122 BASELINE ROAD WEST, LONDON · 520 Wellington Street, Unit #7 | London ON N6A 3R2 | ph: 519-930 -3512 | . PLANNING JUSTIFICATION REPORT . 122 BASELINE ROAD WEST, LONDON

520 Wellington Street, Unit #7 | London ON N6A 3R2 | ph: 519-930-3512 | www.hdclondon.ca

PLANNING JUSTIFICATION REPORT

122 BASELINE ROAD WEST, LONDON

April 2020

Submitted in support of requested planning permissions and the requirements of a complete Official Plan and Zoning By-Law Amendment application.

Prepared By:

http://www.hdclondon.ca/


520 Wellington Street, Unit #7 | London ON N6A 3R2 | ph: 519-930-3512 | www.hdclondon.ca

TABLE OF CONTENTS

1. INTRODUCTION ............................................................................................................................. 1

2. DEVELOPMENT GOALS, OBJECTIVES AND THE PROPOSED SITE DEVELOPMENT CONCEPT ......... 1 2.1. HDC Development Goals ................................................................................................ 1 2.2. Development Objectives ................................................................................................ 2 2.3. Proposed Site Development Concept ............................................................................ 2

3. SUBJECT LANDS ............................................................................................................................. 4

4. SURROUNDING NEIGHBOURHOOD .............................................................................................. 7

5. CURRENT POLICY AND REGULATORY FRAMEWORK .................................................................... 8 5.1. The City of London 1989 Official Plan ............................................................................ 8 5.2. The Z.-1 Zoning By-law ................................................................................................... 9 5.3. The London Plan .......................................................................................................... 10

6. PROPOSED OFFICIAL PLAN AND ZONING BY-LAW AMENDMENTS ............................................ 11

7. PLANNING POLICY ANALYSIS ...................................................................................................... 12 7.1. The Provincial Policy Statement (PPS), 2020 ............................................................... 12 7.2. The City of London 1989 Official Plan .......................................................................... 15

7.2.1. Planning Impact Analysis ............................................................................... 16 7.2.2. Neighbourhood Character Statement ........................................................... 22 7.2.3. Compatibility ................................................................................................. 30

7.3. The Z.-1 Zoning By-law ................................................................................................. 32 7.4. Conclusions related to the PPS, Official Plan and Zoning By-law ................................ 34 7.5. The London Plan .......................................................................................................... 34 7.6. Conclusions related to the London Plan ...................................................................... 41

APPENDIX A: Proposed Site Development Concept ........................................................................... 42

APPENDIX B - Figure 1: UTRCA Limits ................................................................................................. 43

APPENDIX B - Figure 2: Preliminary Grading and Servicing Plan ........................................................ 43



122 BASELINE ROAD WEST PLANNING JUSTIFICATION REPORT

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1. Introduction The recently approved 2019 - 2024 Housing Stability Action Plan for the City of London (City) identifies the “Creation of more housing stock” as one of Council’s four Strategic Areas of Focus to respond to London’s homelessness crisis. An action item therein is the development of publicly-owned and available lands for affordable housing. As Council’s delegated Service Manager for the development of affordable housing, Housing Development Corporation, London (HDC) plays a critical role in the development of publicly-owned lands for affordable housing (including surplus school sites acquired by HDC and surplus municipal lands transferred to the HDC by the City).

HDC has prepared the following Planning Justification Report (PJR) in support of a requested Official Plan and Zoning By-law Amendment (OPA/ZBA) application for lands known municipally as 122 Baseline Road West (hereinafter referred to as the “subject lands” and/or the “Site”). The subject lands were previously identified as surplus to municipal needs and transferred to HDC for purposes of affordable housing development. The purpose and intent of the requested amendments is twofold:

• the requested amendments establish planning permissions to provide for the future development of a low-rise residential apartment building containing a mix of bedroom configurations to be offered at “affordable rent” and “market rent”, as defined by the Canada Mortgage and Housing Corporation (CMHC) and/or HDC, to meet funding program requirements; and,

• the requested amendments, once approved by Council, will inform a future HDC Request for Proposal (RFP) process seeking a Prime Consultant to deliver the development and, ultimately, the “the look” of the built form, including but not limited to, the spatial organization of supportive site elements such as parking, outdoor amenity space and landscaping. It being noted that, the RFP process will be led by HDC as the property owner and the City’s delegated Service Manager. Required within the terms and conditions of the RFP, the successful Prime Consultant will be responsible for future consultations with the City and preparation of Site Plan Approval and Building Permit drawings that are to be consistent with the City’s approved zoning and urban design principles and/or performance standards established for the Site.

The purpose of the PJR is to identify the planning merits of the requested amendments and to demonstrate that the requested amendments are consistent with, and serve to implement, the policy framework of the Provincial Policy Statement 2020, the City’s 1989 Official Plan and the London Plan. The requested amendments, including a holding zone requiring a future site plan review process, will advance a regulatory framework that would provide for a form of development that is sensitive to, compatible with, is a good fit within, and adds value to, the existing surrounding neighbourhood.

The PJR identifies the City policy and/or regulation and section number relevant to the planning permissions required to activate the proposed site development concept. HDC’s development response (identified by bolded and italicized text) follows each.

2. Development Goals, Objectives and the Proposed Site Development Concept

2.1. HDC Development Goals: Development goals for the subject lands have been informed by London’s affordability challenges, the HDC Strategy, the City’s Housing Stability Action Plan, the policies of the City’s 1989 Official Plan and the Key Directions and Strategies of the London Plan.


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Specifically, the proposal seeks to: • Advance a development model for housing affordability that is financially sustainable, attainable,

safe and secure; • Add value to the neighbourhood through sensitive intensification; • Promote land and infrastructure efficiencies; • Support active and passive transportation; • Incorporate energy efficient technologies; and, • Provide for barrier-free accessibility.

2.2. Development Objectives: The intent of the proposal is to promote and advance great urban design. To this end, the following performance standards have served to guide and direct the built form and the spatial arrangement of supportive elements within the proposed site development concept, whereby: • The building will be positioned on the Site to minimize potential impacts to the surrounding land

uses; • The building will establish a built edge along the Baseline Road West frontage, close to the south

property line; • The building will be oriented to the street with its principle entrance located on the south

elevation, facing Baseline Road West; • Service, utility and garbage areas will be located internal to the building and access to these uses

will be from the interior of the Site; • Pedestrian connections through the Site, between building and the street, and between the

building and the parking area are will be safe, barrier-free, convenient and direct; • Functional, appropriately sized and located outdoor amenity areas will be incorporated into Site

design; • Existing vegetation will be maintained and enhanced, where appropriate; • Parking will be screened and located in the rear and interior side yards; and, • Parking areas will include landscaped islands with trees and/or other vegetation and/or Low

Impact Design solutions to reduce the heat island effect, where possible.

2.3. Proposed Site Development Concept: The proposed site development concept provides for a low-rise, four-storey, 61-unit residential apartment building (see Figure 1). The proposed built density of the Site equates to 100 units per hectare. Subject to change, the proposed mix of unit types includes: 47 one-bedroom, 10 two-bedroom and 4 three-bedroom configurations; noting, the three-bedroom units were added to the development proposal in response to recommendations made by the City through the pre-application consultation process leading up to the proposal submission.

Through the current review process, it is the intent of HDC to work collaboratively with City staff to further refine the urban design principles and performance standards advanced within the proposal. The results of this process will serve to inform a future RFP process led by HDC to seek a Prime Consultant that will deliver the development and, ultimately, the “the look” of the building (including the spatial organization of other supportive site elements such as parking, outdoor amenity space and landscaping). The successful Prime Consultant will be responsible for submission of Site Plan Approval and Building Permit drawings that are consistent with the City’s approved zoning for the Site.


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Figure 1 – The Proposed Site Development Concept (also see Appendix A)


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Landscaping is used extensively and strategically throughout the Site to enhance privacy, to provide outdoor amenity space, and to screen spatial elements from the public and private realm. Enhanced landscaping is envisioned along the eastern perimeter of the Site to provide common outdoor amenity space and to serve as a stormwater management mitigation solution (see the Site Servicing Feasibility Report by EXP Services Inc. included as a requirement for a complete OPA/ZBA application submission). A detailed landscape plan to identify trees, plantings, fencing, pathways, etc. will be informed through a future Site Plan Approval review process.

Vehicular access to the Site is provided by a single, full-turn driveway located on the westside of the subject lands. Parking for 61 vehicles (including 10 barrier-free parking stalls) is located along the western property line. Screening for the proposed parking area is anticipated to include both natural and constructed elements.

Pedestrian connections extend directly from the public realm to the principle building entrance situated strategically at the mid-point of “the T” shaped building concept, fronting Baseline Road West. Further pedestrian connections are provided to access the parking area and link the barrier-free parking spaces directly to building entrances.

3. Subject Lands

The subject lands are located on the north side of Baseline Road West, east of Cotswold Gate and west of Wharncliffe Road South (see Figure 2).

Figure 2 – The Subject Lands

The subject lands are rectangular in shape, approximately 66.1 metres in width and 93 metres in depth, equating to 0.62-hectares (1.52 acres). The Site is generally flat and is vacant, apart from an abandoned sea-can container located in the southwest corner of the Site (see Figures 3 & 4).


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Figure 3 – The Subject Lands (From the Northeast corner looking south to Baseline Road West.)

Figure 4 – The Subject lands (Mid-site looking northwest toward the abandoned sea-can.)


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The northwest quadrant of the Site has been cleared. The balance of the Site, including the Baseline Road West frontage (Figure 5), includes a vegetative patch that is dissected by a water feature (“Silver Creek”) that traverses the lot from the southeast to the north (Figures 6 and 7).

Figure 5 – The Subject Lands: Baseline Road West Frontage

Figures 6 – The Subject Lands (Mid-site looking Figure 7 – The Subject Lands (Mid-site looking east towards 106/112 Baseline Road West.) toward the northeast quadrant of the Site.)

The subject lands front Baseline Road West. The Baseline Road West right-of-way includes an east/west vehicular travel lane, delineated on-road bicycle lanes, and is an identified transit route.

Transit supportive infrastructure, including sidewalks, transit stops, and street lighting are located in the Baseline Road West boulevard. The Average Annual Daily Traffic (AADT) volumes on this particular segment of Baseline Road West are 8,500 vehicle trips per day.


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4. Surrounding Neighbourhood

The subject lands are located in an area characterized by a mix of low-, medium- and high-density residential built forms (Figure 8). There is no consistent lot fabric in the neighbourhood; large and small, wide and narrow, regular and irregular lots are intermixed throughout the neighbourhood. A regular shaped lot pattern emerges west of Cotswold Gate and West Street, as the neighbourhood transitions into a “pocket” of single detached residential development. This “pocket” includes the single detached dwellings on the westerly terminus of Centre Street and Centre Crescent, and the single detached dwellings bounded by Baseline Road West, Beachwood Avenue, Commissioners Road West and West Street.

Lands to the immediate east of the subject lands have been developed for two 11-storey high-rise apartment towers and two low-rise, four-storey apartment buildings (each with varying setbacks and building orientation to the street).

Lands to the immediate south of the subject lands include a single detached dwelling lot “sandwiched” between an 11-storey and a nine-storey apartment building (each with varying setbacks and building orientation to the street).

Lands to the immediate west of the subject lands have been developed for two-storey cluster townhouses. The townhouses are positioned on the westerly extreme of the property and are serviced by a drive lane and parking area contiguous with the easterly property boundary.

Lands to the immediate north of the subject lands include two single detached dwellings fronting the south side of Centre Street. The two single detached dwellings are situated on the north half of their respective lots. The southerly half of these lots include, in the case of 127 Centre Street, outbuildings and ancillary structures and, in the case of 119 Centre Street, a vegetative patch.

Figure 8 – The Surrounding Neighbourhood


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5. Current Policy and Regulatory Framework

5.1. The City of London 1989 Official Plan: The City of London 1989 Official Plan designates the subject lands, as well as lands to the north and west of the Site, Multi-Family Medium Density Residential (MFMDR) (Figure 9). Permitted uses in the MFMDR designation includes row houses, cluster houses and low-rise apartment buildings. The 1989 Official Plan contemplates that development within the MFMDR designation will not exceed 75 units per hectare. Exceptions to the density limit may be permitted up to 100 units per hectare through Bonusing, without the need for an Official Plan Amendment.

Figure 9 – The City of London 1989 Official Plan

Lands to the east and south of the subject lands have been designated Multi-Family High Density Residential (MFHDR) in the City of London 1989 Official Plan. Permitted uses in the MFHDR designation include low-, mid- and high-rise apartment buildings. Net residential densities and built height in the MFHDR designation will vary by location but generally do not exceed 150 units per hectare outside of Central London.

The subject lands have not been identified as having archaeological potential and have not been identified as being within a Tree Protection Area.

Lands flanking an identified water feature (“Silver Creek”) are subject to the regulative authority of the Upper Thames River Conservation Authority (see Appendix B – Figure 1: UTRCA Limits).

Baseline Road West has been identified in the City of London Official Plan as a Secondary Collector.

Development Response: The proposed site development concept provides for a use, intensity and built form that is contemplated by way of the MFMDR designation polices of the City of London 1989 Official Plan. No amendment to the City’s 1989 Official Plan is required.


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5.2. The Z.-1 Zoning By-law: The City of London Z.-1 Zoning By-law zones the subject lands a Residential R8 (R8-3) Zone (Figure 10). The Residential R8 (R8-3) Zone is consistent with, and serves to implement, the MFMDR designation of the City’s 1989 Official Plan. Permitted uses in the R8-3 Zone include, but are not limited to, apartment buildings, handicapped persons apartment buildings, senior citizen apartment buildings and stacked townhouses to a maximum density of 65 units per hectare and a maximum height of 13 metres (four-storeys).

The General Regulations of the Z.-1 Zoning By-law identify the subject lands as being within Parking Standard Area 3. Parking standards within Parking Area 3 require the provision of 1.25 vehicular parking spaces per dwelling unit. These regulations further require the provision of 0.75 bicycle parking spaces per dwelling unit.

Figure 10 – The Existing Z.-1 Residential R8 (R8-3) Zone

Lands to the east of the subject lands (including the mid- and high-rise apartment buildings) have been zoned a Residential R9 (R9-7●H40) Zone permitting apartment buildings, handicapped persons apartment buildings and senior citizen apartment buildings to a maximum density of 150 units per hectare and a built height of 40 metres.

Lands to the south of the subject lands (including the existing single detached dwellings and flanking high-rise apartment buildings) are zoned a Residential R9 (R9-7●H32) Zone permitting apartment buildings, handicapped persons apartment buildings and senior citizen apartment buildings to a maximum density of 150 units per hectare and a maximum built height of 32 metres.


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Lands to the west and to the north of the subject lands (including the existing townhouses and two single detached dwellings) have been zoned a Residential R5 Holding (h-5●R5-4) Zone permitting cluster townhouse dwellings or cluster stacked townhouse dwellings to a maximum density of 40 units per hectare and a maximum height of 12 metres. The h-5 Zone associated with these lands requires that the future development be subject to a Site Plan Approval review process to ensure that development takes a form that is compatible with adjacent land uses (including the subject lands at 122 Baseline Road West).

Development Response:

A four-storey apartment building with a maximum built height of 13 metres and a built density of 65 units per hectare is permitted by the existing Residential R8 (R8-3). The proposed density of 100 units per hectare sought by the proposal would not be permitted under the existing Residential R8 (R8-3) Zone but may be sought through a rezoning application, subject to the Bonusing policies of the City’s 1989 Official Plan. The proposed number of on-site vehicular and bicycle parking stalls would not meet the minimum standards advanced under the General Regulations of the Z.-1 Zoning Bylaw.

5.3. The London Plan: The London Plan identifies the subject lands, and lands flanking the site to the north, east, south and west, as being within the Neighbourhood Place Type (Figure 11).

Figure 11 – The London Plan


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The subject lands, including lands flanking the Site to the east, south and west, enjoy frontage on Baseline Road West, identified in the London Plan as a Neighbourhood Connector. Permitted uses within the Neighbourhood Place Type fronting a Neighbourhood Connector include single detached, semi-detached, duplex, triplex and townhouse dwellings to a maximum height of 2.5 storeys.

Lands to the north of the subject lands front to Centre Street, identified in the London Plan as a Neighbourhood Street. Permitted uses in the Neighbourhood Place Type fronting a Neighbourhood Street would include single detached, semi-detached, duplex, and townhouse dwellings to a maximum height of 2.5 storeys.

The London Plan is silent in respect to a maximum permitted built density.

Development Response: The proposed four-storey apartment building would not be permitted on the subject lands under the Neighbourhood Place Type and applicable street typology policies of the London Plan.

6. Proposed Official Plan and Zoning By-law Amendments The existing policies of the 1989 Official Plan (including the Bonus policies) provide for the use, intensity and form of development contemplated by way of the proposed site development concept.

The existing Residential R8 (R8-3) Zone would not provide for a requested residential density of 100 units per hectare or an east interior side yard of 4 metres (rounded down from the 4.8 metres shown on Figure 1, pg. 3, to provide flexibility in design through the Site Plan Approval process). All other requirements of the existing Residential R8 (R8-3) Zone variation identified on Table 12.3 of the Z.-1 Zoning By-law have been met or are substantially exceeded.

The General Provisions of the Z.-1 Zoning By-law would not provide for the number of vehicular and bicycle parking spaces contemplated by way of the proposed site development concept.

The Neighbourhood Place Type policies of the London Plan would not provide for the four-storey, low-rise apartment building sought through the proposed site development concept. Again, the London Plan is silent in respect to a maximum permitted built density.


The following Official Plan and Zoning By-law amendments are being sought through the proposal:

• In-as-much as the policies of the London Plan would not provide for a four-storey, low-rise apartment building on the subject lands, a site-specific amendment to Policy 961 and to Map 7 of the London Plan is being sought to add a special policy in the Neighbourhood Place Type;

• That the existing Residential R8 (R8-3) Zone be amended to a holding Residential R8 Bonus (h-5●R8-3●B (_)) Zone, wherein:

A Site Plan Approval process to further inform the built form and spatial arrangement of site elements be required by Council prior to the issuance of a building permit;

Special Provisions to the Residential R8 (R8-3) Zone to provide for an east interior side yard of 4 metres, a vehicular parking ratio of 1:1 and a bicycle parking ratio of 0.25:1 be included as regulations in the requested Bonus Zone; and


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A Bonus “B (_)” to the Residential R8 (R8-3) Zone to permit a residential density of 100 units per hectare in return for the provision of affordable housing, whereby, subject to change: - The mix of unit type configurations is proposed to include: 47 one-bedrooms, 10 two-

bedrooms and 4 three-bedroom units; and

- A minimum of 30% of the total unit count, in a mix of each unit type configuration provided, will be offered at “Affordable Rent”.

7. Planning Policy Analysis

7.1. The Provincial Policy Statement (PPS), 2020: Issued under Section 3 of the Planning Act, the Provincial Policy Statement (PPS) provides policy direction on matters of provincial interest related to land use planning. All planning applications, including Official Plan and Zoning By-law amendments, are required to be consistent with the policies of the Provincial Policy Statement. The following section identifies how the proposed application is consistent with, and will serve to implement, the identified matter of provincial interest.

PPS Policy 1.1.1.: Healthy, livable and safe communities are sustained by: b) Healthy, livable and safe communities are sustained by accommodating an appropriate affordable and market-based range and mix of residential types (including single-detached, additional residential units, multi-unit housing, affordable housing and housing for older persons), employment, institutional, recreation, park and open space, and other uses to meet long-term needs; and,

e) Promoting the integration of land use planning, growth management, transit-supportive development, intensification and infrastructure planning to achieve cost-effective development patterns, optimization of transit investments, and standards to minimize land consumption and servicing costs;


The proposed site development concept seeks to build complete neighbourhoods by meeting the long-term housing needs of people of all ages, incomes and abilities, and by providing an opportunity to age in place. Not only will the proposal add to the mix of housing types in the neighbourhood, but it will include a mix of “affordable rent” and “market rent” units in one-, two- and three-bedroom configurations. Further, the proposal will advance site-specific development standards (vehicular and bicycle parking rates) that are appropriate given the mix of “affordable rent” and “market rent” units and the location of the subject lands on an identified transit route.

The proposal activates an existing vacant lot that is fully serviceable with a form and scale of development, and level of residential density, that is appropriate given the size and configuration of the Site. The subject lands are fully serviced with municipal infrastructure and sufficient capacity exists to support the level of residential density being sought through the proposal.

The proposed site development concept is consistent and compatible with the surrounding land uses.


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PPS Policy 1.1.3.2.a), e) and f):

Land use patterns within settlement areas shall be based on densities and a mix of land uses which: efficiently use land and resources; support active transportation; and, are transit-supportive.


The subject lands are located within an identified settlement area. The proposed site development concept will provide for a level of residential density that efficiently and effectively utilizes land and municipal infrastructure.

The subject lands are located within a convenient walking distance of open space and commercial uses. The proximity of these uses is further enhanced through pedestrian and bicycle supportive infrastructure (sidewalks, street lighting, and on-road delineated bicycle lanes). The Site is also directly serviced by public transit, and transit supportive infrastructure.

PPS Policy 1.1.3.3 Intensification:

Planning authorities shall identify appropriate locations and promote opportunities for transit-supportive development, accommodating a significant supply and range of housing options through intensification where this can be accommodated taking into account existing building stock, and the availability of suitable existing or planned infrastructure required to accommodate projected needs.

Development Response: The proposed site development concept will increase the supply and range of housing options in the neighbourhood through the development of a low-rise apartment building containing 61 dwelling units. Intensification on the subject lands is appropriate given: the built context of the neighbourhood; the location of the Site on a higher order road, directly serviced by public transit; and, proximity to open space opportunities and goods and services establishments located along the Wharncliffe Road South commercial corridor. The subject lands are also of a sufficient size and configuration to accommodate the scale, intensity, and requisite components of the proposed site development concept without impacting adjacent land uses.

PPS Policy 1.1.3.4.: Appropriate development standards should be promoted which facilitate intensification, redevelopment, and compact form while avoiding or mitigating risks to public health and safety.

Development Response: The proposed site development concept will provide a form of development that is supportive of public transit. The Site is also located in convenient walking distance of open space opportunities and the goods and services required on a daily or weekly basis.

The proposal will provide for “inward and upward” residential intensification at an appropriate location.

The proposal will also serve to advance a parking standard that is more in keeping with a parking standard historically representative of affordable housing developments.


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PPS Policy 1.1.3.6.:

New development taking place in designated growth areas should occur adjacent to the existing built up area and shall have a compact form, mix of uses and densities that allow for efficient use of land, infrastructure, and public service facilities.

Development Response: The proposed site development concept will advance the development of a vacant, underutilized lot in an existing built-up residential area. The proposed density of 100 units per hectare is reflective of a compact, efficient form of housing that adds to the mix of uses, built forms and densities along this portion of Baseline Road West. The subject lands are also identified as being within the City’s Primary Transit Area, which is to be the focus of residential intensification and transit investment in the City.

PPS Policy 1.6.6.2.:

Municipal sewage services and municipal water services are the preferred form of servicing for settlement areas to support protection of the environment and minimize potential risks to human health and safety. Within settlement areas with existing municipal sewage services and municipal water services, intensification shall be promoted wherever feasible to optimize the use of the services.

Development Response: The subject lands are located within the City of London Growth Area Boundary and the City’s Built Area Boundary. The proposal will make full use of the existing municipal sewage and water services proximate to the Site. No capacity issues have been identified. Refer also to the Site Servicing Feasibility Report by EXP Services Inc., included with the proposal submission forming part of a complete OPA/ZBA application.

PPS Policy 1.8.1.a), b) and c):

Planning Authorities shall support energy conservation and efficiency, improved air quality, reduced greenhouse gas emissions and preparing for the impacts of a changing climate through land use and development patterns which: promote compact form; promote the use of active transportation and transit; and, focus travel intensive land uses on sites which are well serviced by transit.

Development Response: The proposal will support energy conservation and improved air quality through a reduction in greenhouse gas emissions (as required by CMHC Co-Investment Fund) by providing for a travel intensive land use on an identified transit route. Proximity of the subject lands to complimentary and supportive land uses will encourage active transportation thereby minimizing gas emissions and preparing for the impacts of climate change.


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7.2. The City of London 1989 Official Plan: The subject lands are designated Multi-Family Medium Density Residential in the City of London 1989 Official Plan (see Figure 9, pg. 8).

Section 3.1.1 ii), vi), and x) - General Objectives for all Residential Designations:

The General Objectives for all residential designations: include the provision of dwelling types according to location, affordability and accessibility so that a broad range of housing requirements are satisfied; minimize the potential for land use compatibility which may result from an inappropriate mix of low, medium and higher density residential uses; and, promote residential development that makes efficient use of land and services.

Development Response: The proposed site development concept provides for the development of a low-rise apartment building containing a mix of “affordable rent” and “market rent” units.

The Neighbourhood Character Statement and Compatibility Report included within this PJR demonstrate that the proposed low-rise apartment building is sensitive to, compatible with, and a good fit within the existing surrounding neighbourhood.

Section 3.3.1 - Permitted Uses:

Permitted uses in the Multi-Family Medium Density Residential designation include low-rise apartment buildings.


The proposal advances an anticipated use within the Multi-family Medium Density Residential designation policies of the Official Plan.

Section 3.2.3.1 and 3.3.1 vii) - Residential Intensification: Residential intensification refers to the development of a property, site or area at a higher density than currently exists on the site. Residential intensification can include the development of a vacant and/or underutilized lot within a previously developed area. Within the Multi-Family Medium Density Residential designation, residential intensification proposals shall be subject to a Site Plan Review process.


The subject lands are currently vacant and are located in a previously established area. The proposed site development concept to provide for a low-rise, 61-unit apartment building is viewed as residential intensification.

The residential intensification sought through the proposal will be subject to a Site Plan Approval review process.

Section 3.2.2. - Location: The preferred locations for the Multi-Family Medium Density Residential designation include lands along higher order roads (including arterials, primary collectors, secondary collectors) and in close proximity to open space and shopping areas. The policies of the 1989 Official Plan further identify


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lands adjacent to Multi-Family High Density Residential designations as preferred Multi-Family Medium Density Residential locations. Consideration will also be given to specific criteria when designating lands for Multi-Family Medium Density Residential uses including: compatibility; municipal services; traffic; and buffering.


The subject lands are located on a Secondary Collector. A Neighbourhood Park (Euston Park) and a community shopping area (at the intersection of Wharncliffe Road South and Baseline Road) are within a convenient walking distance of the Site. Multi-Family High Density Residential designations flank the subject lands to the immediate south and east (Figure 9, pg. 8).

The proposal advances setbacks, landscaping treatments and a scale and form of development that is contextual to the neighbourhood and appropriate given the size and shape of the subject lands.

The Site is an appropriate location for a Multi-Family Medium Density Residential and enjoys frontage on a Secondary Collector with an Average Annual Daily Traffic Volume of 7,500 vehicles.

The City’s Environmental and Engineering Services Division has not identified any concerns pertaining to the capacity of the exiting water and sanitary services along Baseline Road West to accommodate the proposed site development concept.

Section 3.3.3. i) and ii) - Scale of Development:

Development within areas designated Multi-Family Medium Density Residential are intended to have a low-rise form, site coverage and a density that provides a transition between low-density residential areas and areas of high-density residential development. Built forms and densities within the Multi-Family Medium Density Residential designation will not normally exceed four-storeys and 75 units per hectare. Developments may be considered up to a maximum density of 100 units per hectare under the Bonusing polices of the 1989 Official Plan. These polices include the provision of affordable housing and universal accessibility as elements for which additional height and density may be sought.


The proposed site development concept, providing for a low-rise, four-storey apartment building and a built density of 100 units per hectare, is consistent with, and will serve to implement, the scale of development and Bonusing policies of the 1989 Official Plan.

7.2.1. Planning Impact Analysis The policies of the 1989 Official Plan require the preparation of a Planning Impact Analysis (PIA) to evaluate applications for a change in land use and to identify ways of reducing any adverse impacts on surrounding land uses. The evaluation criteria relevant to the proposed site development concept are addressed herein.

(a) The compatibility of the proposed uses with surrounding land uses and the likely impact of the proposed development on present and future land uses.


The proposed site development concept provides for a multi-family medium density residential land use that is contextual and compatible with surrounding land uses. The proposal activates a vacant


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Site with a built form and density that provides for an appropriate transition between the high- and low-density residential uses and built forms that flank the Site to the east and west, respectively.

(b) The size and shape of the parcel of land on which a proposal is to be located and the ability of the site to accommodate the intensity of the proposed use.

Development Response: The vacant 0.62-hectare Site is regularly shaped, of a sufficient size and configuration to accommodate the intensity of the proposed use and is situated in an established residential neighbourhood.

The proposed site development concept would rely on a suite of development standards that meet, or far exceed, the minimum requirements of the existing Residential R8 (R8-3) Zone variation including, but not limited to, lot area, built coverage, landscaped open space and rear and interior yard setbacks.

The proposal seeks to advance a vehicular parking standard that is representative of HDC’s historical experience with affordable housing development. A reduced bicycle parking standard is also being sought. In advancing this standard the HDC would note the proximity of public transit, open space, schools and shopping. HDC would further note the tendency of tenants to want to “park” their bicycles within their own dwelling unit, and the convenience offered by the proposed built form to do so.

(c) The supply of vacant land in the area which is already designated and zoned for the proposed use.

Development Response: The proposal activates a vacant parcel of underutilized land (in a previously established built-up area) with a use, intensity and form of development that is consistent with, and serves to implement, the Multi-Family Medium Density Residential policies of the 1989 Official Plan.

(d) The proximity of any proposal for medium or high-density residential development to public open space and recreational facilities, community facilities, and transit services.

Development Response: The subject lands is located within an 800 metre radius to public open space and recreational and community facilities including, but not limited to, Euston Park, Odessa Park, Basil Grover Park, the walking trails of Southcrest Ravine, Southcrest Park and Briscoe Woods. Westminster Secondary School, Arthur Ford Public School and a French First Catholic Elementary School are also located within an 800 metre radius of the subject lands.

The Site is also located within a Primary Transit Area that is directly serviced by public transit and a delineated on-road bicycle route along Baseline Road West.


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(e) The need for affordable housing in the area in the City as a whole.

Development Response: Canada Mortgage and Housing Corporation (CMHC) maintains housing analytics for the City of London as a whole and smaller geographic areas based on a grouping of neighbourhoods. CMHC’s 2020 City-wide private apartment vacancy rates for London for one-bedroom, two-bedroom and three-bedroom units is identified as 1.9%, 1.6% and 1.4%, respectively. In the grouping of neighbourhoods collectively identified by CMHC as the “Southwest”, private apartment vacancy rates for one-bedroom, two-bedroom and three-bedroom units is identified as 0.9%, 1.3% and 1.9%, respectively.

The proposal provides for housing affordability in the City of London in an area where vacancy rates and average rents present an affordability challenge for Londoners. The proposed site development concept provides for the creation of a 61-unit mixed-affordability housing model consisting of a “affordable rent” units and “market rent” units to meet funding program requirements and in accordance with CMHC posted rental rates for London, ON.

Subject to change, the mix of unit type configurations is proposed to include: 47 one-bedroom, 10 two-bedroom and 4 three-bedroom. A minimum of 30% of the total unit count will be offered at “affordable rent” rates.

(f) The height, location and spacing of any buildings in the proposed development and any potential impacts on surrounding land uses.

Development Response: The proposed site development concept anticipates the construction of a four-storey “T” shaped built form at a maximum built height of 13 metres. The “top” of the “T” shaped building is setback 8 metres from the southerly property line (10.75 metres from the centerline of Baseline Road West, as required per Transportation for a road widening dedication) and anywhere from 4.8 metres to 15 metres from the easterly property line. The “base” of the “T” has a rear yard setback to the northerly property line of approximately 21.7 metres. No other buildings are proposed. The proposed scale and placement of the building within the proposed site development concept is purposeful:

• Working within the maximum 13 metre built height requirements pertaining to the Site, the proposed site development concept will provide an appropriate transition from the 11-storey high-rise apartment buildings to the east and the two-storey townhouses to the west.

• Placement of the building perpendicular to Baseline Road West will serve to “frame the street” and enhance the pedestrian experience.

• Interior and rear yard setbacks are substantive and far exceed the minimum requirements of the existing Residential R8 (R8-3) Zone variation. The height and location of the proposed built form is viewed as appropriate and will serve to refute any potential impacts on surrounding land uses.


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(g) The extent to which the proposed development provides for the retention of any desirable vegetation or natural features that contribute to the visual character of the surrounding area;

(j) The potential impact of the development on surrounding natural features and heritage resources;

(k) Constraints posed by the environment; and,

(l) Compliance of the proposed development with the City’s Official Plan, Zoning By-law and Site Plan Control By-law.


The subject lands include a vegetative patch that extends along the southerly and easterly property limits. Trees also extend the along westerly property limit. Schedule B-1 Natural Features to the City of London Official Plan does not identify any significant natural features on the site.

City staff have indicated that, through a future Site Plan Approval application submission, a Tree Preservation Report will be required. A Preliminary Tree Preservation Report was completed for the subject lands in January 2018 by Branching Out Forestry Consulting. Comments within the preliminary report note that “most trees [found within the subject lands] would be undesirable in a high-density development because of their species, and some by their condition”.

To the greatest extent possible, the existing vegetation will be maintained and enhanced with new plantings to provide for privacy and buffering. Selective cutting will also be utilized to enhance the interface of the public and private realm along Baseline Road West to enhance feelings of safety and pedestrian security.

A water feature dissects the Site (“Silver Creek”). Schedule B-2 Natural Hazards to the City of London Official Plan identifies the water feature as being under the regulation of the Upper Thames River Conservation Authority (UTRCA) (also see Appendix B – Figure 1: UTRCA Limits).

Through the pre-application consultation process, detailed discussions with the UTRCA and City of London Development Services staff resulted in the creation of a stormwater management (SWM) strategy to address the enclosure of the Silver Creek water feature as well as up and down stream connections. These discussions, alongside the preparation of an External Drainage Brief and Preliminary Grading and Servicing Plan by EXP Services Inc. (also see Appendix B – Figure 2: Preliminary Grading and Servicing Plan), satisfied the UTRCA that the exact extent of this feature can be addressed through the Site Plan Approval process.

Capturing the details of the SWM strategy derived through pre-application consultation with the City, EXP Services Inc. prepared a Site Servicing Feasibility Study that is included with this submission as a requirement of a complete OPA/ZBA application.

The subject lands do not contain, nor is it adjacent to, an identified Heritage feature and the Site has not been identified as having archaeological potential.


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(h) The location of vehicular access points and their compliance with the City’s road access policies and Site Plan Control By-law and the likely impact of traffic generated by the proposal on City streets, on pedestrian and vehicular safety, and on surrounding properties.

Development Response: The subject lands have frontage on Baseline Road West. Baseline Road West is identified as a Secondary Collector on Schedule C – Transportation to the City of London Official Plan.

Vehicular and pedestrian access to the Site is facilitated by a single, full-turn driveway and sidewalk located on the western side of the Site. A second sidewalk providing direct pedestrian access to the proposed building is located on the eastern half of the site. The final design and specific alignment of the driveway on the western half of the site and sidewalks will be determined through the Site Plan Approval process.

This proposed site development concept minimizes any adverse impacts on the existing transportation system, and to the abutting driveway to the west, by providing for vehicular infrastructure that is appropriately located and minimizes any potential impacts on the natural environment. The proposed single vehicular access point will enhance pedestrian safety by minimizing interaction with pedestrians in the public realm.

(i) The exterior in terms of the bulk, scale and layout of the buildings and the integration of these uses with present and future land uses in the area.


The bulk, scale and layout of the building within the proposed site development concept was informed by our goals and objectives previously identified within this PJR.

The bulk, scale and layout of the building at the street is compatible with the high and medium density residential built forms abutting the property to the east.

The scale, bulk and strategic orientation of the building within the proposed site development concept directs potential land use impacts away from the existing townhouses to a location on the Site where impacts will be mitigated through an enhanced west interior side yard setback.

The building within the proposed site development concept will be located approximately 55 to 70 metres from the closest 11-storey apartment building immediately to the east. An enhanced rear yard setback in excess of 20 metres mitigates any potential land use impacts on the existing single detached dwellings to the north.

The strategic placement of the four-storey building within the proposed site development concept provides for an appropriate and contextual transition in mass and scale with the surrounding high, medium and low density residential built forms.

(m) Measures planned by the applicant to mitigate any potential adverse impacts on surrounding land uses and streets which have been identified as part of the Planning Impact Analysis.

Development Response: As noted in the previous Development Response to item “(i)”, the placement of the building, substantive interior and rear yard setbacks, and enhanced landscaping will be utilized to mitigate any potential land use impacts on surrounding land uses.


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The location of the parking area within the proposed site development concept, along the westerly half of the Site, will be buffered and screened from the adjacent townhouses by the existing cedar fencing and new vegetation, where needed and appropriate. The proposed parking area has been screened from the street and designed to include lighting standards and landscaped islands (with trees to reduce the heat island effect). The parking area has also been designed in such a way to facilitate safe, barrier-free accessible, convenient and direct pedestrian connections to the proposed building.

The measures advanced in the proposed site development concept will serve to mitigate any potential land use impacts on surrounding land uses inclusive of the public realm.

(n) Impacts of the proposed change on the transportation system, including transit.


No negative impacts on the City’s transportation system were identified through the pre-application consultation process. The reduced vehicular and bicycle parking standards sought through the proposal were not raised as a concern by the City and were not of an order or magnitude to necessitate the submission of a Parking or Traffic Impact Analysis as a requirement of a complete application.

The requested parking standard is viewed as being appropriate given HDC’s historical experience with similar developments; and, the location of the Site within a convenient walking distance of goods and services typically required on a daily or weekly basis, and the proximity of transit and transit supportive infrastructure. The proposal will serve to encourage active transportation and support the City’s public transportation system.

Section 3.7.3 - Required Information:

Applications proposing an Official Plan Amendment to a more intensive residential land use designation or requesting Bonus Zoning shall include a review of the structures and the natural environment within the surrounding neighbourhood. This review may include a Neighbourhood Character Statement and a Compatibility Report. By policy, these reports may be submitted as a single document.


The proposed low-rise, four-storey apartment building would be viewed as a permitted use in the Multi-Family Medium Density Residential designation. The existing Residential R8 (R8-3) Zone variation serves to implement the Multi-Family Medium Density Residential designation by providing for a low-rise apartment building up to a maximum height of 13 metres and a maximum density of 65 units per hectare. No amendment to the City of London Official Plan is required to permit the use or form of development being advanced through the proposal.

To attain a density of 100 units per hectare, HDC is requesting Bonus Zoning. No additional height above the existing regulation permitting 13 metres is being sought. As such, a Neighbourhood Character Statement (see Section 7.2.2.) and a Compatibility Report (see Section 7.2.3.) have been identified by City staff as being a requirement of a complete application.


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7.2.2. Neighbourhood Character Statement

3.7.3 (a) - Neighbourhood Character Statement: A Neighbourhood Character Statement (NCS) is a detailed statement of the character of the existing neighbourhood. The NCS includes consideration of character and image, site design and servicing.

Development Response: Neighbourhood Character Statement – Character and Image

Within this PJR submission, Section 3: The Subject Lands and Section 4: The Surrounding Neighbourhood provide a detailed description of the Site and an overview of the surrounding neighbourhood, including lot patterning, use, intensity and built form. The following observations are intended to build on Sections 3 and 4 by providing a description of the existing street character in the vicinity of the subject lands.

Baseline Road West is the only municipal street within 100 metres of the centre point of the subject lands, as measured in the east/west direction along the south property line (Figure 12). Proximate streetscapes include both the north and south sides of Baseline Road West.

Figure 12 – Streetscapes within 100 metres of the Subject Lands

This particular section of Baseline Road West is characterized by a two-lane Secondary Collector and each side of the street is served by a public sidewalk and on-road delineated bicycle lanes. And, Hydro poles are located on the south side of the Baseline Road West.


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Looking west from the subject lands, there is little activation of the street on either side of Baseline Road West (Figures 13 and 14). Existing street plantings, consisting primarily of mature trees, line most of the north and south side of the street.

Figure 13 – Existing Streetscape – North Side of Baseline Rd. W. (Looking west from the Subject Lands.)

Figure 14 – Existing Streetscape – South Side of Baseline Rd. W. (Looking west from the Subject Lands.)

The existing townhouse block located at 132 Baseline Road West “end faces” the street. These townhouses are set back approximately 47 metres from the public right of way. Within this setback is a small, semi-screened parking area (directly abutting the sidewalk) and a play structure (between the parking lot and the end unit of the townhouse block).

Looking east from the subject lands, there is limited activation of the streetscape on the north side of Baseline Road West (Figure 15). An 11-storey apartment building located immediately adjacent to the subject lands (112 Baseline Road West) is setback approximately 70 metres from the street.


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Its twin tower (106 Baseline Road West) is setback approximately 25 metres from the street. The spatial arrangement and orientation of the towers and their supportive infrastructure (principle building entrances, driveway, sidewalks) do little to activate the Baseline frontage. While very well maintained, the frontage includes a manicured grassed area, a loading/unloading area and driveline, and a “garbage shed”.

Figure 15 – Existing Streetscape – North Side of Baseline Rd. W. (Looking east from the Subject Lands.)

Figure 16 – Existing Streetscape – South Side of Baseline Rd. W. (Looking east from the Subject Lands.)

Also, looking east, the south side of Baseline Road West (Figure 16) is dominated by a mix of medium- and high-density residential apartment buildings. Four of these developments “end-front’ the street and include extensive front yard parking. Setbacks vary from one apartment development to the next, resulting in no clear or definitive street line or built edge.


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A larger spatial analysis was undertaken having consideration for notable features and land uses located within a 400 and 800 metre radius of the subject lands (see Figure 17). The radii represent a straight-line walking distance of 5- and 10-minutes, respectively.

Figure 17 – Spatial Analysis – Notable Lands within a 400 and 800 metre radius of the Subject Lands

Notable land uses within a 400 metre radius include a range of residential uses, including: low-density residential uses in the form of single detached dwellings (Figure 18); semi-detached dwellings (Figure 19); medium-density residential uses in the form of two-storey townhouses (Figure 20); low- to mid-rise apartment buildings (Figure 21); and, high-density residential uses (Figure 22).

Institutional, commercial and office uses are limited within a 5-minute walking distance of the subject lands. Open space uses within a 400 metre radius include Euston Park to the north and a naturalized area to the west referred to as the Southcrest Ravine. Additional open space uses are plentiful within the 400 to 800 metre radii, 10-minute walking distance, including: Basil Grover Park, Odessa Park, Southcrest Park and the naturalized areas associated with Southcrest Ravine North and Briscoe Woods.

Lands within an 800 metre radius are comprised of low-, medium- and high-density residential uses, and commercial, institutional and open space uses. Within the 400 to 800 metre radii, one- and two-storey single detached dwellings are typical. Two-storey townhouses and mid- to high-rise apartment buildings are also within a 10-minute walking distance.


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Figure 18 – Single Detached Built Forms (Baseline Road West, west of the Subject Lands.)

Figure 19 – Semi-Detached Built Forms (Cotswold Gate, west of Subject Lands.)

Figure 20 – Townhouse Built Form (Centre Street, south of Subject Lands.)


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Figure 21 – Low to Mid-Rise Apartment Built Forms (Baseline Road West, east of the Subject Lands.)

Figure 22 – High-Rise Apartment Built Forms (Baseline Road West, east of the Subject Lands.)

Institutional uses are also found within the 800 metre radius, 10-minute walking distance of the subject lands. These uses include: the London Gospel Temple; Westminster Secondary School; Arthur Ford Public School; and, on the immediate periphery, St. Jude Catholic School.

An expansive range of commercial and office uses are located within the 800 metre radius, 10-minute walking distance of the subject lands, including, but not limited to: restaurants; retail stores; grocery store and pharmacy, banks and personal services uses at the Baseline Road and Wharncliffe Road intersection and lining the Wharncliffe Road South commercial corridor; and, populating to the community and associated shopping area node at Commissioners Road East and Wharncliffe Road South.


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Figure 23 – Range and Mix of Residential Built Forms and Densities (Within 400m of the Subject Lands.)

Figure 23 shows the range and mix of residential built forms within a 400 metre radius, including single detached dwellings, two-storey semi-detached dwellings, and a mix of low-, mid- and high-rise apartment buildings ranging in height (four- to 11-storeys) and in density (40 units per hectare to 150 units per hectare).

Neighbourhood Character Statement - Site Design

The proposed site development concept provides for a use, intensity and built form that is consistent with the “character and image” of the neighbourhood. An expansive range of complementary and supportive land uses, active and passive transportation options (including walking, cycling routes and transit), and green infrastructure are found within an 800 metre radius, 10-minute walking distance of the subject lands.

As noted in the introduction to this PJR, the purpose and intent of the requested OPA/ZBA amendments is twofold:

• the requested amendments establish planning permissions that provide for the future development of a low-rise residential apartment building containing a mix of bedroom configurations and “affordable rent” and “market rent” units; and,

• the requested amendments, once approved by Council, will inform a future Request for Proposal (RFP) process seeking a Prime Consultant to deliver the development and ultimately the “the look” of the building (including the spatial organization of other supportive site elements such as parking, outdoor amenity space and landscaping). As a requirement of the RFP, the successful Prime Consultant will be responsible for submission of Site Plan Approval and Building Permit


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drawings that are consistent with the City’s approved zoning and urban design principles and/or performance standards established for the Site.

Site Plan Approval and Building Permit drawings referred to above would include site plans, landscape design drawings, floor plans, elevations, etc. These drawings will subsequently serve to inform, and be subject to, a future site plan review process. HDC has requested a holding zone requiring a future site plan process as an invitation to work collaboratively with our neighbours and the larger community on the future activation of the Site.

The proposed site development concept submitted as part of this OPA/ZBA approvals process serves to address the matters and considerations identified in Section 3.2.3.5 (Site Plan Review and Urban Design) and Section 11.1 (Urban Design Principles) of the City of London 1989 Official Plan.

The proposed site development concept (Figure 1, pg. 3) embeds HDC’s performance standards and serves to demonstrate:

• a building footprint, built height and spatial orientation that: serves to activate the street, is pedestrian “in scale”; and, establishes safe, direct and barrier-free accessible pedestrian connections throughout the Site and from the Site to the public realm;

• a principle building entrance that further serves to activate the streetscape and reinforce the “front facing” built form;

• a built form that serves to transition seamlessly and logically into the neighbourhood;

• a building footprint that serves to provide for enhanced rear and side yard setbacks serving to mitigate and contain on-site potential land use impacts;

• a parking area that: provides for safe, direct and barrier-free accessible pedestrian connections; is suitably sized to accommodate projected demand; and, is strategically located to minimize impacts on the public realm;

• an outdoor amenity area that is not only sufficiently-sized and strategically located to provide for privacy and additional buffering opportunities and plantings, but also serves to mitigate overland flows and other potential SWM impacts;

• a desire to maintain, where possible, on-site green infrastructure in a manner consistent with the findings of the preliminary Tree Preservation Report; and,

• a defined snow storage area and temporary outdoor garbage collection pickup point (all screened from the public realm).

Neighbourhood Character Statement – Servicing As noted above, and throughout the balance of this PJR, the proposal serves to complete and connect the subject lands to the street and, by extension, to the larger neighbourhood and the complimentary and supportive uses located therein. The proposal will further serve to support public transit and the active and passive transportation options located in the immediate vicinity of the Site.

There is capacity “in the pipes” to accommodate the proposal. From a traditional servicing perspective, activation of the subject lands for an affordable housing development provides for the efficient use of land and municipal infrastructure.


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7.2.3. Compatibility

3.7.3 (b) Compatibility Report:

Forming part of an application for residential intensification, the applicant is required to demonstrate that the proposed project is sensitive to, compatible with, and a good fit within the existing surrounding neighbourhood.


HDC’s Planning Impact Analysis (pgs. 16-21) serves to review the use, intensity and built form of the proposed site development concept being advanced through the proposal, relative to the context of the existing surrounding neighbourhood.

The Planning Impact Analysis concluded that the proposal and/or the subject lands:

• provides for a use that is consistent with, and compatible to, the existing surrounding residential neighbourhood. The proposal would also provide for a use that is anticipated by policy for the subject lands;

• provides for a level of intensity that is consistent with, and compatible to, the levels of residential intensity and scale of development that immediately flank, or are in the immediate vicinity of, the subject lands;

• provides for a built form that is currently permitted by policy and permitted by regulation;

• activates a vacant parcel of land in a built-up area with a use, intensity and form of development that serves to provide for an appropriate transition between the high- and low-density residential uses that flank the subject lands to the east and to the west;

• advances development standards that meet, or far exceed, the minimum requirements of the requested Residential R8 (R8-3) Zone variation;

• advances alternative development standards that are in keeping with the affordable nature of the proposal and more representative of HDC’s historical experience with projected demand;

• are of a suitable size and configuration to accommodate the level of residential density without impacting surrounding land uses.

• strategically places the building in the southeast quadrant of the Site, providing for substantive interior and rear yard setbacks that far exceed the minimum requirements of the existing Residential R8 (R8-3) Zone;

• “completes the street” and provides for internal and external connectivity that is accessible, direct and safe; and,

• seeks opportunities to retain and enhance the existing vegetation.

The proposed height (four-storeys, maximum 13 metres) and use (apartment building) are permitted by way of the City’s 1989 Official Plan policy. The proposed density (100 units per hectare) is permitted by policy through Bonus Zoning.

To activate a Bonus Zone for a residential intensification project, a Planning Impact Analysis and a Neighbourhood Character Statement and Compatibility Report must be undertaken. HDC’s due diligence has demonstrated that the proposal provides for a use, intensity and form of development that is sensitive to, compatible with, and a good fit within the existing surrounding neighbourhood.


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12. Housing Objectives:

The City’s Housing Objectives serve to support the provision of dwelling types so that a broad range of housing requirements are satisfied.


The proposal provides for the development of a low-rise apartment building that would be complimentary to the existing mix of low-, medium- and high-density residential built forms. The proposal also provides for a mix of “affordable rent” and “market rent” units within the same building.

12.2.1.iv) Availability of Housing:

The policies of the Plan support the provision of opportunities for affordable housing in residential development throughout all areas of the City.


As noted previously within this PJR, CMHC’s 2020 City-wide private apartment vacancy rates in London for one-bedroom, two-bedroom and three-bedroom units is identified as 1.9%, 1.6% and 1.4%, respectively. In the grouping of neighbourhoods collectively identified by CMHC as the “Southwest”, private apartment vacancy rates for one-bedroom, two-bedroom and three-bedroom units is identified as 0.9%, 1.3% and 1.9%, respectively. The proposal provides for housing affordability in an area of the City which is experiencing an affordability challenge.

12.2.2.ii), iii) and vii) Measures to Increase the Supply of Affordable Housing:

The policies of the 1989 Official Plan state that where there is a need for affordable housing, Council may undertake the following:

• designate further areas of the City for intensification and infill subject to consideration of neighbourhood planning issues, adequate servicing, potential impact and mitigating measures and the preparation of a Neighbourhood Character Statement and Compatibility Report;

• the activation of surplus municipal lands that are of an adequate size to support the use and are located in proximity to public uses and infrastructure; and,

• provide density bonuses, where suitable, to proposals that have an affordable housing component above 30%.

Development Response: The proposal provides for the activation of land previously declared surplus by the City of London and transferred to HDC for the purpose of affordable housing development. The subject lands are vacant and fully serviced with municipal infrastructure and are located in an area proximate to a variety of transportation options and complimentary and supportive land uses. The Neighbourhood Character Statement and Compatibility Report demonstrate that the subject lands are of a sufficient size and configuration to provide for the intended use, intensity and form of development.


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19.4.3 Holding Zones:

The 1989 Official Plan states that a zoning by-law may contain holding provisions to ensure the orderly development of lands and that such development may be secured through agreements with the City.


As noted in the Introduction of this PJR, the purpose and intent of the requested action is to establish zoning permissions that will inform a future HDC RFP for land activation. In support of the requested zoning amendments, HDC has submitted a proposed site development concept demonstrating the location of the proposed building concept and the spatial arrangement of supporting site elements. Elevations and detailed design drawings do not comprise part of the present application. As such, HDC has requested that the proposal be subject to a future Site Plan Approval review process.

19.4.4 ii) Bonus Zoning:

Policies of the 1989 Official Plan state that increases in height and density than would otherwise be permitted in a zoning by-law may be sought in return for the provision of facilities, services and matters as set out in the by-law. The policies further state that increases in height and density may be sought for one or more of the following objectives:

• To support the provision of affordable housing;

• To support the provision of common open space that is functional for active or passive recreational use;

• To support developments which promote energy conservation and the use of public transit; and,

• To support the provision of design features that provide for universal accessibility.


The subject lands are designated Multi-Family Medium Density Residential. Density within the Multi-Family Medium Density Residential designation is permitted up to 75 units per hectare or 100 units per hectare with Bonusing. The existing Residential R8 (R8-3) Zone permits a built density of 65 units per hectare and a maximum height of 13 metres. The proposal seeks an increase in built density from 65 to 100 units per hectare and does not seek an increase in height.

A Bonus Zone is sought to permit a density of 100 units per hectare, in return for an affordable housing development that promotes and is supportive of: energy efficiency and conservation; greenhouse gas emission reductions; barrier-free and universal accessibility; and public transit.

7.3. The City of London Z.-1 Zoning By-law: The City’s Z.-1 Zoning By-law zones the subject lands a Residential R8 (R8-3) Zone (Figure 10, pg. 9). Permitted uses in the Residential R8 (R8-3) Zone include apartment buildings, senior citizen apartment buildings and handicapped persons apartment buildings.

The regulations of the Residential R8 (R8-3) Zone are identified in Table 1 below. Table 1 also identifies the special provisions (“*”) required to the standard Residential R8 (R8-3) Zone variation regulations to advance the proposal.


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Table 1 - Regulations of the Residential R8 (R8-3) Zone

Regulation Required As Proposed Lot Area (min.) 1000 m2 6151 m2 Lot Frontage (min.) 25 m 66.1 m Front Yard Depth (min.) 7 m 7 m East Interior Side Yard Depth (min.) 4.8 m 4.0m requested*

(4.8m identified on site design concept)

Rear Yard Depth (min.) 4.8 m 21.7 m Landscaped Open Space (min.) 30% 37% Lot Coverage (max.) 35% 20% Height (max.) 13 m 13 m (max.) Density (max.) 65 uph 100 uph*

Special regulations to the General Provisions of the Z.-1 Zoning By-law will also be required for an alternative vehicular parking standard (1 parking space per unit as opposed to 1.25 spaces per unit) and an alternative bicycle parking standard (0.25 spaces per unit as opposed to 0.75 spaces per unit).


The proposed site development concept provides for a form of development that meets or substantively exceeds the minimum requirements of the existing Residential R8 (R8-3) base zone variation. It is worth noting that the 4.8 metre interior side yard setback advanced in the proposal represents a single point of the easterly portion of the building face that, as the building face continues north on the site, increases to an interior side yard setback of 15 metres (Figure 1). The proposal seeks some flexibility with the 4.8 metre interior side yard, requesting a 4.0 metre minimum interior side yard. The substantive rear yard setback of 21 metres serves to mitigate any potential land use impacts on abutting properties to the north.

A Bonus Zone is sought through the proposal to permit a density of 100 units per hectare in return for an affordable housing development that promotes and is supportive of: energy efficiency and conservation; greenhouse gas emission reductions; barrier-free and universal accessibility; and public transit.

The Site is also located in convenient walking distance of open space opportunities and goods and services required on a daily or weekly basis. The proposal provides for “inward and upward” residential intensification at an appropriate location. And, the proposed site development concept advances a parking standard that is in keeping with parking standards historically representative of the needs of an affordable housing development.

A reduced bicycle parking standard is also sought. In advancing this standard, HDC would note the tendency of tenants to want to park/store their bicycles within their own dwelling unit and the convenience offered by the proposed built form to do so, and the proximity of the subject lands to public transit, open space, schools and shopping.


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To facilitate a future Site Plan Approval process, a holding zone is appropriate. Accordingly, a holding Residential R8 Bonus “h-5●R8-3●B(_)” Zone is sought, whereby:

• the holding zone would require a future site plan review and approval process; • the Special Provisions to the Bonus Zone would provide for an east interior side yard of 4

metres, a vehicular parking rate of 1:1 and a bicycle parking rate of 0.25:1; and, • a Bonus Zone providing for 100 units per hectare is provided in return for an affordable

housing development that: includes enhanced and functional common open space; promotes energy conservation and greenhouse gas emission reductions; is barrier-free accessible; and, supportive of the use of public transit.

The requested zone would be consistent with, and serve to implement, the MFMDR, Housing, and Bonusing policies of the City of London 1989 Official Plan.

7.4. Conclusions related to the Provincial Policy Statement, the 1989 Official Plan and the Z.-1 Zoning By-law:

The Provincial Policy Statement is a consolidated statement of government policies related to land use planning in Ontario. It gives provincial direction on key land use planning issues that affect communities such as, but not limited to, the provision of sufficient affordable housing to meet changing needs (including affordable housing) and the efficient use of land and infrastructure. The development proposal has been shown to be consistent with, and serving to implement, the policies of the Provincial Policy Statement, 2020.

The policies of the Multi-Family Medium Density Residential designation, and the City’s Housing and Bonusing policies, serve to contemplate the use, intensity and form of development being advanced through the development proposal. The standard test applied to the activation and implementation of these policies is that the use, intensity and form of development must be sensitive to, compatible with, and a good fit within the existing surrounding neighbourhood. HDC’s Planning Impact Analysis, Neighbourhood Character Statement and Compatibility Report demonstrate that the proposal meets the required standard and adds value to the neighbourhood.

The regulations of the Residential R8 (R8-3) Zone variation serve to ensure that the subject lands are of a sufficient size and configuration to provide for the intensity of the use and the built form. As demonstrated above, no relief from the requirements of the Residential R8 (R8-3) Zone variation are required. In fact, the proposal would serve to advance development standards that far exceed the existing minimum requirements of the zone. While special provisions to provide for alternative parking rates are required, HDC would respectfully suggest that the proposed built form and locational attributes of the Site (relative to public transit and supportive and complimentary land uses) serve to underpin and demonstrate the planning merits of the requested standard. HDC would further submit that the requested standards are more in keeping with the demands typically associated with affordable housing.


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7.5. The London Plan: The London Plan, while adopted by Council, remains under appeal. Given that the policies of the London Plan are not currently in force and effect, the proposed development is not presently required to comply with the policies of the Plan.

1_-16_ReThinking London:

The London Plan identifies a number of planning challenges that are foundational to the City’s response to how we will grow as a community over the life of the Plan. These challenges include but are not limited to: 77,000 new Londoners; the escalating cost of growth; a growing seniors population; housing affordability; and, climate change.

Development Response: The proposal will serve to increase the supply of “affordable rent” and “market rent” units in London. The subject lands are defined as being within the City’s Urban Growth Boundary and the Built Area Boundary. Activation of a fully serviced vacant Site within these defined structural boundaries would be consistent with the City’s “inward and upward” focus and a compact urban form.

The subject lands are also identified as being within the City’s Primary Transit Area (PTA). The PTA is to be the focus of residential intensification and transit investment within London. As demonstrated through HDC’s Planning Impact Analysis, Neighbourhood Character Statement and Compatibility Report, the proposal provides for an appropriate level of residential intensity on a suitably sized Site that is fully serviced by municipal infrastructure and public transit. 55_, 57_, 58_, 59_ 60_, 61_and 62 Key Directions and Strategies:

In response to the challenges identified above, the London Plan identifies Key Directions and Strategies including:

• Plan for a prosperous city by investing in affordable housing and pursuing cost-efficient growth patterns;

• Celebrate a culturally rich city by developing affordable housing that attracts a diverse population;

• Become one of Canada’s greenest city’s by managing growth, promoting sustainable forms of development;

• Build a mixed-use city by planning for infill and intensification of various types and forms to take advantage of existing services and facilities to reduce our need to grow outward. Ensure a mix of housing types within neighbourhoods so that they are complete and support aging in place;

• Create active mobility choices such as walking, cycling, and transit to support safe, affordable and healthy communities;

• Build strong, healthy neighbourhoods by providing housing options and integrating affordable forms of housing in all neighbourhoods; and,

• Make wise planning decisions by ensuring that new development is a good fit within the context of an existing neighbourhood.


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The following comments are offered in response to the Key Directions and Strategies identified above:

• The proposal provides for the activation of a fully serviced Site for the purpose of an affordable housing development that will be accessible to all Londoners, both newcomers and current residents;

• The development proposal is sustainable and activates a vacant, fully serviced Site located within the City’s Built Area Boundary and Primary Transit Area;

• The development proposal will add to the mix of built forms and housing types within the neighbourhood;

• Activation of the Site will serve to encourage, promote and sustain the neighbourhoods active mobility infrastructure including the sidewalks, delineated on-road bicycle lanes and public transit;

• The proposal will introduce a new mixed-affordability housing model into the neighbourhood that integrates “affordable rent” and “market rent” dwelling units under the same roof; and,

• The proposed site development concept has been shown to be sensitive to, compatible with, and a good fit within the existing surrounding neighbourhood.

79_ The London Plan places an emphasis on growing inward and upward. Residential intensification will be supported through infill development of vacant and underutilized lots.


The proposal is consistent with the City’s desire to grow inwards and upwards and will capitalize on a residential intensification opportunity through an infill development on vacant, underutilized lands.

83_It is a target of this Plan that a minimum of 45% of all new residential development will be achieved in the Built-Area Boundary of the City.


The proposal activates vacant lands within the City’s Built-Area Boundary for a residential development.

83_ Intensification will only be permitted in appropriate locations and in a way that is sensitive to the existing neighbourhood and represents a good fit.


The HDC’s Planning Impact Analysis, Neighbourhood Character Statement and Compatibility Report demonstrate that the proposal adds value to the neighbourhood and provides for a use, intensity and form of development that is sensitive to, compatible with, and a good fit within the existing surrounding neighbourhood.


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90_ The Primary Transit Area will be the focus of residential intensification and transit investment in London.


The vacant Site is located on an identified transit route and is located within the City’s Primary Transit Area.

152_- 161_ The City’s Regeneration policies seek to facilitate intensification within neighbourhoods where it is deemed appropriate and in a form that fits. These policies further seek to maximize the value returned on the investment in civic infrastructure. To this end, the City’s regeneration policies seek to expand the range of housing choices and create opportunities for affordable housing.

Development Response: The proposal to activate vacant, fully serviced lands in the City’s Built-up Area and Primary Transit Area is consistent with, and serves to implement, the regeneration policies of the London Plan.

497_The Homelessness Prevention and Housing policies of the London Plan work to ensure an integrated mixture of affordable and adequate housing options and quality housing is attainable for all Londoners. The policies further promote a choice of dwelling types so that a broad range of housing requirements is satisfied.


The proposal serves to add to the mix of built forms in the neighbourhood and will provide a range of housing affordability by mixing affordable and market rent units in an integrated development.

506_ Subject to the City Structure Plan and Residential Intensification policies in the Neighbourhood Place Type, infill and intensification in a variety of forms will be supported to increase the supply of housing, in areas where infrastructure and transit, and other public services are available and accessible.


The proposal serves to activate fully serviced vacant lands, add to the mix of housing forms, and increase the supply of affordable and market rent dwelling units in an area characterized by extremely low vacancy rates.

523_ Subject to the City Structure Plan and the Urban Place Type policies, surplus public lands will be evaluated for their suitability for the development of affordable housing prior to their consideration for any other use.

Development Response: The proposal serves to activate land previously identified as surplus to municipal needs and transferred to HDC for the purpose of affordable housing.


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916_Our neighbourhoods will include: a diversity of housing choices allowing for affordability and giving people the opportunity to remain in their neighbourhoods as they age if they choose to do so; they will be well connected and enjoy attractive alternatives for mobility; goods and services will be within easy walking distance; and, employment opportunities will be close to where we live.


The proposal advances a housing form and tenure that provides an opportunity to age in place. The subject lands are well connected to a variety of mobility options. HDC’s Spatial Impact Analysis demonstrates the range of goods and services and employment opportunities within an 800 metre radius, 10-minute walking distance of the Site.

918_ Neighbourhoods should be planned for a diversity and mix and should avoid the broad segregation of different housing types, intensities and forms.


The proposal will add to the mix of built forms in the neighbourhood and will serve to integrate a mix of affordable and market rent dwelling units integrated within the same development.

Table 10/Table 11 - The subject lands are located within the Neighbourhood Place Type (Figure 11) and enjoy frontage on a Neighbourhood Connector. Permitted uses in the Neighbourhood Place Type with frontage on a Neighbourhood Connector include: single detached, semi-detached, and duplex dwellings; townhouses; triplexes; and, small-scale community facilities. A maximum built height of 2.5 storeys is permitted by policy in the Neighbourhood Place Type at this location.


The Multi-Family Medium Density Residential designation of the City of London 1989 Official Plan and the existing Residential R8(R8-3) Zone variation provide for a low-rise, four-storey apartment building. The request to amend the existing Residential R8 (R8-3) is simply required to increase the density from 65 units per hectare to 100 units per hectare, provide for a reduced east interior side yard, and recognize reduced standards for vehicular and bicycle parking. No relief from the permitted height of 13 metres in the existing Residential R8 (R8-34) Zone is required or sought.

The London Plan would not permit a use, intensity and built form that is currently anticipated by the 1989 Official Plan and implemented through the existing Z.-1 Residential R8 (R8-3) Zone. This “disconnect” is not unique to the subject lands and is equally applicable to the low-, mid- and high-rise developments that currently exist along the Baseline Road West frontage, both east and west of the subject lands.

A site-specific amendment to the Neighbourhood Place Type of the London Plan is required to provide for the requested four-storey built form and low-rise apartment building use.

Interestingly, no amendments is required to provide for the requested density of 100 units per hectare.

937_ /938_ Residential intensification is fundamentally important to achieve the vision and key directions of the London Plan. Intensification within existing neighbourhoods will be encouraged to help realize our vision of aging in place, diversity of built form, affordability and the effective use of land in neighbourhoods. However, such intensification must be undertaken to add value to


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neighbourhoods rather than undermine their character, quality, and sustainability. Intensification proposals should be appropriate for the receiving neighbourhood and represent a good fit.

Residential intensification means the development of a property, site or area at a higher residential density than currently exists.


The proposal to activate a vacant, fully served lot in an established residential area characterized by a mix of low-, medium- and high-density residential built forms with an infill development will serve to complete the street and add value to the neighbourhood.

HDC’s Planning Impact Analysis, Neighbourhood Character Statement and Compatibility Report demonstrate that the use, intensity and form of development is appropriate given the size and configuration of the Site and is contextual given the existing surrounding neighbourhood.

949_/953_ Residential intensification proposals will require site plan approval. The City Design policies of the London Plan will apply to all intensification proposals. Compatibility and fit will be evaluated based on such matters as: site layout; building and main entrance orientation; and, height transitions. The intensity of the proposed development will be appropriate for the size of the lot such that it can accommodate such things as driveways, adequate parking in appropriate locations, landscaped open space, outdoor residential amenity area, adequate buffering and setbacks and garbage storage areas.


Prior to submitting the proposal, HDC consulted with the City’s Urban Design and Development Services staff, including extensive consultation with Engineering and Current Planning staff. These discussions served to inform our performance standards, the building location and orientation, and the spatial arrangement of supporting site elements shown on the proposed site development concept included with this submission. HDC’s conceptual plan serves to demonstrate the ability of the subject lands to accommodate the level of residential intensity being sought AND provide for enhanced landscaped open space and residential amenity areas AND provide for substantive interior and rear yard setbacks to facilitate privacy and enhanced buffering elements AND provide for sufficient parking in an appropriate location.

1729_Notwithstanding the other land use policies contained in this Plan, policies for specific areas may be applied where the applicable place type policies would not accurately reflect the intent of Council with respect to a specific site or area. The adoption of policies for specific areas may be considered in limited circumstances where the following conditions apply:

• The proposal meets all the other policies of the Plan beyond those that the specific policy identifies;

• The proposed policy does not have an adverse impact on the integrity of the place type polices or other relevant parts of the Plan;

• The proposed use is sufficiently unique and distinctive such that it does not establish an argument for a similar exception on other properties in the area;

• The proposed use cannot be reasonable altered to conform to the policies of the place type; and,

• The proposed policy is in the public interest and represents good planning.


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A site-specific policy to permit the development of a four-storey, low-rise apartment building meets the five tests of the London Plan, as identified above, including:

• The proposal serves to address two of the primary challenges identified in the London Plan – housing affordability and the escalating costs associated with growth that is not inward and upward. The proposal serves to address the Key Directions identified in Council’s Strategy and activate multiple directions to address housing affordability and the wise and efficient use of land and infrastructure. The proposal serves to a activate a vacant, fully serviced underutilized lot in an established built up area with a use, intensity and form of development that is a good fit given the size and configuration of the lot and contextual with surrounding land uses. And, the requested Bonus Zone also serves to provide for a public benefit identified through policy.

Furthermore, and as previously noted above, the implementation of a site-specific policy to permit the development of a four-storey, low-rise apartment building serves to carry forward and recognize the existing Multi-Family Medium Density Residential policies of the 1989 Official Plan (that anticipate low-rise apartment buildings for the Site) and the regulations of the implementing Residential R8 (R8-3) Zone variation of the Z.-1 Zoning By-law which permits a maximum built height of 13 metres and a density of 65 units per hectare (or 100 units per hectare subject to policy).

• The purpose and effect of the site-specific amendment is to carry forward the existing land use policies of the 1989 Official Plan and provide for an affordable housing development on a vacant, fully serviced lot in an established, built-up neighbourhood. The site-specific amendment would not impact the integrity of the Neighbourhood Place Type.

• The site-specific amendment would provide for the development of vacant surplus municipal lands transferred to HDC to advance an affordable housing development. The proposal and the proposed site development concept contained herein serve to advance a mixed-affordability housing model. The proposal is sufficiently unique and distinctive and would not establish an argument for similar exception on other properties in the area.

• The use, intensity and form of development provided for within the proposal is consistent with, and serves to implement, the “Our Strategy”, “Our City” and the “Homelessness Prevention and Housing” policies of the London Plan. These policies and the proposal function collaboratively and collectively serving to promote, encourage and facilitate land use and infrastructure efficiencies, housing affordability, and residential intensification that is appropriate, contextual and adds value to the receiving neighbourhood. To alter the proposal to conform to the policies of the Neighbourhood Place Type would not be in keeping with the larger policy framework of the London Plan and would not represent good land use planning.

• The proposed amendment serves to advance a mixed income affordable development in an area where vacancy rates are extremely low and where the locational attributes of the subject lands (proximity to a range of complimentary and supportive land uses and transportation options) serves to enhance the value and viability of the proposal. The proposed policy is in the public interest and represents good land use planning.


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1638_ The City of London may use bonusing to provide for an increase in height and density than would otherwise be permitted in the Zoning By-law in return for the provision of such facilities, services and maters that are identified in the bonus zone. Under Type 2 Bonusing, additional height and density may be permitted in favour of affordable housing.


The policies of the London Plan, unlike the City’s 1989 Official Plan, do not regulate density but rather the height of the proposed development. The proposed four-storey, low-rise apartment building would exceed the maximum height restrictions for the Neighbourhood Place Type at this location. In pursuing the additional height sought, the proposal seeks to advance a mixed-affordability housing development wherein a minimum of 30% of the total unit count will be offered at “affordable rent”.

As noted previously in this PJR, the CMHC’s 2020 City-wide private apartment vacancy rates for London for one-bedroom, two-bedroom and three-bedroom units is identified as 1.9%, 1.6% and 1.4%, respectively. In the grouping of neighbourhoods collectively identified by the CMHC as the “Southwest”, private apartment vacancy rates for one-bedroom, two-bedroom and three-bedroom units is identified as 0.9%, 1.3% and 1.9%, respectively. The proposal provides for housing affordability in an area of the City which is experiencing an affordability challenge.

The proposal is consistent with, and serves to implement, the Bonusing policies of the London Plan.

7.6. Conclusions related to The London Plan: The proposed site-specific Official Plan Amendment has been shown to be consistent with, and serving to implement, the “Our Strategy”, “Our City” and the “Homelessness Prevention and Housing” policies of the London Plan. These policies and the proposal function collaboratively and collectively; serving to promote, encourage and facilitate land use and infrastructure efficiencies, housing affordability, and residential intensification that is appropriate, contextual and adds value to the receiving neighbourhood.

The proposal has also been shown to be consistent with, and serving to implement, the Specific Area and Bonusing policies of the London Plan.

In conclusion, this Planning Justification Report demonstrates that the requested actions are consistent with, and will serve to implement, policies of the Provincial Policy Statement 2020, the City of London 1989 Official Plan and the London Plan (as amended). The requested actions are appropriate and represent sound land use planning.

This Planning and Justification Report was prepared by Housing Development Corporation, London and is hereby submitted to the Corporation of the City of London as a requirement of a complete Official Plan and Zoning By-Law Amendment application.

Prepared and submitted by:

_________________________________ ________________________________ Kimberly Wood, MAATO, C. Tech. Brian Turcotte, HBES, Plng. Development Manager, HDC London Development Manager, HDC London


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Appendix A – Proposed Site Development Concept (Expanded to include surrounding area)


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Appendix B – Figure 1: UTRCA Limits related to the Subject Lands

Appendix B – Figure 2: Preliminary Grading and Servicing Plan

Documents

122 BASELINE ROAD WEST, LONDON · 520 Wellington Street, Unit #7 | London ON N6A 3R2 | ph: 519-930 -3512 | . PLANNING JUSTIFICATION REPORT . 122 BASELINE ROAD WEST, LONDON