Since we launched the R4 Review in September, we've received some written comments from developers, individuals and Community Associations. We have posted some of those comments below. If you haven't had a chance to send us your thoughts yet, please take a moment to send us an email at R4Zoning@ottawa.ca or email@example.com.
"Very large units with many bedrooms create what is effectively a rooming house."
We whole-heartedly support action by the City to limit the number of bedrooms permitted in low rise dwelling units such as duplexes, triplexes, and apartment buildings with four or more units. The tendency to build very large units with many bedrooms creates what is effectively a rooming house and makes a mockery of the zoning requirements. The problem of dwelling units that skirt the zoning bylaws is not limited to new construction. Numerous examples exist in our neighbourhood of semi-detached or single unit houses that are converted to multiple resident dwelling units. By signing a lease with only one resident, who in turn collects rent from the other tenants, landlords are able to circumvent the intent of regulating rooming houses. There needs to be some reasonable restriction that works in practice. (Community Association.)
"Measures in R4 may simply move the problem to adjacent zones."
We are concerned that action to limit the number of bedrooms only in the R4 zones will simply transfer the pressure to build what may be termed ersatz rooming houses to the R3 zone, where triplexes are permitted. Already there are examples in our neighbourhood of triplexes which are effectively 12 to 15 unit rooming houses. We feel that there needs to be regulation of both R4 and R3. (Community Association.)
"Demand for student housing is not sustainable; what happens when these units are no longer needed?"
The numbers of students attending university and college is now starting to decrease due to demographic change. This means the demand for the low grade housing is starting to ease. This housing is not amenable to other uses or potential residents, and thus may end up being abandoned or left in a state of even further disrepair. Action needs to be taken now to prevent this problem from occurring in the next few years. (Community Association.)
"Lack of parking"
The intensification of usage of both existing dwellings and new construction has led to a lack of available parking. Although the intention of intensifying development is for the tenants or owners to rely on public transit, they often do own cars, even university students. These vehicles are frequently parked on the streets, or the owners convert required green space on their properties into parking. With so many cars parked on the street it is sometimes difficult for vehicles to pass each other, particularly for large emergency vehicles, and especially in the winter. We can petition to reduce the parking to only one side of the street, but with a large proportion of the housing stock rented it is very difficult to achieve the necessary level of acceptance to do this. There need to be changes to the rules of intensification, either making it easier to restrict parking to one side of the street, require more on-site parking, or both, to ameliorate this problem. (Community Association.)
"Loss of communal green space"
Intensification reduces the amount of communal green space available. Firmer rules around the provision of parks and green space where intensification of usage is permitted are required. (Community Association.)
"Limits on bedroom counts cannot be effectively enforced."
It is difficult to see how limits on bedroom counts per unit would work; how are you going to prevent someone from bedding down in a “family room” or so-called “den”? For similar reasons, refining definitions of “rooming houses” and “apartment buildings,” or that tying number of units to lot size, are problematic. (Individual.)
"Oversized dwelling units are cost-effective given a limit on permitted units."
A large dwelling unit is the only way for development to be cost effective for the builder, and ultimately the for renter where the number of units is limited to 4 unit in R4 zone (such as Sandy Hill). If the City granted higher unit density, these large dwelling units would immediately disappear for a more traditional unit size. (Developer.)
Another point is to allow this type of dwelling, but enforce landlord licensing. This way, from a city bylaw/permit point of view it's fine, and from a community point of view it's also taken care of with the licensing. (Developer.)
"Permit oversized dwelling units, but only in detached buildings"
We support the proposal to define an “oversized dwelling unit” as one in the six-to-eight range of bedrooms; to disallow more than eight (or even more than six); and to limit ODU’s, as defined, to detached dwellings. And by all means, let’s distinguish oversized dwelling units and rooming houses in Ottawa’s zoning by-law definitions, this in line with court and OMB rulings. (Community Association.)
"Cautiously support reviewing four-unit limit in the junior R4 (R4A-R4L) subzones"
We are concerned that the proposal to raise the current four-unit limit in the junior R4's might encourage developers to max’ out building envelopes, giving them more diverse ways of doing so. However, maxed-out envelopes which also contain ODU’s, resulting in maximum densities, are the most objectionable forms of infill. On that account, we are inclined to support this proposal, assuming that its effects would be monitored and, if called for, reconsidered at a predetermined time. (Community Association.)
"Support limiting bedroom counts in dwelling units, but caution against being too restrictive"
We do feel that the Discussion Paper suggestion of a maximum of 50% of units having more two bedrooms is too restrictive. It would have the effect that, in duplexes and triplexes, only one unit can contain more than two bedrooms, which would be an excessive restriction. We would not want to prohibit a building devoted entirely to housing families - with every unit containing e.g. three bedrooms.
The idea of restricting bedroom counts is a good one. We don’t like complicated regulations but a more refined formula might be called for. For example, a relatively simple provision, such as, only 30% of units can be more than three bedrooms – would be more acceptable to all. This would be restrictive but still control the extraordinary cases of 6, 8 or 12 bedroom units to that of being a smaller portion of the space within those multi-unit residential buildings. (Community Association.)
"Unsure/conflicted about reviewing the minimum lot size for low-rise apartment dwellings"
You give a good account of “unintended consequences”, whereby restricting a lot to a duplex or three-unit dwelling on the basis of its size, simply encourages the same massing and occupancy across fewer units. It highlights the difficulty of devising rules (by-laws, as distinct from mere guidelines) that will produce more appropriate infill while we continue to intensify.
Allowing apartment dwellings on smaller lots than the zoning currently allows may mitigate this identified unintended consequence. On the other hand, it may result in more, skinnier (and probably boxy) 4-storey apartment buildings, infilled in some established streetscapes characterized by attractive, more traditional, peaked and considerably lower building forms. (Community Association.)
"Requiring indoor garbage storage for all multiple-unit housing forms is excessive where development is already subject to site plan control."
We do not support the proposed provision to require indoor garbage storage for all multiple unit housing forms. If there are problems of garbage storage with dwellings such as duplexes and triplexes that are not subject to site plan control, then making indoor garbage storage a requirement under the zoning by-law does make sense. However, for those multiple residential units already subject to site plan control that planning mechanism is sufficient to regulate where and whether the garage storage area need be in a building or in a fenced exterior location. (Community Association.)
"Interested in hearing more about maximum lot sizes for low-rise apartment dwellings."
We strongly agree about the need for further consideration to recognize and address the potential problems presented by lot consolidation and the massively out-of-scale development that can follow. We would like to hear some proposals before the R4 Zone Review comment period closes and while there is still time for discussion. Lot consolidation in the middle of a block of uniformly sized lots to permit a larger sized multi-unit dwelling would not be appropriate. But on a street with many lots of quite variable sizes or at the end of a block or on collector roadways they might be appropriate. Lacking a CDP or secondary plan for our area is there some way in which lot consolidation policy direction can be provided? The Official Plan is meant to be a general high level guiding document. Can it get into such detail or is that best left to a supporting document approved by council, even if only a “guideline” document? (Community Association.)
"What safeguards can ensure that a neighbourhood's evolution is indeed gradual and that new development is in fact compatible?"
There are some streets already displaying a wide mix of heights, including sites with old and undersized houses, some in less than top shape, that are ripe for redevelopment, where higher and denser would be quite appropriate. However, a large part of our established and very predominantly low-profile community is zoned R4 (and R3). The great majority of streets and blocks in these zones have “desirable characteristics” and attractive streetscapes that are presently vulnerable and exposed to ill-fitting 4-storey apartment building infill (and 11-metre high, flat-roofed triplexes).The Discussion Paper suggests that apartment buildings could be permitted on smaller lots than currently allowed, “...subject to zoning and other rules that ensure that this will be physically compatible with the neighbourhood.” It’s that last clause that’s the catch. Such “zoning [regulations] and other rules” don’t presently exist. The manner in which Sections 2 and 4 of the Official Plan address compatibility and mitigating measures is in need of much improvement. It affirms that ‘compatibility is not quantifiable,’ and then sets out a list of “measures” that can be used to mitigate non-compatibility. The abuse occurs when planners ‘add up’ a number of mitigating measures employed by a developer and conclude that the ‘total’ renders the development “compatible.” The result is, frequently, that a proposal that is patently incompatible is deemed to be okay (compatible) by City’s professional planners with supporting arguments quoting lines or “measures” from the Official Plan which ordinary people can in no way refute. (Community Association.)
"Agree that development charges should be reviewed at the next opportunity; currently they incentivize a smaller number of very large units."
You indicate that there is only one DC fee for apartments notwithstanding their size or number of bedrooms. So in the case of four very large units the charge would be payment of four DC fees, yet the same sized building split into 16 units would be required to pay 16 DC fees. It appears that the incentive is to have bigger units with more bedrooms because you pay less DC fees. This does not respect the intent of development charges that are to be “roughly proportional to their occupancy”. We understand that having a two charge rate depending on size for apartments might discourage their construction if the cut off between the two types is set too low, e.g. at two or three bedrooms. If however it is set higher say at six bedrooms this is justifiable, which may discourage the creation of those units with 8, 10 or 12 bedrooms. However, as with the zoning provisions limiting bedroom counts, we wonder if there would be attempts to get around this by labelling bedrooms as “studies” or “dens”? (Community Association.)
"Concerned about student rooming houses"
I'm writing to voice my concerns with yet another "rooming house" being built in my neighbourhood. I moved to this area because of its charm and quiet established atmosphere. Since moving into the area it has quickly become what feels like an extension of Ottawa University's frat housing. I guess there isn't enough student housing on campus. Don't get me wrong, I don't mind students renting rooms in the existing homes, but building all these rooming houses without consideration to the residents needs is not fair. Already there is garbage littered on their lawns and at times not being picked up (by the city). There is barely enough parking on the street as it is. My visitors are finding it more and more difficult to find a spot in the area and when winter comes this is worse. (Individual resident.)