Maintaining the current urban boundary while meeting the new PPS housing supply constraint
by Paul Johanis, Greenspace Alliance of Canada’s Capital, and co-convenor of the Peoples Official Plan for Ottawa’s Climate Emergency
The Provincial Policy Statement contains a provision which requires that planning authorities (in our case the City of Ottawa) maintain at all times a set minimum supply of new housing. Here is the relevant extract from the PPS 2020:
1.4.1 To provide for an appropriate range and mix of housing options and densities required to meet projected requirements of current and future residents of the regional market area, planning authorities shall:
a) maintain at all times the ability to accommodate residential growth for a minimum of 15 years through residential intensification and redevelopment and, if necessary, lands which are designated and available for residential development;
The main change in the PPS 2020 that affects the urban boundary issue is the requirement for the City to "maintain at all times the ability to accommodate residential growth for a minimum of 15 years." Previously, this was 10 years. This constraint has in the past been used as justification for expanding the urban boundary on its own merits, beyond the requirement to supply housing for projected population growth. Even if there is sufficient housing planned to fully accommodate the projected growth over the 25 year period of the plan, there is the additional requirement to ensure that by, for example, year 24, the City has the ability to accommodate 15 years of residential growth. There must always be 15 years in the bank.
In the past the City demonstrated that it met this requirement by maintaining a large inventory of vacant greenfield lands in the outer suburbs. By boosting the requirement to 15 years, the existing greenfield inventory will no longer be sufficient. This could be used by the City and by landowners to argue for expanding the urban boundary even more than they had previously planned. The PPS allows, however, and in fact insists, that the 15 year requirement be met "through residential intensification and redevelopment” and, only if necessary, greenfield lands. Counting on intensification as part of this required minimum supply requires the development of new methods and analysis to quantify intensification in terms of years of supply, something the City has not done before. This paper will put forward a basic approach for doing so, using the City’s own numbers. The key elements of the approach are:
supply refers to the supply of residential units, not residential land
the combination of intensification potential inside and outside of the target areas, combined with existing greenfields, is sufficient to meet the 15 year requirement
spreading intensification across the city opens up greater opportunities to redevelop neighbourhoods that are denser, inclusive, connected and green.
Intensification potential and the supply of residential units
Reflecting past practice, the City of Ottawa has fallen into the habit of framing the PPS requirement as a supply of residential land. For example, in the 2018 Development Report (which is where this accounting is reported upon annually):
“The Provincial Policy Statement requires a minimum of 10 year supply of residential land to be maintained at all times.” (5. Land Demand)
But the PPS makes no reference to land at all, only to “the ability to accommodate residential growth” and it puts the emphasis on intensification and redevelopment to do so. To forestall objections to quantifying intensification as a legitimate means of filling out the 15 year supply, it is useful to examine the practice of other planning authorities subjected to the PPS.
The city of St Catharine’s for example meets its growth requirements, including the additional minimum supply constraint, relying heavily on intensification and redevelopment, with no urban expansion. A few extracts from their current Official Plan (2012):
Today the City is comprised of an Urban Area that encompasses approximately 7060 hectares of land and 70 % of the municipal planning area. (2.3.1, p.5)
The remaining 30 % of the municipal planning area is the Agriculture Area, comprising approximately 2725 hectares of land. (2.3.1, p.5)
This Plan does not support any expansion of the Urban Area, this in recognition of a sustainable planning ethic, and the value and opportunities the Agriculture Area and community have in enhancing the City’s sense of place. (2.3.1, p.6)
The Plan recognizes a finite Urban Area, and within it, a diminishing vacant land supply and a finite occupied land base to accommodate projected population and employment growth. (2.3.3, p.7)
This Plan establishes a minimum intensification target of 95 per cent. (2.3.3, p.8)
This is the reality of many cities with finite urban areas. In the context of climate change, the City of Ottawa can and must adopt a similar approach. There is nothing in the PPS to stop it from doing so.
This means quantifying intensification in terms of years of supply of housing potential. The starting point for this exercise is to have some measure of the total intensification potential of the city. How many additional units can realistically be added in the currently built up area of the city?
There is no current measure of this potential. The City keeps track of intensification achieved against the target rates that are set in the Official Plan but these targets are against projected growth (i.e. share of projected growth achieved through intensification), not intensification potential. These are the current targets as per OPA 150.
“The City’s target for residential intensification, as defined in Policy 1, is the minimum proportion of new residential dwelling units and accommodation based upon building permit issuance by calendar year in the urban area. The target will be: 38% in 2012-2016; 40% in 2017-2021; 42% in 2022-2026; and 44% in 2027-2031. [Amendment #150 May14, 2018]” (2.2.2 Policy 3)
However, when targets for intensification rates were first set in OPA 76, the City released two background reports that attempted to quantify intensification potential. This was done to establish targets that were realistic and achievable (which has by now been amply confirmed with actual intensification achieved vastly outstripping the targets). The final version that informed the Official Plan was the Residential Land Strategy 2006-2031, dated February 2009. It concluded that as of mid-2008, the city had a potential for 122,200 units through intensification in what it called intensification target areas. These are shown in Figure 1.
This is a reasonable starting point for determining intensification potential today. From 2009 to 2018, there were 17,310 intensification units added in the target areas, reducing the intensification potential in these to 104,690.
There is no current measurement of intensification potential outside the target areas. However, over this same period, there was considerable intensification outside the target areas, with 2 additional intensification units built outside the target areas for every three in the target areas. So there is likely a large potential outside the target areas as well.
We will examine three approaches to quantifying intensification potential outside the target area.
In the lead up to OPA76, there was a cursory attempt to quantify intensification potential outside the target areas. However it was done in the following policy context: “The OP’s intent with respect to established residential neighbourhoods outside the target areas is that they will remain stable without necessarily remaining static. This means that intensification will be supported where it is in scale and character with the surroundings, but the General Urban Area is not considered to be the main focus of intensification and is not a target area. The intent is not to transform established neighbourhoods, but to accommodate occasional opportunities that meet OP policies and are contextually integrated with their surroundings.” City of Ottawa, Residential Land Strategy 2006-2031
With this in mind, the following intensification potential was identified.
The intensification target over the short term was 38% (2012-16), and 40% (2017-21), an average of 39% over the whole period. This would translate into 4817 units expected to be produced. The fact that the actuals up to 2018 (11,879) far outstrip the target (by a factor of 2.5) argues that the potential was much larger than estimated at the time. That this was achieved under the policy regime stated above, and in particular “The intent is not to transform established neighbourhoods, but to accommodate occasional opportunities” also belies the situation on the ground. In fact, neighbourhoods are already being transformed, but in an unplanned way that is not beneficial to the local community.
Another approach could be to assume that the potential outside the target areas is proportional to the actuals over the period 2009 to 2018. So if 17,310 intensification units were produced from a potential of 122,000 in the target areas (14% of the potential), what potential is implied outside the target areas by a production of 11,879 over this period? The answer is an initial potential of 84,850 units, for a total potential of 206,850 (122,000 in the target areas, 84,850 outside).
But this calculation of intensification potential outside target areas is also based on performance under the current policy regime, i.e. “The intent is not to transform established neighbourhoods, but to accommodate occasional opportunities”. This regime has been successful in boosting intensification numbers, achieving growth shares well in excess of established targets, but, outside target areas, it has driven up prices, destroyed greenspace, created uncertainty and upset in neighbourhoods and not brought the full benefits that greater density could afford.
So a third approach is to estimate intensification potential outside target areas under a new policy regime, one that seeks to transform neigbourhoods into “15 minute neighbourhoods”, denser, complete, inclusive, green and connected communities. This is a stated strategic direction of the new Official Plan and should therefore be reflected in the projections and estimates used for the land budget calculations.
A good way to understand what is out of the target areas is to examine more closely what is in the target areas, which was shown in Figure 1, repeated here.
The central area is defined as essentially the market area east of the canal and the office and financial district west of the canal. This excluded the Glebe, Old Ottawa South, Old Ottawa East, Centretown, Little Italy, Hintonburg, Lower Town, Sandy Hill. All of these central neighbourhoods, which are subject to ongoing intensification, were considered outside the target area.
The following mixed use centres were included as target areas, mostly associated with planned LRT stations: Baseline-Woodroffe, Tunney’s, Bayview-Preston, Lees, Hurdman, Cyrville, Industrial, Blair, Confederation Heights, Billings Bridge. This excluded many more mixed use centres and other transit oriented development on the now approved extensions of the LRT, and the eventual full deployment of the network through to 2046.
Narrow development strips along these Arterial Mainstreeets were included as target areas: Richmond Road, Carling, St. Laurent, Bank, Hazeldean, Robertson-Richmond, St. Joseph, Merivale-Clyde-Baseline, Montreal Road, Innes, Eagleson. While not ideal as central spines for 15 minute neighbourhoods, these are nonetheless significant intensification zones and many arterials could be added in the far suburbs. For example, not a single arterial in Barrhaven is included, nor is March Road in North Kanata, only St Joseph and Innes in Orleans, and so on.
Narrow development strips along these traditional mainstreets (for some only those segments in the older built up areas) were considered target areas: Stittsville Main, Richmond Road, West Wellington, Scott, Preston, Gladstone, Merivale, Somerset, Bronson, Bank, Elgin, Rideau, Dalhousie, King Edward, Beechwood, Main , Montreal Road, McArthur
These are very much focused on the central part of Ottawa and if intensification is to be pursued across the entire territory of the City, many more roads that currently serve as traditional mainstreets could be added. But the largest omission is the significant number of new “traditional” mainstreets that would need to be developed to support 15 minute neighbourhoods across the city. The 15 minute neighbourhood must organized around a hub, a spine, which provides the destination for services, gatherings, and community. This would mean repurposing and rezoning existing thoroughfares in residential areas as traditional mainstreets, enabling commercial, institutional and employment uses. Such redesignation could easily double the number of traditional mainstreets and the intensification potential that comes with them. (From a purely illustrative perspective, 92 neighbourhood based areas, each covering a 1 km radius circle, can be delineated on the territory of the City of Ottawa, as will be shown in an upcoming paper).
Also excluded from the estimation of the intensification potential were the town centres for the four outer suburban communities: Kanata, Barrhaven, Riverside South and Orleans, each the locus of significant intensification potential.
Setting a New Baseline for Intensification Potential
Taking all of these factors into account, a conservative estimate of the intensification potential outside the target areas could easily be at least equivalent to or surpass the 122,200 potential in the target areas as defined in 2008. For the purpose of the quantification of intensification as a means of meeting the requirement of the PPS 2020 to maintain at all times the ability to provide 15 years of residential development, we will use an intensification potential outside the targets areas of 115,191 units.
The total intensification potential would therefore be 220,671 units, made up of 104,690 units in the target areas as defined in 2008, and 115,191 units outside those target areas. The potential greenfield supply as per the City’s analysis is 58,200 units. It is against this total supply then that the requirement to maintain at all times the ability to provide 15 years of residential development will be measured.
To determine the size and composition of the 15 year supply, we will first accept the relative shares by unit types taken from the City’s projections, as shown in the table below. We also accept the practice of dividing the total urban demand of 181,500 units by single years and multiplying by 15 to arrive at 15 year supply by type of unit as shown below.
Table 4 following shows the depletion of the total supply for the three year period 2018-2020 and for each five year period thereafter through to 2041-2045, showing remaining supply, by unit type, at the end of each period. An intensification rate of 68% is used over the entire period, such that of the total 181,500 units required, 123,393 are supplied through intensification. At this rate of intensification, no expansion of the urban boundary is required to accommodate projected population growth, as demonstrated in the presentation No Urban Expansion Scenario at this link.
The share of intensification to be accommodated in the target areas and outside target areas has been set by allocating to the target areas all of the 98,200 intensification units from the City’s 60% intensification target scenario and the remaining 23,193 units required to avoid expanding the urban boundary outside the target areas. These proportions, by type of unit, were carried through all periods.
On the supply side, the total intensification potential inside the target areas was taken from Table 1 presented earlier in this paper. The shares by unit type was taken from the City’s 60% scenario distribution by unit type. The total potential outside the target areas is based on the analysis presented earlier in this paper. The share by unit types was adjusted to take into account the larger lots sizes and the existing distribution of unit types and character of these mostly residential areas (11.8% single, 3.8% semi, 30.2% row, 54.2% apartment inside target areas vs 35% single, 2.1% semi, 36.5% row, 26.4% apartment outside the target areas).
The analysis shows that there is sufficient supply to satisfy the demand for each unit type in each planning period relying on all three sources: in-target intensification, outside-target intensification and greenfield development. The analysis also shows that, at the end of each period, there remains sufficient supply to meet the 15 year requirement for each unit type as shown above. By the end of the planning period, the greenfield supply will have been totally exhausted but there would remain a supply of 97,377 units, the equivalent of 15 years of residential development, with sufficient numbers for each type of unit. All of it would be supplied through intensification: 6,490 in target areas, the balance outside target areas. Based on these findings, it is therefore possible to maintain the current urban boundary while also meeting the new PPS supply constraint. Acknowledgements: Many thanks to Daniel Buckles for reviewing this paper and his many useful comments.