Ottawa City Council approved…

Ottawa City Council approved a new Official Plan on October 27th, 2021. It is now in the
office of the Minister for review and final approval.

This comment, from an alliance of 21 well-established civil society organizations in Ottawa, seeks to
summarize some of the concerns regarding this Official Plan raised city-wide by resident
associations and community groups. We want to ensure that your office hears these perspectives
and solutions, and not only views from the City and some segments of the development industry.
The strategic directions described in the Council-approved Official Plan have our strong support.
They focus on intensification, sustainable transportation, 15-minute neighbourhoods, climate and
health resiliency, and economic sustainability, and do an admirable job of defining the desired
destination. There remains, however, a fundamental disconnect between the policy ends and
the policy means included in the Official Plan. The most serious of these are as follows:

1. Expansion of the Urban Boundary
The Official Plan approved by Council adds 1,281 ha to Ottawa’s urban area to accommodate
projected residential growth. The City calls this a “balanced scenario,” with 51% of new urban
dwellings provided through intensification and 49% built on existing vacant or newly added
greenfields.
The City’s own modelling shows that the number and type of dwelling units needed to meet the
projected residential growth can also be achieved without expanding the urban boundary. A staff
report calls this the “no expansion scenario”, and notes that it can achieve the goal while
maintaining at all times the ability to accommodate residential growth for a minimum of 15 years,
as required by the Provincial Policy Statement (PPS). In the City’s own words, a “no urban
expansion scenario represents the greatest extent to which growth management can contribute to
achieving policy directions where most growth occurs through intensification, growth uses existing
infrastructure most efficiently, and GHG emissions reductions are maximized.”
The Hemson 2021 update commissioned by the City confirms as well that intensification is far more
economical from a public financing perspective than greenfield development (infill generates
municipal revenues of $606/person/year while greenfield development costs the municipality
$465/person/year, plus unknown ecological and climate costs). And yet, despite these hard
numbers, the no urban expansion scenario was rejected by Council and significant urban expansion
approved. It places 49% of the projected population growth on greenfield lands where public costs
are highest and the majority of intensification downtown and in towers where private costs are
highest. This is nonsensical, and inconsistent with the policy objectives of the Official Plan, the PPS
and the City’s own analysis.
In the context of climate change and fiscal responsibility, there should be no urban expansion if
growth can be accommodated otherwise. We therefore call on the Minister to uphold the
Provincial interest by reversing Council’s decision to expand the urban boundary.

2. Key Policy Gaps

2.1 Consultation with Indigenous Leaders
The City of Ottawa is located on the unceded traditional territory of the Algonquin Anishinaabe. It is
clear, however, that the City of Ottawa has not yet meaningfully consulted with all the Algonquin
communities impacted by the Official Plan, as required for land-use planning matters by the
Province. For example, the Kitigan Zibi Anishinabeg Nation and the Algonquin Anishinabeg Nation
Tribal Council have denounced the Official Plan consultation process as woefully inadequate. We
find this gap concerning, especially as the Mayor and some Councillors have cited reconciliation
with Indigenous Peoples/Nations as the primary rationale for a key political decision in the urban
expansion plan (the Tewin land allocation, see below).
We call on the Minister to uphold guidance in the Provincial Policy Statement governing landuse
planning and Indigenous interests, including consultation, the coordination of planning
with Indigenous communities and policy implementation in ways consistent with their rights.

2.2 Housing Affordability
The Ottawa housing market, and hence the housing affordability discussion, is best understood by
distinguishing between market affordability and deep affordability.
Market affordability:
Middle-class residents and new market entrants are increasingly priced out of market affordability
due to a variety of inter-related factors, only some of which can be addressed through the Official
Plan. These include population growth, inflation rising faster than wages, rising construction sector
prices, limited housing supply in transit-served areas, regulatory uncertainty, higher property taxes
and social trends such as aging in place and pandemic responses affecting the long-term demand
for urban housing.
Solutions to market affordability can be found within the current urban boundary. An optimal
response would be to plan for a better distribution of density and innovative housing forms
(especially low-rise development) in all built up areas of the city, whether it be through
intensification or greenfield development. These have more scope for addressing market
affordability than concentrating density in a few areas and on a few housing forms such as massive
towers that are expensive to build and unsuitable for many demographics.
Deep affordability:
Low-income residents are increasingly priced out of the affordable housing market and sometimes
pushed out of deeply affordable housing. This creates housing stress and homelessness. The loss of
low cost private rentals and the slow growth of deeply affordable, social, cooperative and gearedto-
income housing, adds to the urgency.
The Official Plan lays out a definition of housing that recognizes that everyone deserves to have
housing that costs no more than 30% of their income, and commits to identifying and acquiring
additional lands for social housing. It also makes significant commitments to equity and racial
justice, and plans to track equity across urban and rural neighbourhoods.
We strongly support these steps. However, additional policies are needed in the Official Plan to put
effective anti-displacement measures in place to control the demolition of affordable private rental
housing due to gentrification. Support for non-profit housing providers is also needed, as is greater
attention to neighbourhoods where City amenities (daycare, public transit, tree canopy, community
food assets, etc.) are significantly under-resourced. More generally, the Official Plan should raise
the profile of the Council-declared housing and homelessness emergency by making deep
affordability a strategic direction aligned with the National Housing Strategy Act (2019).

2.3 Livability
The Official Plan describes a compelling vision of “15-minute neighbourhoods,” where people can
live, work and play. However, it lacks the policy means for existing and new communities to
become progressively more complete, with the parks, trees, walkability, bikeability, businesses and
community services/assets that make for livability. With the new Official Plan, tall towers and road
corridors will dominate inside the NCC Greenbelt and inner urban neighbourhoods will lose the
trees that make them livable. On new greenfields, and in suburbs and villages outside of the NCC
Greenbelt, the amenities needed to make neighbourhoods walkable and safe for cycling will remain
scarce, and jobs nearby scarcer still. Conflict between developers and neighbourhoods, and car
dependency, will remain the norm.
To avoid this outcome, the Official Plan should plan, as noted above, for a better distribution of
density and innovative housing forms (low-rise development) in all built up areas, inside and
outside of the NCC Greenbelt. This can only be achieved through context-sensitive planning and
design of complete, functioning communities and streets with active modes of transportation. New
technologies and simple, collaborative processes can help to visualize and test ways to ensure
neighbourhood plans are robust, achievable and enrich the characteristics valued by residents and
local organizations. We ask the Minister to direct the City of Ottawa to plan for complete
communities at the neighbourhood level, supported by modelling as an analytical tool for
engaging residents and other stakeholders.

Among the liveability characteristics valued by communities, access to tree canopy and access to
greenspace were the top issues – by far – raised by public delegations over the course of plan
development. This was true for neighbourhoods in tree deserts as well as in currently treed
neighbourhoods. The City responded positively by enhancing targets for access to tree canopy and
greenspace and acknowledging that eliminating tree deserts is a fundamental equity measure.
These policies stop short, however. Without neighbourhood level targets and clear, enforced rules,
tree deserts will remain and currently treed neighbourhoods will continue to decline. We ask the
Minister to call on the City of Ottawa to establish neighbourhood level targets for access to tree
canopy and greenspace, and a no-net-loss rule for communities.
In addition to fostering gentle density in existing communities, all greenfield development (new
communities) should be developed as complete communities and complete streets from the
beginning, rather than retrofitted for density and active transportation afterwards. We ask that the
Minister call on the City of Ottawa to bring density targets for all greenfield developments in
line with the targets and strategies for fostering complete communities in the currently built
up areas of the city.

2.4 Food
Where will our food come from in the future? The Official Plan does not adequately address this
question. While protections for farmland are written-in as required under Provincial law, the
protections are routinely ignored by Council in favor of other priorities. For example, Council
recently voted to remove 106 ha of prime farmland in Riverside South from the protected
Agriculture Resource Area, and allocate it to the urban expansion area for residential
development. This land, close to transit and surrounded by existing housing and services, could
have provided opportunities for dozens of market garden enterprises and helped to meet
unfulfilled demand for locally-produced food. We call on the Minister to uphold the provincial
interest regarding agricultural land by reversing Council’s decision on the allocation of this
prime agricultural land to residential development.
The Provincial Policy Statement contains no minimum parcel size for agricultural lands, calling
instead for lots “appropriate to the area.” By contrast, the Official Plan establishes a minimum 36 ha
parcel size for severances of agricultural land, even though the current average farm parcel in the
City of Ottawa (23 ha) is much smaller. This provision creates an unnecessary bias towards larger
farm parcels, making it more difficult for farmers to access farmland scaled to their own market
niche and production plans. We ask the Minister to call on the City of Ottawa to establish a
minimum severance of 8 ha. This would be consistent with the PPS guidance and enable the
development of a more diversified local farming sector.
Despite public calls for a food lens at the level of the Official Plan, enabling policies have been
pushed into the Greenspace and Urban Forest Masterplan. This lower level policy is relevant, but
cannot resolve cross-cutting mandates such as the Parks and Recreation Masterplan where
significant decisions are also being made regarding the core services of public spaces. Scope for
food security programs within the urban, suburban, and rural areas of the city are at risk of being
People’s Official Plan, November 26, 2021 5
shuffled between City departments and falling through the cracks. To avoid this problem, we ask
the Minister to direct the City of Ottawa to coordinate lower level plans through a “joined-up”
approach to food security across all departments.

2.5 Climate
A lesson we can take from the current global pandemic is that in a crisis bold action is needed. This
applies even more to the climate emergency, which has become ever more urgent and impactful.
The Official Plan should be Ottawa’s climate emergency plan, but it is not. It perpetuates an attitude
of delay and climate denial, leaving Ottawa exposed and vulnerable to the flooding, heat waves and
wilder weather already costing Canadian lives and billions of dollars.
The decision to expand the urban boundary and gaps outlined above in policies regarding
housing affordability, urban density, liveability and food security all undermine efforts to
mitigate greenhouse gas emissions and adapt. To these we add three other climate policy areas
that should be addressed more effectively by the Official Plan: energy, transportation and resilience.
Much more could be done to ensure that the Official Plan aligns with PPS 1.8.1 f) on energy
conservation and efficiency and the role of vegetation and green infrastructure in mitigation. A new
High Performance Development Standard referenced in the Official Plan is triggered by site plan
control but allows many developments to be exempt, including all low-rise residential and mixed
use developments. As a result, more than half of the new builds planned through intensification will
not be required to apply the High Performance Development Standard. In addition, there are no
High Performance Development Standards for existing buildings, even though the City estimates
that over 325,000 buildings in Ottawa will be renovated or expanded as part of intensification and a
proposed energy transition. We ask the Minister to direct the City of Ottawa to provide specific
guidance in the Official Plan on the energy efficiency and green standards it expects for
developments exempt from the High Performance Development Standards.
On energy supply, the Official Plan fails to align with PPS 1.6.11 mandating the development of
electricity generation facilities, transmission and distribution systems, district energy, and
renewable energy systems and alternative energy systems, to accommodate current and projected
needs. Without this guidance, Ottawa will not be able to do its part to transition to a low carbon
economy. We ask that the Minister remind the City of Ottawa of its obligation to provide
opportunities for the use of energy sources consistent with a climate-safe future.
Transportation accounted for 44 percent of Ottawa’s greenhouse gas emissions in 2019. The Official
Plan recognizes the need for a modal shift from cars to public transit and active transportation as
part of a climate response. However, it lacks the commitment to drive this shift, firmly and quickly,
to transit and active transportation. The Official Plan should have policy guidance on the rapid
development of safe and pleasant connections between transit stations, pedestrian routes and
cycling infrastructure in neighbourhoods. It should also do more to enhance public transit
connections across jurisdictional boundaries (with Gatineau and with rural communities). Policies
in the Official Plan are also needed to facilitate the movement of people and goods on e-bikes and
cargo bikes for use by businesses and individuals. Demand studies show that the majority of trips
currently undertaken by Ottawa residents are under 5 kilometres, an accessible distance for
assisted cycling. We ask the Minister to direct the City of Ottawa to establish policies in the
Official Plan that support system connectivity in line with PPS 1.6.7.3, restrict new road
construction and give greater priority to transit and active transportation.
Finally, the Official Plan does an admirable job of referencing resilience among the strategic
directions of the Official Plan. However, the detailed background risk and resilience studies needed
to inform the policy means were not completed prior to plan approval. As a result, the Official Plan
does not provide the policy guidance needed to ensure appropriate adaptation and resiliency
measures are implemented in subsequent Master Plans, by-laws and zoning regulations. Guidance
is needed to protect public assets (infrastructure, transportation) and human health and property
from future climate impacts. We ask the Minister to direct the City of Ottawa to integrate climate
risk and vulnerability analyses into City plans, by-laws, zoning and capital projects, and make
climate risk data and maps available to the public as soon as they are completed. This supports
transparency and people and businesses that want to make their own adaptation plans.

2.6 Financial Implications and Risks
The public has not yet been provided with detailed estimates of how much the Official Plan will cost
or how these costs will be distributed. We can be sure of two things, however:
1. The proposed urban boundary expansion will increase the tax burden on established
communities and permanently lock-in higher emissions of greenhouse gases from housing
and transportation, and;
2. The capital and operating costs of an affordable, high-service, accessible public transit
system are high.
Mapping out the financial burden of decisions embodied in the Official Plan and expectations
regarding how these costs will be shared is a key function of responsible municipal leadership. We
ask the Minister to uphold the provincial interest in fiscal transparency by calling on the City to
undertake a comparative financial analysis of Official Plan policies encompassing growth,
climate action and public transit.
The Tewin financial risk
One unmitigated financial risk stands out above all others: Ottawa’s rushed and huge urban
expansion land-deal. The Tewin development was proposed by the Mayor in the name of
reconciliation and with claims that it would benefit the Algonquin people. Too many questions
regarding this decision remain, however, including:
• The poor quality and incompleteness of consultation with Indigenous Peoples/Nations;
• Serious technical constraints on the land in question (which scored poorly on Councilagreed
rating criteria), and;
• The cost and potential liability for the City of a Private Public Partnership that may be in the
billions, rivalling Ottawa’s investment in Light Rail Transit (LRT).
People’s Official Plan, November 26, 2021 7
City staff originally asked Council to take the time needed to answer these questions, before
allocating part of the urban expansion quota to the Tewin proposal. We agree with the staff
recommendation, and call on the Minister to uphold the Provincial Policy Statement regarding
consultations with Indigenous Peoples/Nations and provincial guidelines on good planning
and public financing by reversing Council’s decision on the Tewin land allocation. We also ask
that next steps on a Memorandum of Understanding between the City and Tewin, drafted in
November, not be delegated to staff. Rather, the MOU should come to Council once more
information is available, supported by independent reviews of the financial risks to the City. More
than any other single component of the Official Plan, this decision could be the most expensive
legacy of this Council.

2.7 Monitoring Success
The Official Plan on its own can’t solve all the big problems and emergencies Ottawa faces. All levels
of government and all sectors of society are needed to do that. The Official Plan does, however,
provide an opportunity to set goals, track progress on these goals in real time and make timely
course corrections as needed.
What goals are monitored, and how, matters if the Official Plan is to provide the public with a
comprehensive view of our city. It is also important to recognize that policies interact in
unpredictable and consequential ways. We support, for example, the commitment outlined in the
Official Plan to monitor intensification targets and plans for urban expansion in light of actual
progress in achieving the greenhouse gas emission targets laid out in the City’s Climate Change
Master Plan. Other interactions may also be important to building public support for the Official
Plan, such as the impact of intensification on neighbourhood liveability. Consequently, we call on
the Minister to direct the City to support community engagement in the development of metrics
related to each of the strategic directions of the Official Plan.

3. Enabling Provincial Policies
In addition to concerns about Ottawa’s Official Plan raised above, we call on the Minister to
undertake those changes to the Planning Act and other provincial policies needed to support the
strategic directions of the 2020 Provincial Policy Statement and Ottawa’s Official Plan. They
include:

Housing
• Modify Section 16 of the Planning Act to anticipate and plan for deeply affordable housing in
all neighbourhoods and new construction projects, not only near transit hubs, and permit
specific support for social and geared-to-income housing.
Transportation
• Authorize municipalities to implement transportation pricing such as congestion charges or
private parking levies so that the full cost of road maintenance can be distributed equitably;
• Implement a toll HOV lane on the 417 and use the revenues to fund transit projects;
• Require electric vehicle charging features in all new buildings.
• Authorize municipalities to offer GHG mitigation rebates to permit the purchase of e-bikes
and cargo bikes for use by businesses and individuals.
Climate
• Allow municipalities to require zero-carbon heating sources for new developments;
• Allow municipalities to require buildings to connect to a district energy system if one is
available;
• Enable virtual net metering for renewable energy generation;
• Implement a net zero building code;
• Require energy labeling of all buildings (new and existing);
• Remove emissions from the electrical grid to ensure electrification is carbon free (in Ottawa
this could be achieved by increasing the interconnection with the Province of Quebec);
• Recognize the critical role of green infrastructure in mitigating the impacts of climate
change and improving human health.

The Peoples Official Plan

Alliance to End Homelessness Ottawa
Bike Ottawa
Citizen Climate Council (C3)
City for All Women Initiative (CAWI)
Climate Reality Hubs
Community Associations for Environmental Sustainability (CAFES)
The Council on Aging of Ottawa / Le Conseil sur le vieillissement d’Ottawa
Ecology Ottawa
Energy Mix Productions
Federation of Citizen’s Associations (FCA)
For Our Kids Ottawa/Gatineau
Greenspace Alliance for Canada’s Capital
Just Food
MD Moms for Healthy Recovery
Ottawa Renewable Energy Coop and CoEnergy Coop
Ottawa Street Markets
Ottawa Transit Riders
Walkable Ottawa
Waste Watch Ottawa