Letter to Minister Clark

Ottawa, November 26, 2021

Hon. Steve Clark, Minister of Municipal Affairs and Housing

College Park 17^th Floor, 777 Bay St. Toronto, ON, M7A 2J3

Dear Minister Clark,

Ottawa City Council approved a new Official Plan on October 27^th, 2021. It now comes to you and your office for review and final approval. 

This letter, from an alliance of 21 well-established civil society organizations in Ottawa, seeks to summarize some of the concerns regarding this Official Plan raised city-wide by resident associations and community groups. We want to ensure that your office hears these perspectives and solutions, and not only views from the City and some segments of the development industry. 

The strategic directions described in the Council-approved Official Plan have our strong support. They focus on intensification, sustainable transportation, 15-minute neighbourhoods, climate and health resiliency, and economic sustainability, and do an admirable job of defining the desired destination. There remains, however, a fundamental disconnect between the policy ends and the policy means included in the Official Plan. The most serious of these are as follows: 

1. Expansion of the Urban Boundary

The Official Plan approved by Council adds 1,281 ha to Ottawa’s urban area to accommodate projected residential growth. The City calls this a “balanced scenario,” with 51% of new urban dwellings provided through intensification and 49% built on existing vacant or newly added greenfields. 

The City’s own modelling shows that the number and type of dwelling units needed to meet the projected residential growth can also be achieved without expanding the urban boundary. A staff report calls this the “no expansion scenario”, and notes that it can achieve the goal while maintaining at all times the ability to accommodate residential growth for a minimum of 15 years, as required by the Provincial Policy Statement (PPS). In the City’s own words, a “no urban expansion scenario represents the greatest extent to which growth management can contribute to achieving policy directions where most growth occurs through intensification, growth uses existing infrastructure most efficiently, and GHG emissions reductions are maximized.”

The Hemson 2021 update commissioned by the City confirms as well that intensification is far more economical from a public financing perspective than greenfield development (infill generates municipal revenues of $606/person/year while greenfield development costs the municipality $465/person/year, plus unknown ecological and climate costs). And yet, despite these hard numbers, the no urban expansion scenario was rejected by Council and significant urban expansion approved. It places 49% of the projected population growth on greenfield lands where public costs are highest and the majority of intensification downtown and in towers where private costs are highest. This is nonsensical, and inconsistent with the policy objectives of the Official Plan, the PPS and the City’s own analysis.

In the context of climate change and fiscal responsibility, there should be no urban expansion if growth can be accommodated otherwise. We therefore call on the Minister to uphold the Provincial interest by reversing Council’s decision to expand the urban boundary.

2. Key Policy Gaps

2.1 Consultation with Indigenous Leaders

The City of Ottawa is located on the unceded traditional territory of the Algonquin Anishinaabe. It is clear, however, that the City of Ottawa has not yet meaningfully consulted with all the Algonquin communities impacted by the Official Plan, as required for land-use planning matters by the Province. For example, the Kitigan Zibi Anishinabeg Nation and the Algonquin Anishinabeg Nation Tribal Council have denounced the Official Plan consultation process as woefully inadequate. We find this gap concerning, especially as the Mayor and some Councillors have cited reconciliation with Indigenous Peoples/Nations as the primary rationale for a key political decision in the urban expansion plan (the Tewin land allocation, see below).  

We call on the Minister to uphold guidance in the Provincial Policy Statement governing land-use planning and Indigenous interests, including consultation, the coordination of planning with Indigenous communities and policy implementation in ways consistent with their rights. 

2.2 Housing Affordability

The Ottawa housing market, and hence the housing affordability discussion, is best understood by distinguishing between market affordability and deep affordability.

Market affordability: 

Middle-class residents and new market entrants are increasingly priced out of market affordability due to a variety of inter-related factors, only some of which can be addressed through the Official Plan. These include population growth, inflation rising faster than wages, rising construction sector prices, limited housing supply in transit-served areas, regulatory uncertainty, higher property taxes and social trends such as aging in place and pandemic responses affecting the long-term demand for urban housing.

Solutions to market affordability can be found within the current urban boundary. An optimal response would be to plan for a better distribution of density and innovative housing forms (especially low-rise development) in all built up areas of the city, whether it be through intensification or greenfield development. These have more scope for addressing market affordability than concentrating density in a few areas and on a few housing forms such as massive towers that are expensive to build and unsuitable for many demographics.

Deep affordability: 

Low-income residents are increasingly priced out of the affordable housing market and sometimes pushed out of deeply affordable housing. This creates housing stress and homelessness. The loss of low cost private rentals and the slow growth of deeply affordable, social, cooperative and geared-to-income housing, adds to the urgency. 

The Official Plan lays out a definition of housing that recognizes that everyone deserves to have housing that costs no more than 30% of their income, and commits to identifying and acquiring additional lands for social housing. It also makes significant commitments to equity and racial justice, and plans to track equity across urban and rural neighbourhoods. 

We strongly support these steps. However, additional policies are needed in the Official Plan to put effective anti-displacement measures in place to control the demolition of affordable private rental housing due to gentrification. Support for non-profit housing providers is also needed, as is greater attention to neighbourhoods where City amenities (daycare, public transit, tree canopy, community food assets, etc.) are significantly under-resourced. More generally, the Official Plan should raise the profile of the Council-declared housing and homelessness emergency by making deep affordability a strategic direction aligned with the National Housing Strategy Act (2019). 

2.3 Livability 

The Official Plan describes a compelling vision of “15-minute neighbourhoods,” where people can live, work and play. However, it lacks the policy means for existing and new communities to become progressively more complete, with the parks, trees, walkability, bikeability, businesses and community services/assets that make for livability. With the new Official Plan, tall towers and road corridors will dominate inside the NCC Greenbelt and inner urban neighbourhoods will lose the trees that make them livable. On new greenfields, and in suburbs and villages outside of the NCC Greenbelt, the amenities needed to make neighbourhoods walkable and safe for cycling will remain scarce, and jobs nearby scarcer still. Conflict between developers and neighbourhoods, and car dependency, will remain the norm. 

To avoid this outcome, the Official Plan should plan, as noted above, for a better distribution of density and innovative housing forms (low-rise development) in all built up areas, inside and outside of the NCC Greenbelt. This can only be achieved through context-sensitive planning and design of complete, functioning communities and streets with active modes of transportation. New technologies and simple, collaborative processes can help to visualize and test ways to ensure neighbourhood plans are robust, achievable and enrich the characteristics valued by residents and local organizations. We ask the Minister to direct the City of Ottawa to plan for complete communities at the neighbourhood level, supported by modelling as an analytical tool for engaging residents and other stakeholders.

Among the liveability characteristics valued by communities, access to tree canopy and access to greenspace were the top issues – by far – raised by public delegations over the course of plan development. This was true for neighbourhoods in tree deserts as well as in currently treed neighbourhoods. The City responded positively by enhancing targets for access to tree canopy and greenspace and acknowledging that eliminating tree deserts is a fundamental equity measure. These policies stop short, however. Without neighbourhood level targets and clear, enforced rules, tree deserts will remain and currently treed neighbourhoods will continue to decline. We ask the Minister to call on the City of Ottawa to establish neighbourhood level targets for access to tree canopy and greenspace, and a no-net-loss rule for communities.

In addition to fostering gentle density in existing communities, all greenfield development (new communities) should be developed as complete communities and complete streets from the beginning, rather than retrofitted for density and active transportation afterwards. We ask that the Minister call on the City of Ottawa to bring density targets for all greenfield developments in line with the targets and strategies for fostering complete communities in the currently built up areas of the city.

2.4 Food 

Where will our food come from in the future? The Official Plan does not adequately address this question. While protections for farmland are written-in as required under Provincial law, the protections are routinely ignored by Council in favor of other priorities. For example, Council recently voted to remove 106 ha of prime farmland in Riverside South from the protected Agriculture Resource Area, and allocate it to the urban expansion area for residential development. This land, close to transit and surrounded by existing housing and services, could have provided opportunities for dozens of market garden enterprises and helped to meet unfulfilled demand for locally-produced food. We call on the Minister to uphold the provincial interest regarding agricultural land by reversing Council’s decision on the allocation of this prime agricultural land to residential development.

The Provincial Policy Statement contains no minimum parcel size for agricultural lands, calling instead for lots “appropriate to the area.” By contrast, the Official Plan establishes a minimum 36 ha parcel size for severances of agricultural land, even though the current average farm parcel in the City of Ottawa (23 ha) is much smaller. This provision creates an unnecessary bias towards larger farm parcels, making it more difficult for farmers to access farmland scaled to their own market niche and production plans. We ask the Minister to call on the City of Ottawa to establish a minimum severance of 8 ha. This would be consistent with the PPS guidance and enable the development of a more diversified local farming sector.

Despite public calls for a food lens at the level of the Official Plan, enabling policies have been pushed into the Greenspace and Urban Forest Masterplan. This lower level policy is relevant, but cannot resolve cross-cutting mandates such as the Parks and Recreation Masterplan where significant decisions are also being made regarding the core services of public spaces. Scope for food security programs within the urban, suburban, and rural areas of the city are at risk of being shuffled between City departments and falling through the cracks. To avoid this problem, we ask the Minister to direct the City of Ottawa to coordinate lower level plans through a “joined-up” approach to food security across all departments. 

2.5 Climate

A lesson we can take from the current global pandemic is that in a crisis bold action is needed. This applies even more to the climate emergency, which has become ever more urgent and impactful.

The Official Plan should be Ottawa’s climate emergency plan, but it is not. It perpetuates an attitude of delay and climate denial, leaving Ottawa exposed and vulnerable to the flooding, heat waves and wilder weather already costing Canadian lives and billions of dollars.

The decision to expand the urban boundary and gaps outlined above in policies regarding housing affordability, urban density, liveability and food security all undermine efforts to mitigate greenhouse gas emissions and adapt. To these we add three other climate policy areas that should be addressed more effectively by the Official Plan: energy, transportation and resilience.

Much more could be done to ensure that the Official Plan aligns with PPS 1.8.1 f) on energy conservation and efficiency and the role of vegetation and green infrastructure in mitigation. A new High Performance Development Standard referenced in the Official Plan is triggered by site plan control but allows many developments to be exempt, including all low-rise residential and mixed use developments. As a result, more than half of the new builds planned through intensification will not be required to apply the High Performance Development Standard. In addition, there are no High Performance Development Standards for existing buildings, even though the City estimates that over 325,000 buildings in Ottawa will be renovated or expanded as part of intensification and a proposed energy transition. We ask the Minister to direct the City of Ottawa to provide specific guidance in the Official Plan on the energy efficiency and green standards it expects for developments exempt from the High Performance Development Standards. 

On energy supply, the Official Plan fails to align with PPS 1.6.11 mandating the development of electricity generation facilities, transmission and distribution systems, district energy, and renewable energy systems and alternative energy systems, to accommodate current and projected needs. Without this guidance, Ottawa will not be able to do its part to transition to a low carbon economy. We ask that the Minister remind the City of Ottawa of its obligation to provide opportunities for the use of energy sources consistent with a climate-safe future.

Transportation accounted for 44 percent of Ottawa’s greenhouse gas emissions in 2019. The Official Plan recognizes the need for a modal shift from cars to public transit and active transportation as part of a climate response. However, it lacks the commitment to drive this shift, firmly and quickly, to transit and active transportation. The Official Plan should have policy guidance on the rapid development of safe and pleasant connections between transit stations, pedestrian routes and cycling infrastructure in neighbourhoods. It should also do more to enhance public transit connections across jurisdictional boundaries (with Gatineau and with rural communities). Policies in the Official Plan are also needed to facilitate the movement of people and goods on e-bikes and cargo bikes for use by businesses and individuals. Demand studies show that the majority of trips currently undertaken by Ottawa residents are under 5 kilometres, an accessible distance for assisted cycling. We ask the Minister to direct the City of Ottawa to establish policies in the Official Plan that support system connectivity in line with PPS 1.6.7.3, restrict new road construction and give greater priority to transit and active transportation.   

Finally, the Official Plan does an admirable job of referencing resilience among the strategic directions of the Official Plan. However, the detailed background risk and resilience studies needed to inform the policy means were not completed prior to plan approval. As a result, the Official Plan does not provide the policy guidance needed to ensure appropriate adaptation and resiliency measures are implemented in subsequent Master Plans, by-laws and zoning regulations. Guidance is needed to protect public assets (infrastructure, transportation) and human health and property from future climate impacts. We ask the Minister to direct the City of Ottawa to integrate climate risk and vulnerability analyses into City plans, by-laws, zoning and capital projects, and make climate risk data and maps available to the public as soon as they are completed. This supports transparency and people and businesses that want to make their own adaptation plans.

2.6 Financial Implications and Risks

The public has not yet been provided with detailed estimates of how much the Official Plan will cost or how these costs will be distributed. We can be sure of two things, however: 

1. The proposed urban boundary expansion will increase the tax burden on established communities and permanently lock-in higher emissions of greenhouse gases from housing and transportation, and; 
2. The capital and operating costs of an affordable, high-service, accessible public transit system are high.  

Mapping out the financial burden of decisions embodied in the Official Plan and expectations regarding how these costs will be shared is a key function of responsible municipal leadership. We ask the Minister to uphold the provincial interest in fiscal transparency by calling on the City to undertake a comparative financial analysis of Official Plan policies encompassing growth, climate action and public transit. 

The Tewin financial risk 

One unmitigated financial risk stands out above all others: Ottawa’s rushed and huge urban expansion land-deal. The Tewin development was proposed by the Mayor in the name of reconciliation and with claims that it would benefit the Algonquin people. Too many questions regarding this decision remain, however, including:

• The poor quality and incompleteness of consultation with Indigenous Peoples/Nations;
• Serious technical constraints on the land in question (which scored poorly on Council-agreed rating criteria), and;
• The cost and potential liability for the City of a Private Public Partnership that may be in the billions, rivalling Ottawa’s investment in Light Rail Transit (LRT).

City staff originally asked Council to take the time needed to answer these questions, before allocating part of the urban expansion quota to the Tewin proposal. We agree with the staff recommendation, and call on the Minister to uphold the Provincial Policy Statement regarding consultations with Indigenous Peoples/Nations and provincial guidelines on good planning and public financing by reversing Council’s decision on the Tewin land allocation. We also ask that next steps on a Memorandum of Understanding between the City and Tewin, drafted in November, not be delegated to staff. Rather, the MOU should come to Council once more information is available, supported by independent reviews of the financial risks to the City. More than any other single component of the Official Plan, this decision could be the most expensive legacy of this Council.  

2.7 Monitoring Success

The Official Plan on its own can’t solve all the big problems and emergencies Ottawa faces. All levels of government and all sectors of society are needed to do that. The Official Plan does, however, provide an opportunity to set goals, track progress on these goals in real time and make timely course corrections as needed. 

What goals are monitored, and how, matters if the Official Plan is to provide the public with a comprehensive view of our city. It is also important to recognize that policies interact in unpredictable and consequential ways. We support, for example, the commitment outlined in the Official Plan to monitor intensification targets and plans for urban expansion in light of actual progress in achieving the greenhouse gas emission targets laid out in the City’s Climate Change Master Plan. Other interactions may also be important to building public support for the Official Plan, such as the impact of intensification on neighbourhood liveability. Consequently, we call on the Minister to direct the City to support community engagement in the development of metrics related to each of the strategic directions of the Official Plan.

3. Enabling Provincial Policies

In addition to concerns about Ottawa’s Official Plan raised above, we call on the Minister to undertake those changes to the Planning Act and other provincial policies needed to support the strategic directions of the 2020 Provincial Policy Statement and Ottawa’s Official Plan. They include:

Housing

• Modify Section 16 of the Planning Act to anticipate and plan for deeply affordable housing in all neighbourhoods and new construction projects, not only near transit hubs, and permit specific support for social and geared-to-income housing.

Transportation

• Authorize municipalities to implement transportation pricing such as congestion charges or private parking levies so that the full cost of road maintenance can be distributed equitably;
• Implement a toll HOV lane on the 417 and use the revenues to fund transit projects;
• Require electric vehicle charging features in all new buildings.
• Authorize municipalities to offer GHG mitigation rebates to permit the purchase of e-bikes and cargo bikes for use by businesses and individuals.

Climate

• Allow municipalities to require zero-carbon heating sources for new developments; 
• Allow municipalities to require buildings to connect to a district energy system if one is available;
• Enable virtual net metering for renewable energy generation;
• Implement a net zero building code;
• Require energy labeling of all buildings (new and existing);
• Remove emissions from the electrical grid to ensure electrification is carbon free (in Ottawa this could be achieved by increasing the interconnection with the Province of Quebec);
• Recognize the critical role of green infrastructure in mitigating the impacts of climate change and improving human health. 

 

Thank you for your attention. 

Sincerely,

Signing members of the People’s Official Plan:

Daniel Buckles, corresponding author on behalf of the People’s Official Plan

P.O. Box 55085, 240 Sparks Street, Ottawa, ON K1P 1A1

Kaite Burkholder Harris, Executive Director, Alliance to End Homelessness Ottawa

Board of Directors, Bike Ottawa

Joan Freeman, Founder, Citizen Climate Council (C3)

Valerie Stam, Executive Director, City for All Women Initiative (CAWI)

Janet Mrenica, Regional Organizer, Southeastern Ontario, Climate Reality Hubs

Angela Keller-Herzog, Executive Director, Community Associations for Environmental Sustainability (CAFES)

The Council on Aging of Ottawa / Le Conseil sur le vieillissement d’Ottawa

Liz Bernstein, Member of the Board of Directors, Ecology Ottawa

Mitchell Beer, Publisher, Energy Mix Productions

Alex Cullen, President, Federation of Citizen’s Associations (FCA)

Marianne Ariganello, Co-lead, For Our Kids Ottawa/Gatineau

Paul Johanis, Chair, Greenspace Alliance for Canada’s Capital

Jenny Emmans, Chair, Just Food

Dr. Eugenie Waters, Dr. Sarah Sloan, Dr. Josdalyne Anderson & Dr. Brianna McKelvie, Ottawa Co-Leads, MD Moms for Healthy Recovery

Aaron Thornell, Customer and Member Manager, Ottawa Renewable Energy Coop and CoEnergy Coop

Chris Penton, President, Ottawa Street Markets

Board of Directors, Ottawa Transit Riders

Carolyn Mackenzie, Walkable Ottawa

Duncan Bury, Founding Member, Waste Watch Ottawa

 

Copy to:

Kate Manson-Smith, Deputy Minister, MMAH

Jim Watson, Mayor of Ottawa

Stephen Willis, General Manager, Planning, Infrastructure and Economic Development

M. Rick O'Connor, City Clerk

Steve Kanellakos, City Manager