Please see below the HCA’s response to the draft of the City’s next Official Plan (OP). Ten community volunteers spent many hours working on our response, addressing a number of concerns with the proposed OP.
March 8, 2021
Manager, Policy Planning, City of Ottawa
Re: Comments and Recommendations on the City of Ottawa’s draft Official Plan
Dear Mr. Miguelez:
The Hintonburg Community Association (HCA) has reviewed the draft Official Plan. We have a number of concerns regarding certain policies set out in the draft Official Plan (OP) as they relate to our neighbourhood. We also provide concrete recommendations that we feel will strengthen the draft OP as a whole and result in a more livable, healthier and diverse City of Ottawa for the future.
It is our understanding that the draft OP is aspirational and focuses on mixed-use and walkable neighbourhoods and in many ways, a shift away from urban sprawl. We applaud the movement towards 15-minute neighbourhoods and our recommendations reflect how the OP can be strengthened to address concerns while maintaining that important shift.
The HCA appreciated the opportunity to learn about the draft OP from City staff at a recent meeting. We recognize that staff have been responding to questions from many stakeholders. We believe that the draft OP will be strengthened by incorporating insight and perspectives from a wide range of sources, including the residents in diverse neighbourhoods whose daily lives will be impacted so deeply by the policies outlined in the draft Official Plan.
We have structured our concerns and recommendations in a broad context, followed by a more detailed thematic and detailed review of policies in the draft OP for your consideration, including an appeal to delay the review process until 2023.
President, Hintonburg Community Association
c.c. Mayor Jim Watson, Councillor Jeff Leiper, Stephen Willis PIED
Overarching Concerns and Recommendations
- Insufficient consultation time
The current OP review process has been very hurried given both the length and the complexity of the policy document and the time required for City Staff to respond to questions, which then generate additional questions.
Recommendations: Extend the public consultation period to provide responses to the draft plan and delay finalization of the draft OP until 2023. We strongly support the Federation of Citizens’ Associations position that the process must be extended.
- Accountability, targets and metrics are required
Metrics are required to measure progress and success.
Recommendation: Include appropriate metrics and targets for each of the 5 Big Moves as part of good governance and accountability practices. Report annually on those metrics.
- Language and Terminology
The draft OP is written in jargon that is new to most readers outside of the urban planning field, which makes the OP quite inaccessible to the general public – understanding the meaning and the implication of concepts such as: “transects”, “overlays”, “hubs”, “compatibility” and “15-minute neighbourhoods” is challenging. Without clearer definitions, the City leaves itself and neighbourhoods open to too many interpretations. Neighbourhoods have been asking for clarity for years and the new OP was supposed to address this issue. This is particularly important for those terms that will be cited in decisions about individual planning applications.
Recommendation: Simplify the language overall and clearly define terms.
- Achieving growth and 15-minute neighbourhoods throughout the city of Ottawa
The draft OP appears to support growth in some areas of the city but not in others. It is not clear why this is the case and is not acceptable if the City’s goal is to have 15-minute neighbourhoods throughout Ottawa
Recommendation: Apply intensification goals across the City of Ottawa and encourage an increase in the number of units in the suburbs. Create incentives for developing 15-minute neighbourhoods throughout the city. A core component of that effort would be a policy that shifts more residents to using sustainable modes of transportation to achieve lower greenhouse gas emission targets.
Growth Management Framework
The draft OP has chosen to replace intensification with “regeneration” in places like Hintonburg; the use of this terminology seemingly implies that something has “degenerated”. The draft OP is implicitly putting forth the narrative that virtually all the inner-city neighbourhoods are undesirable in their current form, except for the commercial area and amenities, and most of the current people need to be removed so their dwellings can be replaced by the right types of buildings.
In addition, the draft OP is overly focused on form and instead should, in our view, be centred on the people who live in the neighbourhoods and how the proposed changes will benefit both residents and developers.
Recommendation: Shift from emphasis on calculating the Growth Management Framework solely against form-based policy and an increase in the number of buildings. If the goal is to make a truly livable city, the policies must address what makes the City livable for its citizens.
The draft OP is centred on the strategic objective of addressing and managing the anticipated 40% increase in population growth (up 400,000 from current population estimate of 1 million) in Ottawa. The focus is clearly on intensification with a specific goal of 60% regeneration by 2046.
More data is needed to better understand these projected goals, specifically:
- What is the total number of units targeted in the Inner Urban and Downtown areas projected to 2046?
- What is the total number of units targeted for neighbourhoods, hubs and corridors?
- During the recent R4 review, City staff said that density would be spread more equitably across the City when the Official Plan came forward, which appears to not be the case. It is unacceptable both in terms of the impact on neighbourhoods and that focusing the density by transects does move towards achieving 15-minute neighbourhoods.
- The density targets of 80 units per hectare for the inner urban, 40 units per hectare for the outer urban and no targets for other areas is not equitable. High density on very small lots can have negative impacts, most notably on the urban tree canopy and our ability to maintain, protect, diversify and expand the mature tree canopy. Please refer to the sections in this document on Healthy and Inclusive Neighbourhoods and Tree Canopy for a more detailed discussion on the importance of maintaining the urban tree canopy.
- Change the draft OP so that increased density is spread throughout the city. For instance, increase the outer urban density goal from 40 units per hectare to 60. Neighbourhoods that are less dense and don’t currently meet the 15-minute neighbourhood goal should be targeted for increased density and commercial development to make those areas of the city more livable.
- Track density by neighbourhood, report that information to the public and respond accordingly with policy and regulations
- For those neighbourhoods that are already meeting the 80 units per hectare in the inner urban, create incentives to maintain or slowly increase population, while focusing intensification on inner urban neighbourhoods that don’t meet the 80 unit per hectare threshold.
- Conduct a yearly count of privately available private market affordable units and track those vulnerable properties so that they can be replaced with affordable units on the private rental market.
Equity and Inclusion
The draft OP is aspirational – we have heard this from City Officials, and we support this approach in principle. The task (or challenge) for City officials and for community stakeholders is to go beyond aspirational language and ask difficult questions about how equity and inclusion are challenged by this stance and what concrete actions must be taken to reduce inequity and promote inclusion. We are concerned that the application of overlay and transects will decrease equity by concentrating density in the already dense areas. Access to housing affordability is not equitable.
Recommendation: Elevate “equity” to the status of a Big Move with its own specific policy goals, targets and metrics in all sections of the OP.
Regarding Land Use:
Large swaths of the land around transit hubs where inclusionary zoning is proposed, including those in Hintonburg, already have developments planned or approved and therefore will be excluded from this possible by-law. Speculation on nearby lands has already started to take place resulting in the disappearance of lower-cost rental options. Residents, especially low-income earners, are being pushed out of neighbourhoods that have easy access to the transit stations.
Recommendation: Conduct a yearly count of current available affordable units on the private market and track those vulnerable properties so that they can be replaced with affordable units on the private rental market.
Hintonburg has been identified, for the most part, in the draft OP as an inner urban transect with a transforming overlay which brings a set of zoning regulations. While we recognize that the draft OP has a policy approach that examines the City of Ottawa as a whole, we want to ensure that the urban design takes a neighbourhood approach during both the design process and implementation of these policies. In addition, we have ongoing concerns with new developments about the provision of parking areas,adequate storage for garbage and the location of garbage enclosures away from the boundaries with neighbouring properties. Previously, we have sometimes been able to obtain some changes through a review of the site plans. We are concerned that removing requirements for a site plan for most properties in our area will lead to increased issues with garbage.
Recommendation: As noted above, we want to ensure that the urban design takes a neighbourhood approach during both the design process and implementation of these policies.
Transects and the Importance of Neighbourhood Character
The draft OP identifies six transects which do not necessarily recognize the unique character of neighbourhoods – nor do transects necessarily recognize how people function or move within their neighbourhood.
- The draft OP identifies Ottawa as a “city of neighbourhoods” yet the “transect” and “overlay” approach homogenizes neighbourhoods rather than recognize their unique character.
- Communities adjacent to each other may vary greatly in character based on history, difference in building lots or building sizes and how they function.
Recommendation: Create Sub-transects to reflect the unique character and history of Ottawa’s neighbourhoods.
Healthy and Inclusive Neighbourhoods
We commend City officials for promoting healthy and inclusive neighbourhoods, with the emphasis on walkable neighbourhoods and a cycling infrastructure through a safe systems approach in Ottawa and for recognising the role parks, greenspace and the urban forest canopy play in creating these neighbourhoods.
That said, the concept of 15-minute neighbourhoods is open to interpretation – there is no clear definition, per se, in the new draft OP. For example, the draft OP (Section 3) suggests that 15-minute neighbourhoods are defined based on what is available in hubs and transects. Yet elsewhere (Section 6) the draft OP states that neighbourhoods could be realized without depending on hubs and transects which appears to contradict what was stated in Section 3.
There are many questions which we feel should be answered before finalizing the draft OP:
- Is there a model for 15-minute neighbourhoods and who defines them? When is that done?
- Are 15-minute neighbourhoods anchored to specific amenities or services that must be present in all neighbourhoods?
- Is there mapping to show where these 15-minute neighbourhoods currently exist?
- Is there mapping to show which neighbourhoods will be designated as 15-minute neighbourhoods or is it that the OP has this as an aspirational goal for all neighbourhoods across the city? If it isn’t all neighbourhoods, what would the rationale be to select some but not others?
- What is the relationship between 15-minute neighbourhoods and transforming and evolving neighbourhoods? The former are not defined but have specific policies, while the later are defined but don’t appear to have policies attached.
Focussing the growth on existing 15-minute neighbourhoods may slow down the creation of new 15-minute neighbourhoods in other areas and may destabilize the current neighbourhoods by: changing the density too greatly, reducing housing choice, affordability and tenure; and by not providing commensurate social infrastructure.
Permitting non-residential uses in all residential areas, as-of-right, has the potential to reduce housing affordability and density unless there is a limit on how many non-residential uses a given neighbourhood can sustain. Businesses will likely pay a higher rent or purchase price than tenants or owners.
Providing no definition for “compatible” uses in the OP leaves it open for interpretation which may be detrimental to the surrounding community.
The provision of greenspace is an important aspect of healthy neighbourhoods. How is the desirable green infrastructure (Section 2.2.4, page 31) to be maintained, enhanced and protected in the face of such pressure to increase density when the design for infill buildings walls the trees to be planted into a tiny area of soil (the space of a car) that is often surrounded by three or more storeys of buildings which deprives the trees of the very things that it needs to grow: sunlight, land (space) and good soil?
There is currently no requirement in redevelopments to replace the larger trees that are cut down with tree species that will provide shade canopy at maturity. Often, the tree species that are approved for replacement are small tree species and bushes that will never provide adequate shade, if they survive at all. There are many examples in Hintonburg of infill projects where there were no trees planted at all, even when there is space available.
- How is the desired density of housing compatible with trees that require space known as the critical root zone, roughly equivalent to the size of the crown for their roots to thrive, good soil and sunlight?
- How will the existing trees be protected, and conditions created for new trees to grow to mature trees and support in mitigating the effects of climate change?
- How will the urban greening be provided? What measures will be used to ensure that the urban heat island effect is reduced?
- How will shaded sidewalks be achieved?
- If the city recognizes the importance of tree canopy throughout residential neighbourhoods, how can it create policy or incentivize infill projects to plant trees, given that developers currently are often not planting trees.
- If the required tree canopy and greenspace cannot be achieved on developed lots, where are the policies that will drive the creation of parks or other greenspace to maintain the needed proportion?
- Provide clear definitions of 15-minute neighbourhoods and clarity on the mapping process to define these neighbourhoods across the city before finalizing the draft OP by responding to questions listed on the previous page (see bulleted section pg. 6).
- Define transforming and evolving neighbourhoods and their relationship to policies for 15-minute neighbourhoods.
- Ensure that the design of infill buildings is compatible with the requirements for trees to grow and thrive (See Sections 4.6.5 and 4.6.6 and in particular 4.6.6 8 a) and d) and 9a)). Strengthen language around tree canopy and follow the OP up with incentives for developers to plant and maintain substantial trees.
- Protect the green infrastructure (trees, and greenspace) [Section 2.2.1, Policy Intent 3] by strongly enforcing the Tree Protection By-law. Preserve distinctive trees and planting on the subject property [as per Section 4.2.1. e) iii.] Ensure there is adequate space for trees to grow.
- Tie the creation of parks and greenspace to the loss of greenspace through infill and other development in established neighbourhoods.
Housing and Diversity Options
Regarding the size of housing units – Currently, there are 5,000 already approved new units that have yet to be built in Hintonburg/Mechanicsville, largely studio and 1 bedroom apartments that will not provide for a diversity of family types and structures.
Replacing a mix of small apartments and small family housing with small apartments for singles and couples does not provide an equitable choice to families – it drives them to the suburbs. The 613 flats will not apply to this area as we have few lots large enough (most lots are 10m or less), instead we are slated for buildings with tiny apartments. In addition, Hintonburg has three primary schools.
The draft OP states that a diversity of housing options, including “tiny houses”, coach houses and/or secondary units, are a key component of affordable housing stock. The draft OP describes housing options that would likely be smaller in size (maximum two-bedroom with most being studio or one-bedroom) and rented at market value. These are not practical housing options for families of more than two or three people.
- Where neighbourhoods have already achieved the 80 units/hectare goal, create clear language that does not require further intensification.
- Update zoning in less dense areas to increase the goal of 80 units/hectare in those areas and to provide a balanced approach to available housing, including housing for families.
- Incentivize developers to build and to offer larger housing units for families, specifically units with three+ bedrooms in new builds with more than three housing units.
- Include and define policy whereby a range of housing (e.g., tiny houses, multi-unit apartments, side-by-side duplexes) are an option for all neighbourhoods
Regarding Renovations vs. Tear Downs
Other countries have found it is more economical and more environmentally sound to renovate and add additions rather than the wholesale tearing down of sound buildings. There is a large environmental impact of construction materials in waste and much of the existing housing stock may be sound.
Recommendation: Encourage more renovations and additions rather than tear downs in conjunction with the Energy Evolution Strategy
Greening related to the Climate Crisis
We strongly support the need for the protection, preservation and growth of greenspaces in the context of a climate emergency which the City of Ottawa declared on April 24, 2019.
We commend the statements in the draft OP that “Ottawa must reverse the trend of urban tree loss”.
We support the new tree by-law requiring a 2:1 or 3:1 replacement, however, there is no mechanism to ensure the replacement trees on private property survive and no guarantee that the replacement trees that do not fit on the infill property are planted in the same community, especially if all the available space is taken up by development.
The new tree by-law, adopted on January 1, 2021, must be adhered to. Trees species must be chosen that will grow large enough to provide actual shade and the trees assessed for a period of 10 years to ensure survival and requirements to replace those that have died. A larger budget for Forestry is required to accomplish this and a plan for encouraging native trees and plants and diverse species of trees is required.
Maintaining the urban forest and street trees are stated goals in the draft OP but the Forestry Services for the City of Ottawa have been historically underfunded. – Please ensure Forestry is adequately resourced to accomplish this.
- In OP, Include ALL residential properties, no matter their transect area, have sufficient space for trees to grow and thrive. (See Sections 4.65 and 4.66 of OP for examples)
- Maintain, enhance and protect the desirable green infrastructure despite the intense pressure to increase density.
- Create measures to measure and monitor the urban island heat effect and provide means such as, shaded sidewalks through planting and protecting the trees along the streets, to reduce this urban heat island effect (Section 2.2.3, Policy Intent 5 and 7 page 28).
- Ensure that the new OP’s 40 % tree canopy target is applied at the neighbourhood level as opposed to city-wide: and
- Exclude the National Capital Commission (NCC) and Greenbelt lands when calculating the 40% tree canopy target city-wide. We are making the specific recommendation that the NCC, and Greenbelt lands be excluded from the landmass calculation.
We are pleased to see that the draft OP aspires to provide equitable access to urban greenspace with provisions for access by transit to public greenspace within walking distance of an urban natural feature or natural environment area. However, there are no requirements regarding the size of such greenspaces. Greenspaces (trees and greenspace) must be protected and closely monitored to support the aspirational goals of the OP to create and support healthy and liveable cities. This is particularly true in inner-urban areas, such as Hintonburg, where a high rate of intensification is projected into the future.
- Define minimum requirements for greenspaces per neighbourhood, taking into account the need for additional public greenspace requirements where population density is higher.
- Require a monitoring process for this requirement and strengthen OP policy to fund additional public greenspace lands and improvements of those lands as density increases.
The draft OP has a separate section on parks; parks feature sports playing fields which are different from greenspace and the urban forest. We are encouraged to see that the draft OP clearly states that parks are not only a priority within Ottawa’s growth areas but that new parks be provided in inner urban areas and in the downtown core.
- There are no clear mechanisms outlined to increase greenspace, urban canopy, parks, recreation opportunities and social infrastructure as density increases. The previous Official Plans or Master Plans have not fulfilled these requirements.
- Hintonburg is already well below the ratio for parks, with only 0.82 hectares/1000 population (2016) rather than the policy of 4 hectares/1000 residents. Approved developments in the last 7 years, that are yet to be built, will double the population and further decrease the ratio.
- New parks must keep pace with population growth. Clear metrics tied to population growth are required for this to happen.
- The draft OP states that where cash-in-lieu is taken, it should be principally for new parkland or improvements to existing within the neighbourhood being developed, but that a proportion will be used for those things that are city-wide. Those funds should be focused on areas of the city which are among the lowest ratio for parkland well below the target of 4 hectares/1000 residents.
- To what degree have the targets been met in individual neighbourhoods?
- Which neighbourhoods have fallen short of that objective? Is that information available currently? This needs to be determined before policies can be developed and implemented.
- Remove the provision regarding the use of a proportion of cash-in-lieu funds for city-wide use and, instead, use 100 percent of these funds within the ward where they are collected.
- Alternatively, focus the City of Ottawa’s cash-in-lieu funds for parkland in those neighbourhoods which have the lowest ratio of parkland per 1,000 residents. This strategy would bring more equitable access to residents across the city, given that dense neighbourhoods do not have large yards as compared to yards in outer urban areas.
We are encouraged by the Big Policy Move 2 (page 14) that has sustainable transportation as a foundation of vibrant, walkable and convenient neighbourhoods where it is possible to walk or cycle to community infrastructure and most other amenities.
However, we have concerns how existing streets, that is streets already constructed, will be adapted to support cycling infrastructure. We are particularly concerned for neighbourhoods in the inner urban transects such as Hintonburg where the streets are narrow and are now expected to accommodate a marked growth in sustainable modes of transportation such as cycling, walking and carpooling and public transit.
While the draft OP appears to focus on the development of new or reconstructed streets, how does will this priority be achieved in neighbourhoods such as Hintonburg, where we expect to have an influx of residents living in new buildings and larger developments designed with little or no parking around busy transit hubs at Tunney’s Pasture and Bayview stations?
Recommendation: Ensure that existing streets are as much of a priority as are new or reconstructed streets for sustainable modes of transportation, particularly in areas in close proximity to transit hubs. Determine how this will be funded.
Impact of Covid-19 Pandemic
The draft OP is founded on assumptions that do not acknowledge the impact of the Covid-19 pandemic and the health emergency that was announced almost a year ago now and the unanticipated change to how we live, work and play. While we could not have predicted how this pandemic would change behaviours, it is undeniable that it has impacted on:
- How and where we work and loss of employment.
- Significant reduction in transit ridership with many employees now working remotely from home – the federal government, which is a major employer in the region, has shifted to this trend of working from home.
- Businesses may have closed or are attempting to pivot to conform to restrictions to curb the pandemic by offering curbside pick-up, delivery or limited in-person shopping. It is premature to say if these trends will become entrenched business practices, but they may if customer demand is high.
- City Council delay its Official Plan process until such time that there can be a complete assessment made of the permanent changes to life, work and play as a result of COVID -19.
- The City of Ottawa amend its draft Official Plan planning process to seek public input on an updated draft Official Plan in the first quarter of 2023.