Re: Carleton Heights and…

Re: Carleton Heights and Area Residents Association (CHARA) call for new evidence to ensure the health and safety of residents with intensification and the New Official Plan

Our association supports intensification as a key tool for the City to respond to new challenges and opportunities. However, we believe adjustments are required to ensure the City safeguards the health and safety of our residents given the levels of intensification proposed under the New Official Plan.

The Carleton Heights and Area Residents Association (CHARA) is a volunteer-run community association. We work with our members to build and maintain a safe and healthy community. Our neighbourhoods are bordered to the north by the Experimental Farm at Baseline Road, east by the Rideau Canal and Rideau River, south by Prince of Wales Drive, and west by Fisher Avenue.

Local context

Predominantly developed in the 1950s, our community has rural arterial roads, narrow streets (e.g., 25-28ft wide), no areas for permanent on-street parking and no sidewalks. Many of the bus routes that used to serve the community no longer run. Among the bus routes that remain, buses run less frequently and unreliably.
Water, sewers, stormwater and collection systems are ageing, having remained largely the same from the original development. Large streams buried during development flow underneath residents’ homes, and standing water is commonplace. With a high-water table in the community, poorly maintained drainage ditches, culverts, and catch basins barely manage peak water flows for low-density development during spring thaw or heavy rainfall events.

The absence of coherent city planning already endangers our community.

Recent and relatively minimal infill has already begun to reveal the weaknesses of our limited services and outdated, poorly maintained community infrastructure.

• Transit service levels to our area have decreased significantly in our recent history, and remaining higher frequency routes only function in conjunction with an operable Light Rail Transit (LRT) system. Since there are no funded transit projects forecasted for completion within the next ten years (e.g., Baseline Rapid Transit Corridor), there is no indication that the City intends to reverse this decline or meet the needs of an intensified community.

• Over many years, transit service levels to our area have significantly decreased and have impacted all residents—particularly low-income and younger community members. Public transportation needs to align with the aspirations of the N.O.P. as an essential pillar for its successful implementation. Housing affordability, reduced reliance on private vehicles, 15-minute neighbourhoods that are walkable and accessible depend on reliable public transit.

• Recent infill has prioritized the economic benefit to developers over the health and safety of our residents and overburdened our community’s ageing and fragile infrastructure. With no clear plans to address pre- existing infrastructure deficiencies, the N.O.P. lacks the comprehensive evidence to support its assumptions for reasonable levels of intensification in our community.

• Instead, this N.O.P. supports haphazard development that exacerbates existing deficiencies, undermines affordability and assumes that the best time to upgrade water, sewer, stormwater systems, roads and transit services is when they fail. Observed recent changes in precipitation trends and cycles coupled with climate model projections of future precipitation require more of our infrastructure and City of Ottawa planners. This approach should not be acceptable to Committee Members, and it certainly is not sufficient for the health and safety of our residents.

We cannot support intensification and the major variances of our Secondary Plans that will continue to imperil the health and safety of our residents, decrease the affordability and accessibility of our neighbourhoods and put further stress on our area’s infrastructure.

The City of Ottawa has not met their obligations for safe and sustainable intensification as outlined in the Provincial Policy Statement (2020) and the Planning Act to proceed with this New Official Plan1 2 without the accountability and transparency of independent third-party comprehensive engineering reports, environmental assessments and reliable, valid data needed for evidence-based planning decisions and investments to ensure residents’ health and safety.

We include our previous submissions to City of Ottawa staff3 and highlight our top priority concerns below.

1. No transit projects and no vehicle spaces create health and safety hazards for residents

The City of Ottawa confirms there is no timeline or funding for a transit project in our area. Members of CHARA learned this from a recent application by Novatech (2020) that states: “Staff do not have a certain timeline for this project. There is no funding commitment in place for this project.” With current performance,4 there is a good chance the Rapid Transit Corridor will not arrive during the 25-year duration of this plan.

With modest infill development, residents’ vehicles permanently and illegally take up space on our narrow streets. (e.g., 25-28 feet wide). Without designated pathways, moving and parked vehicles, pedestrians and cyclists compete for space on our streets. With traffic congestion, vehicles get backed up and block larger streets designated as ‘corridors’. Near accidents have occurred. In winter, neighbourhoods have become unserviceable.

By-law officers cannot resolve the breadth of these problems (e.g., on illegal parking: 240 calls, 60 days, only 30 tickets levied). The City has already demonstrated that the existing enforcement agency is unable to manage and deter current illegal parking issues.

2. Lack of adequate public transit reduces the affordability and accessibility of our community

Transit service levels have declined significantly in our area over the last 20 years. Our community used to be served by many more transit routes, many of which have been cancelled – including the 3, 13, 113, and 175. Bus routes 88 and 118 run less frequently and are often cancelled or run late during peak hours. The 111 route often fails to stop during rush hour. Public transit is less frequent, and service has become more unreliable – with increased wait times and full buses bypassing stops – both E-W and N-S over the past decade.5

Students and low-income families, including those served by the Debra Dynes Family House, rely on public transit to get to work. They need reliable buses to drop their kids at daycare, get to work on time, so they can complete shift work in the day and at night, often upholding jobs with more than one employer at more than one location to maintain a living wage. Typical commutes can be 1-1.5 hours twice a day, even longer when overfilled buses fail to stop.

People spend hours every day and dangerously at night on public transit trying to get to and from work. In our transportation-starved area, residents who have no choice but to rely on public transportation to try and meet their basic needs are the most affected - those who can afford second and third vehicles increasingly resort to paid parking or illegal parking on City streets.

With these transit deficiencies, the N.O.P. decreases the affordability of living in our community. Without adequate transit in our community, the N.O.P. plans for growth will continue to exclude residents and increase the material harm to the most vulnerable.

3. Unchecked intensification replaces our Secondary Plan and destabilizes our infrastructure

In our current Secondary Plan, infrastructure capacity is “based on the present (1980s) zoning.” The City is ignoring this capacity constraint with infill that is destabilizing the infrastructure in our community.6 City of Ottawa data and third-party reports provide conflicting assessments of the quality, capacity, and even flow directions of water, sewer and stormwater services serving our neighbourhoods.7 8 9 10 11 12 13 The N.O.P. overlooks historical knowledge and competing reports to introduce intensification that puts our safety, our properties, our homes and their long-term affordability at risk.

Infrastructure upgrades for water (stormwater, wastewater and drinking water) are needed to support intensification – a problem mainly affecting older (ca 1945-50) veterans’ subdivisions built and not upgraded to modern urban standards to safely support the City’s plan. Water management systems are frail and fail in the face of ongoing redevelopment – a problem identified in the 1970s, regularly occurring in Carleton Heights. Failures cause damage to public and private property and unplanned, expensive repairs.

The Provincial Policy Statement requires that the City of Ottawa ensures the infrastructure and public service facilities are available, appropriate for, and efficiently used for expansion to occur. Otherwise, the City needs to avoid the unjustified, uneconomical, expanded use of our infrastructure. The City will inevitably face liabilities for damaged homes and properties as well as unplanned, unbudgeted public works projects.

4. Rivers and climate change demand improved water management, not privatization

Huge ravines collect stormwater, and other contaminants, that flow out of our community into the Rideau Canal and Rideau River. Without municipal storm sewers, the delayed release of stormwater into yards and ditches can cause a rise in the already high local water table. High runoff scenarios could contribute to catastrophic basement failures if the water table rises above the level of basement floors. Basements have flooded. Water mains have broken. With the spring thaw and the increased frequency of heavy rainfall events with the effects of climate change, water has flooded our streets beyond, creating health and safety hazards for residents and their homes.

Already sump-pumps and backup generators to keep them functioning in case of a power failure are necessary to keep the homes in our neighbourhoods dry. The N.O.P. introduces privatization of onsite stormwater management which saddles homeowners with new liabilities when stormwater systems fail. Soon, the proliferation of private systems instead of public storm sewers and stormwater treatment will have a material, negative impact on housing affordability.

As per Provincial Policy, the N.O.P. for stormwater management needs to integrate with sewage and water services planning to ensure that systems are optimized, feasible and financially viable over the long term; to minimize erosion and changes in water balance, and to prepare for the impacts of climate change.14 15

Assumptions are not consistent, risking haphazard growth

Without greater transparency and accountability, we cannot support the N.O.P. and its intensification without ensuring the health and safety of our residents and our neighbourhoods.

We ask that you uphold the intentions and obligations of the Provincial Policy Statement and the Planning Act.

Our hope is that we can work together to ensure the City of Ottawa presents an N.O.P. that advances the shared interests of our communities and those of the City more broadly.

Respectfully,

The CHARA Board of Directors

References
1 Approved by the Lieutenant Governor in Council, Order in Council No. 229/2020 (2014). Provincial Policy Statement, 2020. [online] www.ontario.ca. Available at: https://files.ontario.ca/mmah-provincial-policy-statement-2020-accessib… .
2 Ontario Legislature and Registrar of Regulations, (2021). Planning Act. [online] Available at: https://www.ontario.ca/laws/statute/90p13#BK27 . Consolidation period from June 3, 2021 to the e-Laws currency date. Last amendment: 2021, c.25, Sched. 24.
3 Letters to City of Ottawa staff March 12, 2021 and April 12, 2021. Pedestrian Pathways Submission to Councilor Brockington, River Ward, May 26, 2021. Walking Tour Field Guide handed out to City of Ottawa staff on July 28, 2021 and emailed to City of Ottawa planners July 29, 2021.
4 Woods, M. (2021). City of Ottawa escalates legal pressure on LRT contractor. [online] ottawa.ctvnews.ca. Available at: https://ottawa.ctvnews.ca/city-of- ottawa-escalates-legal-prreessure-on-lrt-contractor-1.5612222 .
5 OC Transpo Corporation, (2021). Schedule adherence reports. [online] Available at: https://www.octranspo.com/en/about-us/stats/schedule-adherence/
6 City of Ottawa emails (2021), Planning Application, Ottawa Planning Area, Plan of District 16. (n.d.). Part C - The Appendix, [online] Chapter XI, pp.11–13. 7 Inadequate storm sewer infrastructure and historic risks of sheet (flash) flooding, Ottawa Citizen, 2014, and Ottawa Journal, September 1973, https://ottawastart.com/dark-clouds-hang-over-the-auto-sky-a-history-of…
8 Stantec, (2013), Combined Sewage Storage Environmental Study Report. [City of Ottawa]. Available at: http://ottwatch.ca/meetings/file/47423/File_COMBINED_SEWAGE_STORAGE_TUN… SEWAGE_STORAGE_TUNNEL_ENVIRONMENTAL_ASSESSMENT_NOTICE_OF_COMPLETION_OTTAWA_RIVER_ACTION_PROJECT_NO_3_Meeting_Environment_Committee_Date_2013_01_15_09_30_00 .
9 Ottawa Riverkeeper (2017). Brewery Creek and Beyond: The Problem with Combined Sewer Overflows in Ottawa & Gatineau. Available at: https://ottawariverkeeper.ca/publications-2/ .
10 City of Ottawa (2021). Water and Wastewater Networks Interactive Map. Available at: https://ottawa.ca/en/planning-development-and- construction/developing-property/engineering-services#water-and-wastewater-networks-interactive-map
11 Rideau Valley Conservation Authority (2012). Stewardship and Watershed Protection Reports. Available at: https://www.rvca.ca/watershed-conditions 12 Greater Ottawa Homebuilders’ Association (2020). Presentation to National Capital Heavy Construction Association. Available at: https://nchca.ca/wp- content/uploads/2020/02/Greater-Ottawa-Home-Builders-Assoc.pdf
13 Wastewater Services (2015) Regulatory Compliance Report, Wastewater and Stormwater Systems, 2015 Annual Summary Report. Available at:
http://ottwatch.ca/meetings/file/364303 .
14 Patterson, T. (2021), Rainfall historical review 1890-2019 present. [Patterson Lab: Carleton Climate & Environmental Research Group, 2021) 15 Chung, E., (2021), Canadians are unknowingly buying homes in climate change danger zones, report finds. [online] cbc.news.ca Available at: https://www.cbc.ca/news/science/climate-risks-1.6196450