September 24, 2018

Re: Developing Our Urban Villages

Mayor Iveson and City Councillors:

The Downtown Edmonton Community League (DECL) and Oliver Community League (OCL) are
concerned about the growing trends with development proposals in our communities, many of which
are direct control provisions (DC2), that have increasingly allowed excessive densities on development
sites.

Both DECL and OCL are in favour of dense, urban-format development, and always welcome more
people, businesses, and vibrancy in our communities. We do not feel our concern here is of the “not in
my backyard”. Rather, our concern pertains to bigger-picture downtown city building: both
neighbourhoods have a plethora of vacant and underdeveloped land, and in a real estate market with
finite demand for high-density residential product, enabling select development sites to absorb too
much of this demand will result in a glut of vacant land into the future.

While both community leagues are supportive of new development and new residents in our
communities, below are some concerns outlined about how new rezoning applications are being
evaluated, and as a consequence, supported.

● The real estate market is regulated. City Council decides what gets built, and where, through
zoning bylaws. While one can argue that development is a decision made only in the private
sphere, City Council ultimately places restrictions and requirements on all land development.

● Approval of excessively high density buildings can influence the land market. When a new
DC2 for an excessively dense development is approved, it causes land values to go up for
comparable sites as the market adjusts to new development possibilities. Thus the increased
land values may cause developers to have to propose much denser projects in order to make
financial sense, and detracts from the kinds of projects that may be desired by planning or
policy.

● The market for new residential in Edmonton is finite. While some multifamily demand may
be shifting to the core, there nonetheless exists a finite amount. Therefore, planning in
Downtown and Oliver should consider Direct Control Provisions in the context of market
demand for housing against the supply of vacant land in the area. In this context and what
actually gets built, there may be winners and losers based on what new development rights City
Council approves and for whom.

● Approving denser and taller projects means less land will be developed. Proposals and land
with approvals for excessively dense projects will ensure other land is not developed in the
 timely fashion.

As a consequence of the above reasons, OCL and DECL strongly urge City Council to look at the
market factors that relate to the approval of new DC2 provision in the core. An urban community
with a few very tall residential towers situated within blocks of vacant land is not desirable from a
community, policy, or private investment standpoint.

Once new property rights are afforded, they set a new baseline against which future developments are
viewed by the private sector. This is not a desirable situation from a community, policy, or private
investment standpoint. For example, recent decisions by City Council to approve the 45 storey Emerald
Tower DC2 and the 80 storey Alldritt Tower DC2 set new precedents. A number of upcoming DC2
rezoning bylaw proposals are based on these newly set precedents, as land values have risen to reflect
this new regulatory environment. Is there a place for tall, dense buildings in our core? Absolutely. But
what do overly tall, high density buildings (beyond what is currently zoned) do to the market as a
whole when residential demand is finite? What effect does this have on the incentive to redevelop
underutilized land or brownfield sites across the city? How does approval of excessively high density
development limit or remove desire to invest in the “missing middle” in the core?

Both OCL and DECL recognize recent high density developments that positively contribute to our
neighbourhoods. The Hendrix project in Oliver, with an FAR of 6.5, is located adjacent to an LRT
station and includes 13 townhouse units as the podium. The Icon and Fox Towers on 104 Street were
developed under the zoning updated in 2010 which allows a generous FAR of 8.0 to 10.0 and height of
115m. These are all examples of projects that are very dense under existing zoning regulations or
policies.

Will Edmonton's urban core be populated by large, excessively dense projects next to underutilized and
vacant land or surface parking lots for the foreseeable future? At the current rate of growth and market
adsorption, only so many buildings will be constructed. Our city has hundreds of years of land
available in Edmonton’s core, in brownfield sites, and various redevelopment areas that may go
unrealized if the zoning regulations area not harmonious with market realities. We strongly urge City
Council to thoroughly review its decision process on these matters.

Sincerely,

Chris Buyze Lisa Brown

President, President,
Downtown Edmonton Community League (DECL) Oliver Community League (OCL)
president@decl.org president@olivercommunity.com

cc: Linda Cochrane, City Manager, City of Edmonton

Peter Ohm, Branch Manager, City Planning, Sustainable Development, City of Edmonton
David Holdsworth, Senior Planner Downtown Plan Implementation, Sustainable Development, City of Edmonton