WBCA Feedback on the City of Ottawa Official Plan

March 2, 2021

Please click here to view the full draft of City of Ottawa New Official Plan

WBCA General Comments: 

1. The previous OP had a City-wide planning frame, the concept of “Transects” allows for a more specific planning frame for land use – a vast improvement which is appreciated. 

1. It is not acceptable that the City continues to develop from the core outwards. It is an equity issue on regeneration, not regeneration itself that is the issue. On this point, residents in the Inner Urban Transect are very concerned about intensification and density. Over-intensification in an older neighbourhood is having dramatic impacts on residents, significantly altering lifestyle. Leaving the suburbs largely untouched by regeneration efforts needed to accommodate Ottawa’s growing population is an inequitable proposition and is not acceptable.

1. The OP appears to not include references to lessons learned from the previous plan and what was accomplished under that plan. This new OP should be correcting mistakes of the past and building on successes – and the City should be explicit about that. Ongoing monitoring and review will help ensure community input is being taken into account and the OP is meeting its stated objectives. 

1. While the OP has been approved, before the zoning by-laws are established to meet the OP policies, can a moratorium be placed on all new development proposals?

1. While it is understood that the OP is intended to describe principles supported by Secondary Plans, many of the terms in the OP are vague, undefined, and unclear, making it difficult to ascertain how they will be interpreted by City planners, residents and developers. The concern here is that some of the vague concepts could be vulnerable to exploitation by developers and lead to confusion on the part of drafters and community members.  

1. The OP includes an important concept – that of 15-minute neighbourhoods.  This is an important development and while it is great to aim for amenities in neighbourhoods, query whether such amenities are accessible to all community members. Are they affordable? In some cases, it may require capital contributions towards enhancing amenities or parklands, for instance. 

Key here is to involve citizens in the transformation of their neighbourhoods. It should be done by citizens who live, work, play, walk within the 15-minute neighbourhood. Allowing zoning, or more density in and of itself, or done by planning staff will result in a cookie-cutter 15-minute neighbourhoods, it will not meet the changes and adaptations needed for every community to become a 15-minute neighbourhood.

Also, could we acknowledge in the OP that neighbourhoods that have undergone intense regeneration, that no more regeneration will occur until community infrastructure and publicly accessible places have been identified and improved to accommodate the increase in population density?

1. With respect to regeneration and the Built Form Overlays, it is unclear how the Overlays were identified (what criteria were used), whether they will be entrenched in the zoning by-law and critically, and what input impacted residents will have. 

1. Finally, we would like to say the New OP is beautifully and comprehensively done. The maps are a wonderful addition, well done and made easier to understand.

Notwithstanding the above, we would like to add the following specific comments to the draft Plan for your consideration:

Specific Comments:

p. 2, Table of Contents

• Throughout the OP are references to other City documents – master plans, guidelines, etc.  I would suggest that there be an Annex listing each of these documents, where they are referenced in the Plan (section and page), and with a hotlink to where they can be found on the City’s web site.  

p 19, Section 2.2.1 Regeneration, Policy (3)

• If you are able to say that the strategy is to achieve a 60% regeneration target by 2046, you should also be able to give a proportional percentage target for public amenities and services within 15-minute neighbourhoods, as it is stressed in the OP the importance of public amenities and services

p. 22, Section 2.2.2 Economic Development, Policy (1) Enhance Ottawa’s high quality of life to attract a skilled workforce and businesses

• Policy Intent (1) should be more encompassing. Are we going to enhance the high quality of life to attract only what is currently stated rather than a diversity of employment?

pp. 23-24, Section 2.2.2 Economic Development, Policy (6) Support growth of important economic generators through Special District Policies.

• Why is the idea of “growth” associated with several of these Special Districts, including Parliament, Lansdowne and the Ottawa River Islands?  Where is the growth beyond what’s already there or approved?

p. 28, Section 2.2.3 Energy and Climate Change, Policy (6) Build resilience to future flood risks: Avoiding building in flood plains and mitigating risks in areas vulnerable to flooding under future climate conditions.

• The language here should be “prohibiting” as opposed to “avoiding” building in flood plains
• Using low impact development storm water management features to manage rain where it falls should include our streets and roads, and should be explicitly stated. 

(Comment: The impacts of intensification are dramatic in the Selby Plains area in Westboro Beach, resulting in events such as flooding of residences that for decades never flooded before. Increased density has impacted residents negatively.)

p. 29, Section 2.2.3 Energy and Climate Change, Policy (8) Enable local food production 

• Add a 4th bullet: Supporting nut and fruit bearing trees and shrubs along pathways to support organizations that provide food to those living with food insecurity

p. 30, Section 2.2.4 Healthy and Inclusive Communities, “What we want to achieve” box

• If you are going to spell out “design for all ages including children and older adults” in (2) – it should either not be spelled out, or it should include “persons living with a range of difficulties”. It is spelled out under Policy Intent on the following page, but it should be included in the highlights because of its importance.

p. 31, Section 2.2.4 Healthy and Inclusive Communities, Policy (1), 3rd bullet

• It should include all modes of getting to school, no doubt there will be futuristic modes yet to be invented, but for today “roll” (e.g., scooters, skateboards, one-wheel, etc.) should be included, to say “… to walk, roll, cycle or take transit to school.”

(We would like to suggest that “roll” be included in all instances where “walk, cycle, or take transit” is mentioned. Roll is on the increase and this preferred mode of getting around should be acknowledge and safety of the users and non-users and conflicts should be considered.)

p. 33, Section 2.2.4, Policy (3) Promote health through sustainability

• Add a bullet after the 2nd bullet to say: “recognizing the value of the ecological sustainability of our natural waterways.”
• To add somewhere: “that all shoreline along and around natural waterways to remain as public land and be accessible to the public” 
• To add somewhere: the importance of accessible public toilets 24/7 throughout the year. (Perhaps it could be included as an additional bullet under Policy Intent under 2.2.5 Gender Equity? Or under built environment?)

p. 36, Section 2.2.5 Gender Equity, Policy (1) Meet the housing needs of women

• Subtitle should read: Meeting the housing needs of women with children, and of older frail women
• Add an additional paragraph: Housing that supports gender equity includes the older frail women, where exterior landscaping and interior design will accommodate mobility assisted devices and address other frailty issues.

p. 36, Section 2.2.5, Policy (2) Improve mobility options for women

• Subtitle should read: Improve mobility options and mobility access for women
• Add an additional paragraph to address the mobility access for women: public transit frequency, on time and fare cost to be improved; and to address the safety and security of the stations to achieve this policy intent.

p. 37, Section 2.2.5, Policy (3) Improve access to amenities, 2^nd bullet from top

• To read: “… range of income levels and a range of unit sizes and design that will accommodate large families to the singe person with mobility issues.”

p. 37, Section 2.2.5, Policy (3), 5^th bullet from top

• To read: “… there are opportunities for recreation and leisure activities;”

p. 37, Section 2.2.5, Policy (3), add an additional bullet under 7^th bullet from top

• To say: “Walkability is further improved with accessible public toilets 24/7 throughout the year in particular for pregnant women, women with children, and older women.”

p. 39, Section 2.2.6 Culture, Policy (3) Promote the arts as an important element of placemaking

• Add at the end of the 1st paragraph: “… that nurtures cultural development and addresses accessibility issues”

(explanation: there are spaces in the public realm for cultural expression but to rent space to stage a play or to rent space for a music gig, the cost of rental is prohibitive for many artists whose income level are barely liveable)

• Would it be possible to include: to facilitate installation with Federal partners on public art on federal-owned land?

p. 40, Section 2.2.6 Culture, Policy (4) Strengthen the economic impact of the creative and cultural industries 

• Add at the end of the 1st paragraph: “… and reduce barriers to enable arts, music and culture events, and for the performers”.

(explanation: same reasoning as for Policy Intent (3) above. You give space, but rental policy (rental cost and provision of liability insurance) is a huge barrier for many of our local performers)

p. 46, Section 3.2 Support Regeneration: “The target amount of dwelling growth to occur through regeneration is 51 per cent… “

• How does that 51% relate to the 47% mentioned on page 44?

p. 48, Section 3.2, Policy (4)

• Residents with accessibility issues have raised significant concerns with the 15-minute neighbourhood concept and whether “15 minutes” is even possible for them. Are amenities and accessibility considerations given prominence in this concept? If not, then the policy goals will have a disproportionate negative impact on those residents.
• The nature of 15-minute neighbourhoods is unclear. By looking at the Schedules, if 15-minute neighbourhoods would have to always depend on services and amenities available in Hubs and Corridors, then there would be many neighbourhoods that would never make it. That such a link is necessary is of course invalid. Other policies in the Plan (see comment “h” for page 170 below) make that clear.

p. 49, Section 3.2 Support Regeneration, Policy (8) 

• This is excellent, but perhaps misses major opportunities to align the Plan with the Council-approved Energy Evolution strategy. 
• Add, insert into (d): “… infrastructure to support the electrification and other alternative fuel sources of private and public vehicles.”

(Explanation: Other alternative fuel sources for vehicles could include hydrogen in the future when the extraction of hydrogen particles can be made less vigorous, and who knows other forms may be discovered. Don’t limit ourselves only to electricity.)

p. 49, Policy (10) The residential growth allocation by dwelling sizes and designation as shown on Schedules B1 through B7 in 15-minute neighbourhoods are established in Table 2. 

• Does this allocation apply only to 15-minute neighbourhoods, not to others?  

p. 50, Table 3 – Minimum Residential Density and Large Dwelling Requirements

• Concern: 80 units per hectare for the Inner Urban (even for the Downtown Core) is too much. Could it be decreased to say 70 units per hectare or less, and add the difference to the Outer Urban transect. This will help make regeneration a more equitable proposition. 
• Note that there is very little space left for parks and recreational amenity space to accommodate such a high increase in density, which belies the OP vision of making our City liveable.
• The minimum Large Dwelling requirements in this Table is also concerning as there is no such requirement for the suburbs. Why not?
• How will this be enforced? Is it expected that development applications will be denied until the quota for large dwellings is filled? What levers will City Planners use to implement this policy? 

p. 50, Policy (15)

• NO amendment to the Zoning By-law or to the OP or Secondary Plan. If amendments are allowed, we will return to the current state of uncertainty for the residents and distrust (and can we add, dislike) of developers whose guiding principles appear to be financial greed with total disregard of the neighbourhood characteristics and liveability.
• Other than in Annex 2B (for the Central Area), where are these height categories mapped?

p. 51, Policy (18)

• This policy is unclear. Would suggest this be properly defined. 

p. 51, Section 3.3 Design new communities to be 15-minute neighbourhoods

• The policies in this section refer to a “Future Neighbourhood Overlay on Schedule B” and “new neighbourhoods as shown on Schedules B5 through B7” but none of that can be found in these Schedules.

p. 56, Section 3.5 Meet Employment Needs, Policy (12), i. i

• Major office developments in neighbourhoods within 800m walking distance from a station should be considered carefully from the pedestrian security angle. Generally, offices are vacant after business hours (also on weekends and holidays) in the evening, giving a feeling of insecurity for pedestrians returning home in the evening from the station.

p. 58, Section 4 City Wide Policies

• To include in the 2^nd paragraph: “… new roadways will be built in a manner that will preserve and protect natural features and natural waterways from large waterways to the smallest trickle. Waterways will no longer be covered or diverted to accommodate new roadways.”

p. 66, Section 4.1.4 Support the shift towards sustainable modes of transportation 

• Policy (2) is an example of a policy that leaves much discretion to the planners/Council that no certainty is created.
• Policy (4) fails to provide any direction to the drafters of the Zoning By-law — not definitional (“larger-scale”) nor functional (what is the basis for the requirements?)

p. 83, Section 4.4.1 Identify park priorities within Ottawa’s growth areas, Policy (10)

• To add: If a change in ownership or use is considered, the final product/outcome must remain visible and accessible to the public.

p. 91, 

• Consider adding Section 4.5.5 – Conserve remains of natural history and cultural history, or consider adding to Section 4.5.4 to read: Conserve sites of archaeological value and conserve remains of our natural and cultural history

(Explanation: An example are the Stromatolites. They are found along the Ottawa River downstream from Westboro Beach, but some are found inland and they can also be seen along the tunnel wall of natural stone east of Dominion Station. New York has built a park featuring Stromatolites, with only half the amount that we have here.

There is evidence of First Inhabitants settlements, as well as activities and remains from the Lumber years, that archaeological digs are justified and relics and remains found be preserved and exhibited. Lumber and sawmills have a prominent role in the history of Ottawa.)

p. 93, Table 5 – Design Priority Areas

Policy (4), The City will establish criteria for the review of projects by the UDRP, which may include different thresholds for review based on the Design Priority Area’s tier of priority outlined in Table 5 taking into account the hierarchy in Table 4, and the area’s economic role within the region.

• Unclear how does Table 4 (Road Classification and Function) on page 59 relate to this Table 5.

p. 96 – Definition of Living Streets

Refers to the seasonal, or temporary reallocation of space within our streets from primarily serving vehicles, to providing a range of amenities that serve people in a manner that supports placemaking and healthy 15-minute neighbourhoods while informing permanent street design.

• What does “informing permanent street design” mean? What is its practical implication?

p. 96, Section 4.6.3, between Policy 8 and 9

• Suggest an addition along the lines of: minor enhancements that are temporary in nature and does not involve permanent structures can be implemented through the local BIA, local elected representatives and the local community association or recognized group without having to request for permits. At the local street level children can be allowed to play street hockey or set up a pop-up lemonade stand without applying for a permit through City Hall.

p. 97, Section 4.6.4, Policy (1), between #f and #g

• Add: “managing residents waste by incorporating sufficient space for recycling, composting and landfill operations”

p. 97, Policy (4)

• Delete “building is preferred” in the second sentence.

(Explanation: Buffering the outdoor children’s play area fronting the street with a building is NOT preferred because it reduces visibility. Play areas should be made as visible as possible. More eyes on the children will increase safety.) 

p. 98, Section 4.6.5, Policy (1) b

• Add: “… and to preserve the sky view and sunlight”

p. 103, Section 4.6.6, Policy (11) c

• Add: “… and that the park space is visible, accessible and welcoming to the public realm”

p. 105, Section 4.7.1, Policy (1)

• It is mentioned under another Section in our feedback, but it is worthwhile repeating: Natural waterways in proposed development sites must be respected. Diversion, coverup or burying of the waterway shall be avoided.

p. 112, Section 4.8.1 … Natural Heritage System 

3) The City recognizes the following natural heritage features, as defined in Ottawa’s Environmental Impact Study Guidelines:

a)  Significant wetlands;

b)  Habitat for endangered and threatened species;

c)  Significant woodlands;

d)  Significant valley lands

e)  Significant wildlife habitat;

f)  Areas of Natural and Scientific Interest;

g)  Urban Natural Features;

h)  Natural Environment Areas;

i)  Natural linkage features and corridors;

j)  Groundwater features;

k)   Surface water features, including fish habitat;

l)  Landform features; and

m) Natural features or natural areas having significant cultural, economic, or historical value to the Algonquin Anishinabe Host Nation, as may be identified in mapping through dialogue and collaboration between the Host Nation and the City.

6)  Development or site alteration shall take a no net loss approach with respect to wetlands and forest cover in the rural area. Mechanisms for achieving no net loss include land use planning, development processes, acquisition and conservation of land, and support for voluntary, private land conservation and stewardship.

7) The City shall identify municipal nature reserves in the Tree Protection by-law as those lands that require special restrictions on access and use to protect their natural values or ecosystems services.

• The list of what comprises Ottawa’s Natural Heritage System in Policy (3) is more comprehensive than the list in the current Plan’s section 2.4.2 Policy (1), and uses far fewer words. A real improvement.  
• Fully support Policy (6).
• Excellent intent expressed in Policy (7).

p. 113, Section 4.8.2 Provide residents with equitable access to an urban forest canopy

…

2) The City shall pursue an urban forest canopy cover target of 40%.

…

6) When considering impacts on the urban forest and trees, approvals and Tree Permits shall not be denied for development that conforms to Zoning By-law. Council or the Committee of Adjustment may object to an amendment to the Zoning By-law which does not otherwise conform to the Official Plan, or a variance to either By-law, as the case may be, if the proposed development impacts the retention of tree(s) that are protected by the City’s Tree Protection By-law, or if it fails to consider the planting of new tree(s). Approvals granted by Council or Committee of Adjustment may include conditions to support tree protection, removal, and replanting. The City and the Committee of Adjustment may object to an application where it deems the loss of a tree(s) avoidable. This policy shall also apply to a Community Planning Permit approved through delegated authority or Council. 

• This should be broken down to the neighbourhood level – where it matters. While a 40% minimum is supported by science, even as stated Policy 2) is ambiguous: What is the land base for the 40% goal?  It should be the urban area minus the Greenbelt. 
• Requests to remove trees should be evaluated in light of the relative deficiency in cover for the area. Similarly, requirements to plant new trees should be more stringent as the existing tree canopy in the area is more deficient.  In theory, the area considered could be the actual or prospective 15-minute neighbourhood.  For practical reasons, the area considered will be determined by data availability.  There is much information about canopy cover at the Ward level and even lower.  
• While Policy 6) offers authority to avoid tree loss when a zoning amendment is sought, the first sentence is too weak (assuming the Zoning By-law itself does not offer protection for trees). Why would a developer whose project conforms to current zoning be exempt from contributing to the retention of tree cover?
• Each of the authorities established in Policy 6) are “mays”. These should all be “shalls.”

p. 114, Section 4.8.2, Policy 6

• The size of new trees must be qualified so that it will not be made easier to circumvent. In the middle of the paragraph add: “… or if it fails to consider the planting of new tree(s) of similar girth and age to those removed.”

p. 116, Section 4.9.3, to add after Policy 2

• The setback (as provided in Policy 1) from all surface water features (rivers, bays, lakes and other forms) shall remain in the public domain and made accessible to the public to explore and walk along and around the shoreline of the water feature. Temporary exceptions will be made to areas undergoing shoreline and aquatic regeneration.

p. 116, Policy 4) Where development or site alteration is proposed in adjacent to headwater drainage features, the proposal and supporting studies must address the following:

a) Evaluation and description of the project site, sensitivity of the headwater drainage features and sampling methods;

b) Assessment and classification of hydrological function, riparian conditions, fish and fish habitat and terrestrial habitat; and

c) Management recommendations regarding the need to protect, conserve, mitigate, maintain recharge or maintain/replicate terrestrial linkages of the headwater drainage features.

5) No site alteration or development is permitted within the minimum setback, except as otherwise provided for in this section.  Exceptions to this policy are: …

• Policy 4) is very weak, requiring only that supporting studies “address” what follows. After the studies have evaluated, assessed and made recommendations, what will the City do? This policy should state that the proposed development or site alteration will be prohibited if specified standards are not met.
• The exceptions specified in Policy 5) appear to be reasonable.

p. 121-2, Section 4.10.2, Policy 2) Schools should generally co-locate compatible land-uses on-site for a more efficient use of land and promotion of healthy, walkable 15-minute neighbourhoods. The Zoning By-law shall allow school sites to have dual zoning for a variety of complementary land-uses, including: residential; licensed child care facilities; parks; small scale commercial and other community serving uses.

• Why are “residential” and “small scale commercial” among the list of complementary uses of school grounds?

p. 127, Table 7 – Minimum and Maximum Height Overview Based on Official Plan Policy

• Under Inner Urban Transect, it is confusing. Looking at Mainstreet Corridors the table states maximum of nine storeys. Yet the definition of high-rise is given as between 10 and 30 storeys.
• The OP Policy Reference for Inner Urban Minor Corridors should be 5.2.3 (3), not 5.2.4 (3). There is no policy for Inner Urban Neighbourhoods outside 15-Minute Neighbourhoods; the stated 5.2.3 (1) policy refers to Hubs.  (See also comment for page 170.)
• The OP Policy References for Outer Urban and Suburban Neighbourhoods (5.3.4.(1) and 5.4.5.(1) respectively) refer to within 15-Minute Neighbourhoods only.

p. 130-1, Section 5.1.3 Locate the tallest buildings and greatest densities in the Downtown Core

• This policy is confusing and difficult to follow.

p. 141, Section 5.3.3, Policy (2) Parking in Outer Urban Hubs shall be managed as follows:

a) Minimum parking requirements may be reduced or eliminated; and …

• What criteria or factors will be considered when allowing reduction or elimination of parking requirements?

p. 148, Section 5.5 Greenbelt and Rural Transect Areas

• Take Greenbelt out of the equation. The Greenbelt was established and is more applicable today than ever before, to ensure environmental and health protection and NOT economic enhancement. It should also include a commitment to stop cutting or widening roads through the Greenbelt.

p. 152, Section 5.6.1.1

• To include, but there may be another location where it may be more appropriate: NO amendments to the Zoning By-law. Zoning By-laws should be written to allow achievement of the objective(s) and therefore no amendment(s) will be required.

It is the ability to request amendments that leads to uncertainty and pits residents against residents against developers. With NO amendments permitted both developers and residents know what can be allowed and expected.

p. 153, Section 5.6.1.2  

• The words in the titles of these two Overlays are extremely subjective and vague. Has community input been sought?  Some communities are carved up into Evolving, Transforming and just plain Neighbourhoods, and/or have part of their community lopped off as a Special District.
• Policy 2) of Section 5.6.1.2 uses the dreaded word “generally” and the soft “should.”  In contrast, in Policies 2) and 3) of Section 5.6.1.3, the verb is “shall.”  This difference is what led me leads one to conclude that the Transforming Overlay is really the engine of regeneration in this Plan.

p. 158, Section 5.6.3.1 Protect the Natural Heritage System and Natural Heritage Features

• In Policy (1) a): no development or site alteration should be allowed in core natural areas for residential or commercial purposes.
• In Policy (1) b) appears to place ecological and recreational connectivity on equal footing, and it should not be. To insert after the semicolon: “…; and, not compromise the potential for long-term enhancement and restoration primarily of ecological connectivity of the area. Recreational connectivity can be considered if the ecological sustainability is not compromised.

p. 159, Policy 5.6.4 Future Neighbourhood Overlay

• There are no Future Neighbourhood Overlays on the Schedules B. What do “Category 1” and “Category 2” lands refer to?

p. 163, Section 6.1.1, Policy (3) Development within hubs

• Requiring commercial and service uses on the ground level of a building close to transit stations should be of the nature, or of offices willing to stay open to a later hour, which will help dispel the emptiness of the street, and of any feelings of insecurity for pedestrians walking home alone at night.

p. 166 – Table 9

• The terms of the Density Target are not defined in the table. Policy 2) suggests it’s a hybrid of people and jobs per gross hectare.

p. 170, Section 6.3.1

• Re Policy (4): Small-scale non-residential uses are permitted throughout the Neighbourhood designation, provided that it is also the principal residence of the proprietor of the business or service. This caveat should be included to prevent the “empty building” syndrome after business hours and on weekends and holidays.
• Policies (4) b) and c) are laudable and show that 15-minute neighbourhoods will be allowed to be realized without having to depend on Hubs or Corridors.
• This is the third place in the OP where building heights in Neighbourhoods are set out, after Table 7 (p. 127) and the policies in some of the Transects. Within this section, Policy (1) states that the maximum building height is low-rise, i.e., 4 storeys; Policy (2) says something else.  The result is a confusing OP and should be clarified.
• Re Policy (2), approvals under the Planning Act do not “plan” for anything, let alone “generally.”.
• Policy (2) a) uses the term “major streets”, a term used only here and on page 173. It is not defined.
• In Table 7 (p. 127), in Inner Urban Neighbourhoods “zoning will permit at least three storeys but no more than four storeys”.  As noted earlier, there are no policies for Neighbourhoods outside 15-Minute Neighbourhoods in this Transect. In Policy (2) b) here (Section 6.3.1), it’s “generally, three full storeys”. How will this be applied by zoning by-law drafters?
• In Table 7 (p.127), in Outer Urban and Suburban Neighbourhoods, “zoning will permit at least three storeys but no more than four storeys “, contradicting Policy (2) c) here (Section 6.3.1)

p. 171, Section 6.3.1, Policy (6)

• To add at the end of the sentence: “… does not create an adverse risk to public health, and does not compromise snow removal and recycling and composting efforts.”

p. 172, Section 6.3.2, Policy (4)

• To add as mentioned above: “… does not contribute to the empty building syndrome after business hours, weekends and holidays.”

p. 173

• As noted, “major streets”, an undefined term, is used in Policy (2) b) and c).

p. 173, Section 6.3.3, Policy (2) f

• Goods for sale or displayed outside an establishment helps animate the street. It would be preferable to say: “Goods for sale or display are not placed where it will inhibit the flow of pedestrian traffic, strollers and assistive mobility devices.” (That is, it is allowed to be placed in the municipal right of way if it does not inhibit the flow.)

p. 174, Section 6.4

• Industrial areas tend to be a concrete jungle, could we encourage planting of trees and greenery that would not impede the flow of internal traffic or cause conflict with the operations, perhaps on the building rooftops, or at the perimeter of the property to help reduce the negative effects of climate change.

p. 180, Section 6.6 Special Districts

• Although under federal ownership and jurisdiction, the Ottawa River and shoreline play an important part and contribute to our City’s culture and liveability. The entire length that is within the City’s boundaries should be considered a Special District.

p. 195, Section 7.1 

• Schedule C9 does not show Parks, Open Spaces nor Conservation Areas. In the Schedules B, the only non built-up areas shown are “Greenspaces” (if 3.2 ha or larger, according to Policy 2) of this section).

p. 198, Policy (4) The Conservation Area designation identifies provincial parks, Conservation Authority properties, and other lands which are identified or protected through separate legislation, regulation, or convention for conservation, sport, recreation, leisure and cultural facilities, but does not include the National Capital Greenbelt. Examples include Fitzroy Provincial Park, the Baxter Conservation Area, and the Beckett Creek Migratory Bird Sanctuary.

• As just noted, Conservation Areas are not shown as such on Schedule C9.  However, Fitzroy Provincial Park is on the list of Core Natural Areas, as is Beckett’s Creek Headwaters.

p. 201, Section 8.4, Policy (4) d

• Perhaps add text along the lines of… “to work together with the Federal Government towards reorienting the Connaught Rifle Range and Primary Training Centre away from the shoreline or relocating to a different location altogether, in order to return the area to its natural state, ecological sustainability and biodiversity and to return the area to the public realm to allow for enjoyment of the shoreline”.

p. 215-6, Section 10.1.1 Natural Hazards: Flooding Hazards and Erosion Hazards

• This section could be simplified a lot if the Policy were simply that development and site alteration in flood plains is prohibited except for what is listed in Policy (6).

p. 216, Section 10.1.1, Policy (6)

• To add: “new buildings and new dwellings built in erosion-flood-prone areas, after the approval of the new OP, the City will not offer financial compensation should it suffer damages from flooding or erosion.”

p. 217, Section 10.1.2 Two-Zone Flood Plain Areas and Areas of Reduced Flood Risk

• Two-Zone Flood Plain Areas are not shown on any Schedule, nor are One-Zone Flood Plains.

p. 218, Section 10.1.3 Areas Vulnerable to Flooding Under Climate Change

• This section introduces new concepts (Climate Change Flood Vulnerable Area and climate change scenario flood limit) that are wholly within the purview of the Conservation Authorities. It is their mandate to identify flood plain risk with specified probabilities, including taking into account climate change scenarios. The City should make sure that the CAs have sufficient resources to perform this task but not do their work.

p. 226, Section 10.3 Build resiliency to the impacts of extreme heat 

• Shade structure although defined elsewhere, should also be defined here, and to add along the lines of: “… that materials used to build the shade structure, does not contribute to the urban heat island effect.”

p. 230, Section 11.1, Policy (2) a

• Process and lower costs for regeneration objectives does not trump over liveability, environment and health, and climate change issues. Deleting (a) would be recommended.

p. 231-2, Section 11.2 Create the framework to for a Community Planning Permit System

• This is positive. Adoption of a Community Planning Permit System may bring greater coherence to the way planning proceeds in Ottawa. 
• However, suggest including an explicit commitment to public consultation.
• Policy (5) foresees a pilot project somewhere in the Rural Transect.  Why not consider a prospective development in the urban area as a candidate for a CPP process?

p. 234, Section 11.4, Policy (1) a

• For notices sent should include to residents that live within a predetermined radius of the proposed development. Please note, it is an onerous task for community associations to inform immediate residents on a proposed development. Please remember that community associations are primarily volunteers and rely on fundraising to maintain their operations, like printing of notices.