August 17, 2012 Dear Mayor Mandel and City Councillors, Re: August 27 Public Hearing, Item 5.

9 Text Amendments to Accommodate Seniors Living and other Supportive Housing The Edmonton Federation of Community Leagues encourages City Council to send the Community Supportive Provisions back to Administration for revisions and further considerations: 1. We strongly recommend that the application of the Supportive Community Provisions be discretionary so that the neighbours and Community Leagues are notified of the proposed supportive housing and there is an opportunity for consultation. There is no doubt that proposed supportive housing , particularly large developments, will have both a positive and negative impact on the neighbourhood, thus it is essential the neighbourhood be consulted in order to maximize the positive impacts and minimize negative impacts. To do otherwise would be contrary to the Citys Public Involvement Policy C513 which states the Citys commitment to citizen engagement : A key element of representative democracy is that people have a right to be involved in decisions that affect them. Under the present bylaws and procedures, Community Leagues and neighbours are informed and consulted when higher densities and parking reductions are allowed by the City. But this democratic right to information and consultation would be denied under the proposed text amendments. The Supportive Community Provisions would allow a 25% increase in density (without a public hearing) and would allow less than half the usual parking requirements (without having to do a parking study), all without informing or consulting the neighbours who would be impacted. This is not acceptable. We are not asking you to scrap the Provisions. All we are asking for is the right of citizens impacted by the Supportive Community Provisions to be informed and consulted. Furthermore, reduced opportunities for neighbours to be informed of proposed supportive housing could not come at a worse time from EFCLs perspective. This fall we are hoping to embark on a collaborative research and demonstration project to enhance neighbourly relations with supportive housing all kinds of supportive housing. We would like to see increased opportunities for dialogue and interactions between Community Leagues and housing projects, rather than fewer opportunities. Neighbourly relations could be impeded by not making the Provisions discretionary.

2. We recommend that the Supportive Community Provisions be considered when the text amendments for Congregate Living are considered. Both projects are interdependent. The Congregate Living project is attempting to monitor and prevent further concentration of supportive living accommodations. However, the draft text amendments state that housing using the Supportive Community Provisions would be exempt. It is difficult to monitor and control supportive housing if most supportive housing is exempt. Although the Supportive Community Provisions were created with Seniors Housing in mind, these Provisions can apply to any kind of supportive housing. This dilemma needs to be resolved before adopting the Supportive Community Provisions. 3. Research evidence suggests that the proposed parking requirements will not meet the parking needs of supportive housing for seniors. Bunt & Associates examined the actual parking demand for 6 supportive living seniors residences in Edmonton. The peak demand for blended parking (residents, staff & visitors) ranged from .79 stalls/unit to .29 stalls/unit, with the average being .55 stalls/unit. Based on this peak demand, we know that the proposed parking provisions of .4 per sleeping unit and .5 per dwelling unit will frequently not accommodate regular peak hour demand, thus on-street parking will still be needed for visitors at certain times of the day. The Bunt report also points out that the Institute of Transportation Engineers Seniors Facility Parking Survey concludes that weekday peak parking demand is 1.0 stalls/dwelling unit for Continuing Care Retirement Communities. Given that these age in place facilities are the types of facilities that the Province is wanting to fund, it is fair to assume that the peak parking demand for the new facilities will be close to 1.0 stall/unit. This is approximately double the parking requirements in the proposed Provision. Please recognize that the dramatically reduced parking requirements being proposed will have an impact on the neighbourhood. Again, we want to emphasize the importance of making the Supportive Community Provisions discretionary and ensuring community consultation. We are confident that you, as elected officials, will understand the importance of consultation and democracy.

Regards,

David Dodge, President