking and other matters may be presented as "tried and true" when other multi family zones are later revised.
Second, the purpose of zoning is to implement the official plan; it also works in concert with design guidelines, neighbourhood plans and other tools to achieve the plan's objectives. These too are expected to change as part of the new official plan, with some neighbourhood plans and heritage provisions revised or deleted altogether. It is therefore difficult to assess the merit of the proposed zoning changes now if the new official plan-especially its vision for the future of mature neighbourhoods-is still under development.
Our comments and concerns with the proposals are listed below.
Context. The discussion paper states that "The R4 Phase 2 Zoning review will help improve housing affordability and choice in neighbourhoods... by enabling and encouraging the development of small, affordable and context-sensitive infill apartments " There is no description of how the proposed
zones reflect the context of any given community. The discussion paper states that the "only material difference between these zones boils down to how many units an apartment is allowed to have and how big the lot has to be:"
The dozen or so communities with the largest areas of R4 zoning vary from Carlington to Centretown to Overbrook. Sensitivity to the context of diverse communities requires a more fine grained approach, perhaps through additional R4 zones or design studies or other measures.
A more sensitive approach to locations for 8- to 12-unit apartments based on a community plan may be needed instead of an across-the-board increase in density. Residents from all over the City in the community workshops on the official plan highlighted their desire to protect the character of their neighbourhoods. The new official plan to date is silent on preserving community character and instead refers to policies that are sensitive to the "context" of large areas like the inner urban area.
Affordability. The discussion paper states that more units on smaller lots will increase the supply of affordable housing. This seems unlikely. Rents will be set at market rates regardless of costs and likely will be high. According to the 2018 CMHC Rental Market Report, rents on units built in the last 15 years in Ottawa on average are 26% higher than rents for comparable other units. This is not "affordable housing" as defined in the Official Plan and elsewhere, as housing for which low-income households-households in the lowest 30% income group-pay no more than 30% of their income.
Heritage. New official plan proposals for a Heritage Management Plan may include changes to some Heritage Conservation Districts and Heritage Overlay areas. These changes may leave existing heritage R4 areas, currently protected, vulnerable to infill developments that are inappropriate to and inconsistent with the existing heritage context.
Landscaping vs. Parking. The R4 proposals prohibit surface parking on lots less than 15 m (50 feet) in width or 450 m2 in area. All areas not required for walkways and other specified uses must be landscaped. The parking ban would likely deter some prospective tenants and increase demand for street parking. However, it would also potentially support on-site infiltration, urban trees and backyards for tenants.
While we have not taken a position on parking, we object to the proposed exemption from the 30% landscape requirement for smaller lots with up to 12 units. An increase in the number of units and people on a small lot suggests a greater need for landscape area, or at minimum, maintaining the current 30% requirement.
Building Facades. OSCA supports several proposals that together create a varied building fac;ade and avoid a box-like structure. These include a requirement that a portion of the front fac;ade be recessed and an allowance for a bay window projection into the front yard. Several neighbourhoods also include Heritage Conservation Districts and Heritage Overlays where additional design measures apply.
Rear-yard Projections. The R4 proposals allow projections of 2.2 m (7 ft) into the required rear yard to accommodate a three-storey exterior stair well. This measure would substantially increase the mass of the building. It would also reduce the rear yard, landscaped areas, and outdoor privacy in adjacent properties. This proposal is not supported by OSCA.
RooftopTerraces. The discussion paper proposes prohibiting rooftop terraces in Sandy Hill where they are a source of noise and nuisance. They should be prohibited in all neighbourhoods so all are protected.
Garbage. The discussion paper is unclear regarding the location of garbage and recycling materials, stating that Site Plan Control will determine where and how waste is stored. Under the City's waste management by-law, buildings up to six units require indoor garbage storage; at seven or more units, garbage must be kept in dumpsters and large rolling bins. Real solutions for waste storage at the rear of R4 properties need to be developed to make sure they can be implemented through site plan.
Site Plan Approval. The discussion paper proposes Site Plan Control as the means to require overall landscaping; the location of air-conditioning units and other matters. Yet, the R4 study looks at relief from site plan control as a cost-reduction measure-$107 per month per unit-a theme also found in official plan discussions and proposes perhaps, in some cases, eliminating the requirement altogether. OSCA does not support watering-down the use of Site Plan Approval, a proven, effective control mechanism.
We plan to publish this letter in our community newspaper, the OSCAR, to encourage residents to become informed and involved in planning issues. Thank you for your consideration of our comments.
President, Old Ottawa South Community Association