Happy City: In October (in part, to access federal government funding) the City of St. John’s committed to consider a number of changes to development regulations to allow more housing and more units in existing housing across the city, including in Ward 4. In many cases construction or renovation to add rental units that used to require Council’s approval would be able to go ahead without its review.

Council intends to decide on this issue by June 2024, so you will be asked to vote on it should you be elected. No matter the outcome, some Ward 4 residents will be negatively affected and are likely to call you to complain. How will you respond? All of these people are residents of Ward 4, and as Councillor you are committing to uphold their best interests. 

Media coverage of the announcement: https://www.cbc.ca/news/canada/newfoundland-labrador/stjohns-federal-funding-housing-proposal-1.7014249

Full staff report: https://pub-stjohns.escribemeetings.com/filestream.ashx?DocumentId=31114

Myles Russell

My professional background is civil infrastructure and urban planning development. I can  say with full confidence that the current envision regulations are completely unambitious  and will not address short-term or long-term goals of our housing crisis. There are  numerous reasons for this, and I will try my best to be concise but as it stands our  development regulations will not fix our housing crisis. 

There are several aspects of why this will not work. I won’t get into them all, but I will get  into several of the big-ticket items that colleagues and clients deal with daily. ∙ Aggressive snow storage requirements. 

∙ Stormwater management for net-zero runo. 

∙ Class 5 personal vehicle only traic analysis. 

∙ Complex zoning with conflicting structure geometries. 

∙ Parking minimums and maximums too high that still require immense amount of private vehicle storage. 

o No mechanisms for providing funding to active and public transportation directly in  lieu of vehicle space. 

∙ Land use agreements requiring developers to take on risk and burden of the city. 

This is just the tip of the iceberg but I will try to go into at least some detail on every one of  these aspects because without correcting all of this we, again, will not fix our housing  crisis. The city of St. John’s is eating its own foot by preventing development that will  increase revenue. They’re letting perfection be the enemy of progress, in an ever changing financial social and environmental climate.

Let’s start with aggressive snow storage requirements. 

Snow clearing is a serious issue all over the city. We face some of the highest snowfalls in  Canada, and we spent decades building out developments that did not factor snow  storage in. However, as the city began to look at adequate snow storage they did not  properly assess the way we were building to minimize snow clearing generation. The  problem is now that the city requires developers to provide private property to store city  snow, on top of the developer ensuring there’s enough private space to store snow. Instead  of narrowing down roads to decrease snow generation, the city is instead adding large  grass boulevards making the road right of way even wider. That decreases the overall  profitability of any individual parcel of land, directly impacting the ability for any piece of  land to be developed. 

If we want to build more housing we need to get those houses closer together and the way  we do that through the lens of snow storage is to make narrower one way roads so that we  can have the units closer towards the street, and ultimately fit in more units per hectare. 

Next up we’ll talk stormwater management for net-zero runoff 

Ever under why there’s a giant retaining wall just outside of Galway or there is a big field of  nothing near the airport? It is because the city required a gigantic storm-water detention  pond to be built for an extreme one in 100 year rainfall event. Those rainfall events do not  happen once every 100 years, it just represents a statistical chance of occurring. With  climate change we are directly seeing changes in rainfall intensity frequency and duration,  and higher intensity storms happening more frequently. 

From a lens of housing, making roads narrower, and prohibiting excessive parking can  decrease overall surface runoff. Ensuring residents plant and maintain trees on their  property, can help with water absorption. Additionally, any playground or green space should be incorporated into the stormwater dry ponds. These dry ponds essentially never  see water, and in the event we do get hit by a rare storm with a extreme precipitation rates,  people will not be playing in playgrounds and green space. Developers can lose up to 10%  of their land for a structure that only exists to hold water in a rare event. 

The long-term goal of the city to prevent the it from having to expand stormwater piping,  however it is impossible to build for the current supercells that form due to our climate emergency. The rainfall events we are seeing now are well outside of any climate models  predictions dumping hundreds of millimeters of rain per hour even if only for a few  minutes. Even the existing stormwater system inside St. John’s cannot handle that but  these events are so rare that building for them is an economic failure.

Let’s talk now about class 5 personal vehicle only traffic analysis 

This boils down to essentially the city assuming 100% of people move in cars and require  car space for parking require lanes for driving etc. This falls under the purview of something  called traffic management. However modern cities plan for all modes of transportation  which falls under transportation management. This factors in public transportation, walking, active transportation, micromobility, and class 5 personal vehicles. The problem  with the way the city analyzes traffic is that the smallest inconvenience can prevent a  development from occurring. 

From the lens of housing, this means cars get the priority. Road geometry to ensure 50  kilometer an hour speed limits give little flexibility in lot grading. This results in clear cutting  every existing tree and terraforming hundreds of hectares of land to put up housing. 50 KPH  also has requirements for sight lines and curvature that are not conducive of safe streets.  Finally providing on street parking for the rare time that residents want to have guests over,  results in roads that are nearly twice as wide as they need to be and on street parking is  underutilized, the apparent lane width is mostly much wider than reality resulting in higher  speeds and higher collision risk in our city. 

We need to ditch traffic management and switch to transportation management, providing a connected protected active transportation network for cyclists and micro mobility, and a  reliable frequent transit system that people can get to with just 15 minutes of walking. 

Next up is talking about our complex zoning with conflicting structure  geometries. 

When we try to develop housing the first question asked by developers is what zone do we  pick, if it is not already zoned for higher density that makes infill development worthwhile. The city of St. John’s has over 20 zones that are just for residential and apartment units.  Cities with 10 times our population do not have that many zones for residential. Not only  that, but different zones have different geometries for building placement for the same  type of structure. 

A townhouse placed in A1 has half the setback numbers you’d see in R1 zoning. When it  comes to housing and addressing our current housing crisis, we must be able to build  houses that meet the cities housing needs assessment report. That is to say we must build  a large number of bachelor to two-bedroom dwelling units. This is not economically  possible in R1 zoning, which occupies the majority of St. John’s residential housing zones. 

There are setbacks and building lines that are required and minimum lot sizes. With the  cost of road construction, it is not economical to build housing that is more affordable in  our current zoning regulations. Geometries would need to be less restrictive and adaptable  to a developer who wishes to put in smaller townhouse units, or multi-plexes, or smaller  tiny homes.

The revised housing accelerator fund is an ad hoc solution to just amending our  development regulations to build the housing demand that we require to address the  housing crisis. It is more complicated and adds another layer of complexity when a simple  regulation change by combining many zones into one would solve the problem. 

Next up is parking minimums and maximums 

as a relates to housing, there are different parking requirements for the same housing type  depending on the zone. Additionally, as the city moves to begin approving micro units and  tiny homes, some zones parking requirements are 0 while others are one. It is inconsistent and complicated. The city does not factor in that residents of ward four are the highest  transit users in St. John’s and have the second highest walk score in all of the province. 

Parking minimums assume everybody needs a car. Statistically there are 15,000 people in  St. John’s who do not own a vehicle. And another 10,000 who do not drive a vehicle as their  primary method of transportation according to Statistics Canada. This excludes children.  The problem with requiring all of his car parking is that other discussion points in my  response, such as stormwater runoff and snow storage are directly impacted negatively.  They cost the developer precious space, when that could be better filled with more units  green space or literally anything other than a parking lot that sits empty most of the time. 

The calculations for car parking have no basis in the scientific literature. They’re  completely made-up based on copying other municipalities that did the same. If a  developer could show that a residential area has a high walk score, is along frequent  transit, and along core cycling and active transportation space, then there’s no reason that  developer should not be able to choose the parking they want, which in some places may  be 0. We all bear the cost of car ownership even if we do not own a car ourselves and that  is simply unfair and a large barrier to the reduction of overall home costs to address the  housing crisis. 

Very briefly parking maximums should be reduced. Buildings should not be able to have  more space dedicated to parking cars and actual floor space. Reducing parking maximums  and enforcing it would unlock dozens of hectares of St. John’s to be developed into housing  with no need of stormwater management or snow storage because they’re already  hardscape surfaces that have that factored in. If it’s a grandfathered in lot, then it makes  no difference whether it’s a parking lot or houses. 

Talking about housing required to meet arbitrary parking requirements blends into the next  note about developers being able to fund public transit in lieu of parking space. I’ve met  with several developers who want to remove unnecessary parking due to all of the other  ramifications, and they would be willing to pay to fund Metrobus, for that luxury. A direct  dollar value ratio would have to be established but this is done in other regions of Canada that have adequate public transportation. Public transportation would need to be 

expanded to be more frequent and reliable along with the other issues noted, however  providing car free transit oriented development is a proven strategy that generates high  revenue per area. Cars do not make money for the city. People make money for the city. If  we want to address a housing crisis we need to provide some mechanism to allow those  who wish to not own or cannot drive a vehicle to not bear the cost of that infrastructure. 

Finally let’s talk about land use agreements requiring developers to take on  risk and burden of the city 

Developers regularly have to contend with the city of St. John’s pushing for requirements  that go beyond the development regulations and the engineering manuals. This comes in  the form of turning over land from incorrect surveys, upgrading roads that the city owns,  being told to upgrade city storm water and sanitary infrastructure, and more. 

The city wants to make all of its money upfront but the problem is they are putting off on  making long term meaningful revenue on the higher density developments. The majority of  our housing that will meet our current housing crisis will be small units. Those small units  make more sense in denser structures like row houses multiplexes an apartment  structures. Without getting into too much detail I’ve seen time and time again the city citing wishes beyond the regulations and holding developers to them. 

This is an unfair system that directly penalizes higher density developments and infill  developments, which are the developments that make this city the most revenue per  service cost. In fact these types of developments actually decrease the maintenance cost  per service meter by generating more revenue for the same infrastructure. There is a limit  to this, such as we cannot put 10 times the units on a single sewer pipe without rebuilding  the sewer pipe. However there are a lot of tiny requirements that are accustomed to every  single approval that hold back meaningful projects because the city has not yet properly put them into regulations that are easily understandable. 

I am currently working with three different developers on several affordable housing and  general development projects inside the city and it is nothing but pulling teeth to get the  city to agree on even their own regulations. 

I could get into a long list of actual real world issues, but for the sake of client  confidentiality I will not. I will say that every issue I’ve brought up here has been something  that has come up in an actual planning discussion with not just St. Johns, but other local  municipalities as well. These issues are real and directly impact developers’ ability to build  the infrastructure City Council themselves have said they want built; affordable housing  to meet our housing crisis. This is why the current envision regulations will not address  our housing crisis.

We need a council who understands the engineering principles and development  regulations. Without that, council cannot property address issues or direct planning,  engineering, and public works to make relevant meaningful changes to our regulations and  manuals. I see residents’ concerns falling on empty responses. I see nothing but  frustration from developers trying to build what we need. I see no ambition in our plans to  address our growing climate emergency. I see no professional experience to assess these regulations. 

If we do not adapt ourselves quickly, St. John’s will find itself continuing to fall behind our  peer cities at a rapid rate. We already have some of the worst weather in the world yet  people from all over the world love to move here. They enjoy the culture and experience,  yet we do not provide the ability for them to have mobility freedom, true accessibility, or  even adequate housing.