7/31/2019 EFCL Letter to Council - Supportive Housing Provisions

1/2

August 17, 2012

Dear Mayor Mandel and City Councillors,

Re: August 27 Public Hearing, Item 5.9 Text Amendments to Accommodate Seniors Living and other

Supportive Housing

The Edmonton Federation of Community Leagues encourages City Council to send the Community

Supportive Provisions back to Administration for revisions and further considerations:

1. We strongly recommend that the application of the Supportive Community Provisions bediscretionary so that the neighbours and Community Leagues are notified of the proposed

supportive housing and there is an opportunity for consultation.

There is no doubt that proposed supportive housing , particularly large developments, will have

both a positive and negative impact on the neighbourhood, thus it is essential the

neighbourhood be consulted in order to maximize the positive impacts and minimize negative

impacts. To do otherwise would be contrary to the Citys Public Involvement Policy C513 which

states the Citys commitment to citizen engagement : A key element of representative

democracy is that people have a right to be involved in decisions that affect them.

Under the present bylaws and procedures, Community Leagues and neighbours are informed

and consulted when higher densities and parking reductions are allowed by the City. But this

democratic right to information and consultation would be denied under the proposed text

amendments. The Supportive Community Provisions would allow a 25% increase in density

(without a public hearing) and would allow less than half the usual parking requirements

(without having to do a parking study), all without informing or consulting the neighbours who

would be impacted. This is not acceptable.

We are not asking you to scrap the Provisions. All we are asking for is the right of citizens

impacted by the Supportive Community Provisions to be informed and consulted.

Furthermore, reduced opportunities for neighbours to be informed of proposed supportive

housing could not come at a worse time from EFCLs perspective. This fall we are hoping toembark on a collaborative research and demonstration project to enhance neighbourly relations

with supportive housing all kinds of supportive housing. We would like to see increased

opportunities for dialogue and interactions between Community Leagues and housing projects,

rather than fewer opportunities. Neighbourly relations could be impeded by not making the

Provisions discretionary.

7/31/2019 EFCL Letter to Council - Supportive Housing Provisions

2/2

2. We recommend that the Supportive Community Provisions be considered when the textamendments for Congregate Living are considered. Both projects are interdependent. The

Congregate Living project is attempting to monitor and prevent further concentration of

supportive living accommodations. However, the draft text amendments state that housing

using the Supportive Community Provisions would be exempt. It is difficult to monitor and

control supportive housing if most supportive housing is exempt. Although the Supportive

Community Provisions were created with Seniors Housing in mind, these Provisions can apply to

any kind of supportive housing. This dilemma needs to be resolved before adopting the

Supportive Community Provisions.

3. Research evidence suggests that the proposed parking requirements will not meet the parkingneeds of supportive housing for seniors.

Bunt & Associates examined the actual parking demand for 6 supportive living seniors

residences in Edmonton. The peak demand for blended parking (residents, staff & visitors)

ranged from .79 stalls/unit to .29 stalls/unit, with the average being .55 stalls/unit. Based onthis peak demand, we know that the proposed parking provisions of .4 per sleeping unit and .5

per dwelling unit will frequently not accommodate regular peak hour demand, thus on-street

parking will still be needed for visitors at certain times of the day.

The Bunt report also points out that the Institute of Transportation Engineers Seniors Facility

Parking Survey concludes that weekday peak parking demand is 1.0 stalls/dwelling unit for

Continuing Care Retirement Communities. Given that these age in place facilities are the types

of facilities that the Province is wanting to fund, it is fair to assume that the peak parking

demand for the new facilities will be close to 1.0 stall/unit. This is approximately double the

parking requirements in the proposed Provision.

Please recognize that the dramatically reduced parking requirements being proposed will have

an impact on the neighbourhood.

Again, we want to emphasize the importance of making the Supportive Community Provisions

discretionary and ensuring community consultation. We are confident that you, as elected officials, will

understand the importance of consultation and democracy.

Regards,

David Dodge, President