This update seems to be…

This update seems to be intended towards the infill-type ARU scenario, despite capturing (perhaps unintentionally), all residential lots with proper servicing.

In a situation where developers are either installing ARU "rough-ins", in new communities, I think the Province needs to think about how these changes get interpreted at the draft plan stage.

For instance, with a maximum 4m separation between units; are municipalities going to interpret this as a goal for side yard separation between adjacent houses? 2m on each side would be egregious and not in keeping with your intent to intensify (eats up land). We are already hearing that planning departments are butting heads with fire marshalls who want to see wider side yards for potential ADU access purposes. It's making it hard to provide on-street parking because there are no longer wide enough public boulevards that would accomodate on street parking in between driveways. And we're going to need more on-street parking for the ADUs! It's a catch022. This is just one example of the snowball effect with many competing interests.

And how should new communities factor in ADUs when managing density targets, infrastructure capacity, school capacity, parking, etc...

It seems there may be several unintended consequences coming through the ADU regs as presented, in how they get applied to new community builds, and they should be better understood and addressed so the industry can be engaged on them.