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THE SALVATION ARMY PROPOSAL BREAKING THE RULES TO BREAK THE COMMUNITY

CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL


AT 333 MONTREAL ROAD.

Vanier Zoning and By-Laws Committee1

TABLE OF CONTENTS

Executive Summary ............................................................................................................................................... 2


Salvation Army Planning Rationale ........................................................................................................................ 3
Implications under the Planning Act & City of Ottawa Official Plan (2003) ............................................................ 3
A. The Orderly Development of Safe and Healthy Communities ........................................................................4
B. The Adequate Provision of a Full Range of Housing ........................................................................................6
C. The Protection of the Financial and Economic Well-Being of Communities. ..................................................8
Implications under the City Zoning By-laws ......................................................................................................... 10
A. Restrictions on Main Streets .........................................................................................................................10
B. Restrictions in Placements ............................................................................................................................14
C. Separation Distance Between Shelters .........................................................................................................16
D. Maximum Four Shelters in Ward 12 .............................................................................................................18
Case Law .............................................................................................................................................................. 20
Summary of Proposal Breeches of City Policies and By-Laws ............................................................................... 21
Conclusion ........................................................................................................................................................... 21
ANNEX A: Planning Act: 2014 Provincial Policy Statement ................................................................................ 22
ANNEX B: City of Ottawa Official Plan ................................................................................................................. 23
ANNEX C: Zoning By-law 2008-250 Consolidation ............................................................................................... 24
ANNEX D: City of Ottawa Reports ........................................................................................................................ 25
ANNEX E: Low Income Support Services and Housing Options in Vanier .............................................................. 26
ANNEX F: Graphic Representation of the Shelters in Vanier ................................................................................ 27
ANNEX G: Vanier Zoning and By-Laws Committee ............................................................................................... 29
ANNEX H: Media & Communications Lines .......................................................................................................... 30
About the author: ................................................................................................................................................ 31

1
The Vanier Zoning and By-Laws Committee Chair is Peter Kucherepa, Barrister & Solicitor. Members listed in Annex G. The author rendered
this report under his own volition. The report reflects personal research and does not reflect the interests, positions or policies of his
employer(s), any level of government nor organizations to which the Chair or any members are affiliated, or not. Mr. Kucherepa can be
reached at . The author acknowledges the support from community organizations and individuals, including Councillor
Mathieu Fleury for support and information.
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 2

Executive Summary

The Salvation Army proposal to locate a mega shelter at 333 Montreal Road is in conflict with laws and
policy principles outlined in the Ottawa Official Plan, city planning reports on shelters, and the city
zoning by-laws. As a consequence, it is recommended that the City of Ottawa not accept the planning
rationale provided nor provide non-confirming rights for this development to occur at the proposed site.

First, the proposal violates the City of Ottawa Official Plan as the shelter accommodation is not
designed in a manner compatible with the general area. If the shelter proposal violates key tenets of
the plan, including the Montreal Road District Secondary Plan, and jeopardizes economic diversity and
development in Vanier. This provides a compelling community objection to the proposed development

Second, the proposal violates all shelter zoning regulations in the city. The proposal is seeking an
exception to the rule that shelters are not permitted on Traditional Mainstreets. The reasons outlined in
the Salvation Army proposal only benefit the proposal itself, not the main street community.
Furthermore, given the existence of other shelters in Ward 12, abiding by the city definition of shelter
the proposal exceeds both the maximum number of shelters and the shelter minimum distance rules.

The applicants proposal is in direct and blatant violation of the city shelter rules and community
planning principles. As such, the City of Ottawa should not provide a positive recommendation to the
Salvation Army proposal.

A memorable maxim of Lord Denning, perhaps the greatest English judge of the century, is that where
there is a rule there is a remedy; the most equitable remedy in this scenario is a denial of the
application, and not permitting exceptions to the rules. Any decision to the contrary provides a clear
cause of action for appeal to the Ontario Municipal Board.
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 3

Salvation Army Planning Rationale

The Salvation Army is proposing to build one of the largest shelter facilities in Canada at 333 Montreal
Road.2 The planning rationale for the proposal includes the construction of a new 9,600 square metre
facility that will offer temporary residential accommodations including short term emergency
accommodation for those who are homeless.3 This proposal includes 140 emergency shelter beds and
210 beds for a variety of uses, including addiction programs and longer term social housing.4 Of
these 210 beds, 38 are considered overflow if the 140 emergency shelter beds prove insufficient to
meet demand.5 In all, this 350 bed facility is seven times larger than the average shelter size in Canada,
creating, in effect an unprecedented super shelter. 6

The applicant acknowledges that the proposed development includes a shelter but caveats that it
consists of innovative services and holistic approach that go beyond the traditional definition of a
shelter.7 However, as the facility includes a shelter the facility, as a whole, attains the clear legal
definition of a shelter. 8

The applicant further seeks a single zoning exception for this development, that is the rule that does
implicitly permit shelters may be located on Traditional Mainstreets in accordance with City of Ottawa
Zoning By-law Policy 4 of Section 3.1. 9

Implications under the Planning Act & City of Ottawa Official Plan (2003)

The Planning Act10 policy interpretation note outlines a fiduciary responsibility for the City of Ottawa to
undertake planning considerations that ensure strong and healthy communities. 11

The Ottawa Official Plan outlines overall land use policies to achieve healthy, sustainable, inclusive
communities while retaining and enhancing downtown cores so as to achieve a vibrant yet safe
downtown - one which is economically and socially healthy.12 The Plan provides guidance to the City of
Ottawa to ensure that development projects and policy decisions have a generally positive effect on the
communities in which they impact. This means that policy decisions must enable the sustainable socio-
cultural and economic fulfillment of the concerned communities while further ensuring sustainability.13

2
City of Ottawa. Salvation Army New Facility Development Application - Montreal Road http://ottawa.ca/en/city-hall/public-
engagement/planning-and-infrastructure/salvation-army-new-facility-development-application-montreal-road
3
Salvation Army Proposal (Planning Rationale) 333 Montreal Road. June 13, 2017. [Salvation Army Proposal] See.
http://webcast.ottawa.ca/plan/All_Image%20Referencing_Site%20Plan%20Application_Image%20Reference_2017-06-
20%20Planning%20Rationale%20D07-12-17-0077.PDF
4
Ibid.
5
Ibid.
6
The National Shelter Study reports that the average size of a homeless shelter in Ontario constitutes 51 beds. See: Aaron Segaert,
Homelessness Partnering Strategy: The National Shelter Study: Emergency Shelter Use in Canada 2005-2009. Homelessness Partnering
Secretariat. Human Resources and Skills Development Canada 2012. It is also larger than the Montfort hospital
http://homelesshub.ca/sites/default/files/Homelessness%20Partnering%20Secretariat%202013%20Segaert_0.pdf
7
Supra, Salvation Army Proposal
8
Supra. Ottawa Official Plan. See section entitled Separation distance between shelters for a clear legal definition of a shelter in accordance
with city of Ottawa by-laws.
9
Supra. Salvation Army Proposal, P. 3, P.22
10
Planning Act, R.S.O. 1990, c. P.13 https://www.ontario.ca/laws/statute/90p13
11
Provincial Policy Statement Under the Planning Act. 2014. [Planning Act Guidelines] Part V. Ministry of Municipal Affairs and Housing
Provincial Planning Policy Branch. http://www.mah.gov.on.ca/AssetFactory.aspx?did=10463
12
City of Ottawa. Report to Planning and Environment Committee and Council 22 May 2008 Submitted by: Nancy Schepers, Deputy City
Manager, Planning, Transit and the Environment Urbanisme [City Report, 2008]. Ref N: ACS2008-PTE-PLA-0011 Source :
http://ottawa.ca/calendar/ottawa/citycouncil/ec/2008/06-10/ACS2008-PTE-PLA-0011.htm
13
The Official Plan is one of the most important tools a City has to demonstrate a commitment to sustainability. This plan has sustainability as
its primary goal where sustainable development is defined as development that meets the needs of the present generation without
compromising the ability of future generations to meet their own needs.
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 4

The plan further includes a policy interpretation note by city of Ottawa officials (2008) (City Report),
concerning policies regarding shelter locations within the city.14

A. The Orderly Development of Safe and Healthy Communities

Municipal Policy & Principles

The Planning Act guidelines outline that the City of Ottawa must avoid
development and land use patterns which cause public health and
According to a City Report,
safety concerns.15 the proposed site is likely to
increase drug trafficking,
The Guiding Principles of the Official Ottawa Plan, present that the drug abuse, and illegal acts
object of the plan is to provide the orderly development of safe and near shelters. A proposed
healthy communities.16 A fundamental policy objective of the act is mega shelter will only
that a clean and healthy environment and a strong economy are increase this problem while
inextricably linked to strong communities. 17 making existing shelters
less effective, resulting in
higher enforcement and
Regarding community safety, the City Report notes that a
social costs to the city.
concentration of shelters increases drug trafficking, drug abuse, and
illegal acts as they occur adjacent to the shelters.18 The report further
provides that a concentration of negative impacts, worsens the health
and safety situations of both the homeless and at-risk, as well as
increases safety concerns of the residents, particularly in communal areas, such as streets, sidewalks,
stores, parks and schools. 19

Salvation Army Proposal

The Salvation Army proposal acknowledges the issue of public safety of shelters.20 However, it attributes
the safety risk to a perceived over-concentration of social services within Ward 12 and, more
particularly, the current distribution of shelters, drop-in centres, and residential care facilities within the
ward.21 As such, it attempts, ineffectively, to argue, that building the facility at the proposed site at 333
Montreal Road would reduce negative safety impacts to the community. The proposal would introduce
350 men, many with mental health and addiction problems, into the centre of a residential community.

The proposal further admits that the facility provides no security off-site; beyond police involvement no
processes are suggested to ensure the safety of the community22. No security is outlined be provided
for Montreal Road frontage.

Concerning community health, the proposal further implies that an additional shelter in Ward 12 will
result in greater community health, specifically, highlighting that it will provide housing and support for
some of the most vulnerable members of the community.23
14
Ibid.
15
Supra, Planning Act Guidelines. Part V. P.6. See also The Role of the Official Plan. http://ottawa.ca/en/node/1009710#1-1-role-official-plan
16
Ottawa Official City Plan. Section 1 - http://ottawa.ca/en/node/1009710
17
Supra, Planning Act Guidelines
18
Supra, City of Ottawa Report, 2008
19
Ibid.
20
Supra, Salvation Army Proposal. P. 26.
21
Ibid.
22
See Salvation Army Information Site www.333montrealroad.ca. FAQ section.
23
Ibid.
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 5

Analysis & Implications

The Salvation Army proposal would not advance health and safety in Vanier. It deviates from the policy
objectives of public health and safety of the Vanier Community under both the Planning Act and the City
Official Plan.

The proposal would very likely increase crime levels in an area that already a higher crime rate per
capita than most other communities in the city. The introduction of a very large number of high-risk,
vulnerable people into the proposed location would undoubtedly increase the risk of spill over into
the broader Vanier community. This would increase issues such as prostitution, vagrancy, drug
trafficking and use, personal and property crime, petty crime, pan handling, as troubled people commit
crimes to finance their addictions and life-style. All of this would be compounded by the sheer size of
the super shelter facility proposal.

It is respectfully submitted that it is not a concentration of shelters that correlates to high crime areas,
but the existence of shelters in sensitive economic areas, which results in higher crime. The proposed
site is adjacent to a plethora of pay-day loan centers, pawn shops and marijuana dispensaries,
proliferating crime and reducing community health and wellness.24 Further, the proposed site is on a
Mainstreet, thereby increasing passing pedestrian engagement in crime related activities. According to
City of Ottawa Police crime trends, the overall crime rate of Ward 12 Rideau-Vanier has increased 11% in
2015-16.25

The proposal will also negatively affect pre-existing community support services in Vanier. A
proliferation of low income persons in an already economically sensitive area would negatively affect
the rehabilitation prospects of people already in existing shelter facilities. There are 25 low income /
affordable housing facilities that serve 386 residents in Vanier to address social challenges (see Annex
E). Exposing these 386 residents to additional risk factors of drug availability and addiction influences,
money laundering opportunities (via payday loan centers), and crime facilitators is not constructive to
on-going rehabilitation services.

In fact, a 2006 study by the City of Ottawa provides that studies exist which indicate that at-risk
populations are able to function more effectively and integrate more successfully into their communities
when they are housed in smaller units in dispersed areas, rather than concentrated into large buildings
in a limited number of neighborhoods. 26 It further provides that the risk of relapse into addictive and
other difficult behaviors is reduced when clients are not grouped together in large numbers.27 As such,
the proposed site actually reduces the capacity for the Salvation Army to achieve its mandate and
further negatively affects other nearby shelters and support services in achieving their objectives.

In summary, the Salvation Army proposal did not consider the impact of a mega shelter on community
safety. Furthermore, the Salvation Army proposal erred in holding that an addition of a mega-shelter, in
an area which already contains a proliferation of shelters and support services, would not contribute to

24
Peter Kucherepa. Municipal Policy Options to Address the Proliferation of Payday Loans and other Predatory Lenders in Ottawa. 2016. The
paper provides that a concentration of payday loan centers increases the propensity of local crime.
https://www.dropbox.com/s/kxboph19g6bzt8z/Pay%20day%20Loan%20Paper%20V15.pdf?dl=0
25
Ottawa Police 2015 - 2016 Crime Trends Ward 12 - Rideau-Vanier https://www.ottawapolice.ca/en/annual-
report/resources/Crime_Stats/Ward_12-Rideau-Vanier.pdf
26
City of Ottawa Planning and Environment Committee. Regulation of Special Needs Housing in Rideau-Vanier. 28 Aug. 2006. Ref N: ACS2003-
CCS-PEC-0011 [Shelter Separation Distance Report] http://ottawa.ca/calendar/ottawa/citycouncil/pec/2006/09-12/ACS2006-CCS-PEC-
0011.htm
27
Ibid.
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 6

the orderly development of a safe and healthy community. This


project would drastically increase costs for community social
services, by-law enforcement, security and policing.
Vanier has double the social
and affordable housing
Recommendation
options than other areas of
Ottawa. A mega shelter will
It is recommended that the Salvation Army not be permitted to only further ghettoize the
proceed with the project of siting a shelter at 333 Montreal Road community.
because their doing so would negatively affect security and
safety and would negatively affect the social well-being of the
community.

B. The Adequate Provision of a Full Range of Housing

Municipal Policy & Principles

Under the Planning Act guidelines, the City of Ottawa must consider the well-being of the municipality,
in accommodating an appropriate range and mix of residential and institutional spaces to meet long
term needs.28

The Official Plan further outlines an objective to ensure a wide range of affordable housing into all
neighborhoods to meet the varied needs of the community housing policies support increased
availability of affordable housing and address the integration of a range of housing into all
neighbourhoods to meet the varied needs of all household types including families, seniors and young
people.29

This principle contains two main policy objectives: first to ensure an equitable distribution of shelters
across the city of Ottawa, reducing a proliferation in low income areas, and second to ensure that any
development has a positive impact upon the needs of individual communities.

A 2006 City of Ottawa Study found that Ward 12 contains the highest concentration of homeless
shelters, the most Ottawa Community Housing Centers and the most confirmed rooming houses with
the lowest average income.30 In fact, the report adds Rideau-Vanier has an excessive concentration of
special needs housing, rooming houses (both legal and illegal), halfway houses, soup kitchens, shelter
accommodations which in turn exacerbates a host of social problems.31

According to the City Report, a proliferation of shelters lowers health and safety of both the homeless
and those at risk, undermining the reformation objectives of individual pre-existing shelters.32 The
policy objective of reducing the number of shelters in Ward 12 is to permit a more equitable distribution
of shelters, group homes, community health and resource centers, and residential care facilities.33
According to the City Report, a concentration of social services leads to fewer positive impacts for both
residents as well as for those seeking the social service.34

28
Supra, Planning Act Guidelines. Part V. P.6
29
Ibid. See also See also The Role of the Official Plan. http://ottawa.ca/en/node/1009710#1-1-role-official-plan
30
Supra, Shelter Separation Distance Report
31
Ibid.
32
Supra, City of Ottawa Report, 2008
33
Ibid.
34
Ibid.
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 7

As the proposed site is on Montreal Road, the border of Vanier North and Vanier South, the following
table provides comparative charts of housing options in Vanier (North and South) as compared to the
remainder of the city.35

Vanier Vanier City


Table 1: OTTAWA NEIGHBOURHOOD STUDY
North South Average
HOUSING Number of social and affordable
546 501 229.4
housing units
Number of social and affordable
63.7 67.6 24.4
housing units per 1000 people
Number of domiciliary hostels 2 0 0.3
Number of domiciliary hostels per
0.2 0 0
1000 residents
Number of Rooming Houses 3 0 1.4
Number of Rooming Houses per 1000
0.3 0 0.1
residents
INCOME Percent of total population living in
22.1 25.8 11.6
low income
Percent of population aged 18-64
23.6 24.5 11.6
living in low income
OWNERS Percent of owner households 40 29.1 67.3
Percent of tenant households 59.9 71 32.7
MOTHER Percent English 46.1 38.2 62.4
TONGUE Percent French 36.9 40.6 14.2

Vanier, as a whole (both North and South), contains nearly double the city average in number of social
housing availabilities, almost three times the number of affordable housing unit, three times more
rooming houses, and double the tenants, than the city averages. Furthermore, the percent of low
income residents is double the city average. As such, Vanier contains a disproportionate amount of
affordable city housing options.

The following above statistics on pre-existing housing conditions demonstrates that any additional low-
income housing or shelter options in Vanier will further derogate Vanier from attaining city averages on
affordable housing options.

Salvation Army Proposal

The Salvation Army Proposal provides detailed information of emergency housing solutions, including
emergency accommodation, state-of-the-art housing facilities, day programs, and services to serve the
most vulnerable families and individuals in our community.36

Analysis & Implications

The proposal does not address the concentration of low income housing in the targeted community of
Vanier. The Salvation Army proposal would concentrate low income residential facilities in Vanier, not
attain a diversification of affordable housing options that support community needs. The Salvation Army
proposal clearly contradicts the policy objectives of the Planning Act and Ottawa City Plan as regards
diversity of affordable housing options in Vanier.

35
Ottawa Neighbourhood Study. Vanier North and Vanier South. http://neighbourhoodstudy.ca/vanier-north/ and
http://neighbourhoodstudy.ca/vanier-south/
36
Supra, Salvation Army Proposal. P.22
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 8

The Salvation Army proposal does not pursue a strategy aimed at a variety of housing, but the opposite.
It concentrates low income housing options in one community that already exceeds city low income
housing averages. It is evident that the proposal will concentrate low income housing options (i.e.
shelters), clearly deviating from the policy objectives of the 2008 City Report. This will result in negative
impacts on Vanier, not fitting with the needs of the community. A concentration of social services
undermines constructive social development planning and good use principles for social services. An
undue concentration creates a ghettoization of low income services creating negative impacts for
the Vanier community.

Limiting the diversification of housing in Vanier reduces the overall quality of housing stock in Vanier. A
concentration of low income housing options creates a subpar housing stock, limits mature renters,
condominium development and the castrates gradual improvement of the community.

In summary, the Salvation Army proposal does not meet the city housing policy objectives of
diversification and, as a result, low income housing options will not be dispersed across Ottawa, but
rather be concentrated in Vanier. The proposal will not attain community integration principles and
negatively affects the Vanier housing stock hampering long term development.

Recommendation

It is recommended that the Salvation Army not be permitted to proceed with the site selected at 333
Montreal Road as the proposal would not serve the Vanier communitys needs but rather deepen the
concentration of temporary shelter housing in Vanier, thereby ghettoizing the neighborhood and very
negatively affecting long-term housing development.

C. The Protection of the Financial and Economic Well-Being of Communities.

Municipal Policy & Principles

The Ministry of Municipal Affairs and Housing (2011) handbook provides the policy rationale that
housing is one of the most fundamental of human needs, a key driver of shaping the economic and
social sustainability of communities.37 In fact, any municipal housing policy must be relevant to local
circumstances and support economic prosperity.38 Following the Planning Act guidelines, the city must
promote efficient development and land use patterns which sustain the financial well-being of the
Province and municipalities over the long term.39

The Ottawa Official plan further includes an economic strategy to ensure a strong, growing and
diversifying economy while also reflecting the specific needs of the community and the qualities that
make the neighborhoods special in considering change of land use. 40 The City Report provides that the
object of zoning shelters is to regulate land use to mitigate negative impacts, worsening the health and
safety of both the homeless and at-risk, as well as increased safety concerns amongst the residents,
particularly in communal areas, such as streets, sidewalks, stores, parks and schools including loitering
near residential neighborhoods.41

37
Municipal Tools for Affordable Housing (Handbook). Ministry of Municipal Affairs and Housing. Provincial Planning Policy Branch.
Government of Ontario. 2011. http://www.mah.gov.on.ca/AssetFactory.aspx%3Fdid%3D9270
38
Ibid.
39
Supra, Planning Act Guidelines. Part V. P.6. See also The Role of the Official Plan. http://ottawa.ca/en/node/1009710#1-1-role-official-plan
40
Ibid.
41
Supra, City of Ottawa Report, 2008
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 9

The Montreal Road District Secondary Plan provides that decisions should be made that compliment and
improve upon the positive qualities of the existing character of the District.42

Salvation Army Proposal

The proposed development highlights a state-of-the-art facility which would not be a mega-facility but
rather an important community hub that would respond to a broad range of needs of low income
clientele.43

Analysis & Implications

The Salvation Army proposal would undercut efforts to pursue economic development while further not
ensuring the special needs of Vanier are met. The Salvation Army proposed
plan of a shelter at 333 Montreal Road clearly violates key economic
developmental objectives of the City of Ottawa Official Plan (2003) and the
Planning Act. A mega shelter in Vanier
will negatively affect the
The proposed shelter would undercut on-going efforts to diversify the socio-economic
economy, and reduce crime, including prostitution, vagrancy, property and development of the
personal crime and loitering.44 This would deter property investment Vanier community
generally especially higher value investment and would be a disincentive including housing stock,
for mature renters and for young families, two groups who take advantage commercial investment
of Vaniers low real estate-costs and its reasonable proximity to downtown. and economic
The proposed shelter site would add to the pre-existing high volume of development.
shelters and social service providers already located in Vanier, negatively
impacting socio-economic advancement and community development.

The proposed shelter would further have a negative effect on the general economic development of
Vanier. This would reduce meaningful economic investment into a transitioning commercial area.
Quarter Vanier BIA is concerned that the proposed development is not an appropriate anchor business
for Montreal Road.45 Low end business options (e.g., payday loan centers) would be the norm, which
would harm Vanier and deter local visitation and tourism.

In summary, the proposed site plan does not consider the unique and special needs of the Vanier
community in economic and social development. Furthermore, the proposal does not improve upon the
positive qualities of Vanier economic development, but exacerbates poverty and crime. This
development would clearly violate the principles of both the provincial policies and city plans for the
economic development of Vanier.

Recommendation

It recommended that the Salvation Army proposal not be permitted to proceed with the site selected at
333 Montreal Road would not contribute to the financial and economic well-being of the community.
42
Montreal Road District Secondary Plan. http://ottawa.ca/en/city-hall/planning-and-development/official-plan-and-master-plans/official-
plan/volume-2a-secondary-plans/montreal-road-district-secondary-plan
43
Supra, Salvation Army Proposal. P.13
44
This includes efforts to reduce the proliferation of payday loan centers, as authored by Peter Kucherepa, Barrister & Solicitor.
https://www.dropbox.com/s/kxboph19g6bzt8z/Pay%20day%20Loan%20Paper%20V15.pdf?dl=0
45
Michelle Nash Baker. Vanier BIA not happy with Salvation Army's plans to move to Vanier Jun. 23, 2017. Ottawa Community News.
https://www.ottawacommunitynews.com/news-story/7388449-vanier-bia-not-happy-with-salvation-army-s-plans-to-move-to-vanier/. See also
public letter from Quartier Vanier BIA available at http://vanierbia.com/wp-content/uploads/2013/09/Final-w-Letterhead-Salvation-Army-
QVBIA-Statement-July-10.pdf
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 10

The planning rationale does not consider the impact of the proposed development on the provinces
planning and housing objectives or the City of Ottawa Official plan: nor does it appropriately consider
the economic development objectives of the community.

In conclusion, the Salvation proposed project development at 333 Montreal Road clearly violates
primary policy objectives outlined in the Planning Act and the Official Plan, and as such, should not be
permitted at the proposed site.

Implications under the City Zoning By-laws


In 2008, the City of Ottawa updated its zoning bylaws, entitled, City of Ottawa Zoning By-law (2008). It is
an objective, rules based approach that addresses the relocation and movement of shelters in the city. 46
The bylaw update was based on a study undertaken by the City entitled: Rideau-Vanier Ward 12
Interim Control By-Law Study and Zoning By-Law Amendment (City Report) adopted by the Planning
and Environment Committee.47 The City Report serves as an interpretive note regarding the legal and
policy considerations in addressing the placement, management and proliferation of shelters in Ward 12
in compliance with the City Plan. The report provides the guiding principles on effective site placements
of shelters in the city.

The by-laws and City Report, read together, contain several restrictions on placement of shelters in
Ottawa.

A. Restrictions on Main Streets

Municipal Policy & Principles

The interpretive note for the Planning Act provides that long term economic prosperity should be
maintained and, where possible, should enhance the vitality and viability of downtowns and
Mainstreets.48

According to the City of Ottawa Official Plan, shelter accommodation shall be designed in a manner
compatible with the general area.49 The socio-economic policy of a Traditional Mainstreet Zone (TMZ) is
to encourage diverse economic development.50 The policy purpose of a TMZ is to recognize primary
business or shopping areas, as provided and defined by Business Improvement Areas.

Section 3.6.3 of the City of Ottawa Official Plan states that all Mainstreets are intended to function as
mixed-use corridors with the ability to provide a complete range of goods and services for neighbouring
communities and beyond.51 A wide range of uses are permitted within the Mainstreets designation
including retail and service commercial uses, offices, residential and institutional uses. A mix of uses is
encouraged, either within the same building or side by side in individual buildings. 52

46
City of Ottawa Zoning By-laws. Section 134 Source: http://documents.ottawa.ca/sites/documents.ottawa.ca/files/documents/pt_05_en.pdf
47
City of Ottawa. Report to Planning and Environment Committee and Council 22 May 2008 Submitted by: Nancy Schepers, Deputy City
Manager, Planning, Transit and the Environment Urbanisme [City of Ottawa Report, 2008]. Ref N: ACS2008-PTE-PLA-0011 Source :
http://ottawa.ca/calendar/ottawa/citycouncil/ec/2008/06-10/ACS2008-PTE-PLA-0011.htm
48
Provincial Policy Statement Under the Planning Act. 2014. Ministry of Municipal Affairs and Housing Provincial Planning Policy Branch.
http://www.mah.gov.on.ca/AssetFactory.aspx?did=10463. P.19
49
Ottawa Official Plan. Section 3 - Designations and Land Use http://ottawa.ca/en/node/1009706
50
Don Butler, Ottawa Citizen "We are trying to make the corridors graduate into true urban avenues, where they become the focal points for
the neighbourhood, not dividers. You can have your daily needs served on the avenue. That's the model.", January 1, 2017,
51
Supra, Salvation Army Proposal P.15
52
Ibid.
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 11

The City of Ottawa Report, 2008 specifically prohibits shelters along those streets in Ward 12, as well as
all streets city-wide, that are designated Mainstreet in the Official Plan.53 The report clearly provides
that the emplacement of shelters is not permitted in the Traditional Mainstreet and Arterial Mainstreet
Zones under the existing former Ottawa and Vanier Zoning By-laws. The proposed site road, Montreal
Road, attains the definition of a TMZ by the City of Ottawa.

The Montreal Road District Secondary Plan outlines key policy objectives for the development of
Montreal Road. 54 The main goal of the plan is to foster development and redevelopment which
compliments and improves upon the positive qualities of the existing charters of the District.55 The plan
includes that buildings fronting Montreal Road will have a maximum height of six stories.56

Vanier is a unique French Quarter community demonstrating special characteristics and having special
needs. According to Table 1 (supra), Vanier contains twice the level of mother tongue French speakers
than the remainder of Ottawa. This has resulted in all commercial and provincial services (i.e. Montfort
hospital) providing French language services. Further, any development and redevelopment should
include building, site design and streetscaping elements which acknowledge the history of the French
Quarter.57

Lastly, Vanier holds a higher level of First Nations population than elsewhere in the city. As a
consequence, any major social development project must address the interests and needs of this
vulnerable population.

Salvation Army Proposal

The proposed location is in direct violation of by-law requirements and as a result the Salvation Army is
seeking an Official Plan Amendment, an exception to the rule. 58 The proposal provides the following
justification for non-compliance exception:

1. Mainstreet use: The proposed site is only 14.96 metres on the Mainstreet and as such the de
mimimus usage is not consequential to the application.59

2. Shelter scope: The Salvation Army proposal is mixed use so it is not only a shelter and as such
will add to the diversity of the TMZ of Montreal Road. 60

3. Height requirements: The proposal acknowledges the building heights maximum of six (6)
storeys, with a minimum building height requirement of two (2) storeys, but also notes greater
building heights may be considered in accordance with the city policies.61

53
City of Ottawa Report, 2008. The use [of shelters] is not to be permitted in the Mainstreets designation in keeping with the Official Plan.
Therefore, the use will not be permitted in the Traditional Mainstreet and Arterial Mainstreet Zones under the existing former Ottawa and
Vanier Zoning By-laws, those streets that are zoned the equivalent of the proposed TM or AM locations in the Comprehensive Zoning By-law
will not be permitted to have a special needs house or shelter abutting Beechwood Avenue, Montreal Road and McArthur Avenue, Rideau
and Dalhousie Streets.
54
Montreal Road District Secondary Plan. http://ottawa.ca/en/city-hall/planning-and-development/official-plan-and-master-plans/official-
plan/volume-2a-secondary-plans/montreal-road-district-secondary-plan
55
Ibid.
56
Ibid.
57
Ibid.
58
Supra, Salvation Army Proposal
59
Ibid. P.16
60
Ibid. P. 15
61
Ibid.
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 12

4. Mainstreet benefits: The proposal argues that a Traditional Mainstreet is most beneficial for a
shelter location given increased activity and visibility, accessibility by pedestrians, and their
proximity to transit and other associated services.62

5. Cultural adaption: The proposal will accommodate the location in Vanier under the Montreal
Secondary Plan as it will include setbacks, building heights and development and
redevelopment in this area will include building, site design, and streetscaping elements that
acknowledge this history.63

Analysis & Implications

The Salvation Army proposal fails to adequate address the policy implications of its development,
misleading the public on the actual implications of its proposal to the city by-laws.

1. Mainstreet use: Notwithstanding the limited amount of frontage, the Salvation Army proposal
undertakes a significant frontage of Montreal Road, as the design excludes the existing Salvation
Army Thrift Store. These buildings, taken together, by the same owner, provide a significant
portion of Montreal Road in comparison to other retailers.

2. Shelter scope: The Salvation Army proposal is effectively moving a shelter location from
downtown to Vanier, and then increasing the shelter size to mega shelter. The proposal does
not effectively diversify services to the point of redefining the main purpose of the application,
which is providing (and increasing) shelter services. Furthermore, the proposal does not take
into consideration the pre-existing plethora of shelter and support services in the TMZ area of
Montreal Road and elsewhere in Vanier.64 Thus, the new shelter does not add to or complement
diversity in Vanier, as the region already holds a disproportionate level of support services as
compared to other areas of the City of Ottawa (see Annex E).

3. Height requirements: The plan may be in compliance with the height requirements, however, a
visual inspection of the plans further notes the building may be eight (8) storeys tall in some
places, requiring a full analysis of the building objectives, both short term and long term, as
height adjustments were implied in the proposal.

4. Mainstreet benefits: The Salvation Army justification on the exception sought is based upon the
direct benefits of the proposed shelter, but does not serve the policy objectives of Traditional
Mainstreet planning.

First, the proposed development is not commercial in nature and is incompatible with
permissible planning uses on a Mainstreet. The proposed development does not fit with the
commercial planning objectives of Montreal Road in particular. The Vanier Community is
seeking diverse economic investment, reducing the proliferation of low-end establishments
catering to vulnerable people. Vanier needs commercial or non-commercial entities that pursue
positive socio-economic impacts to the community. This is reflected by the planning and
development objectives of the Quartier Vanier Business Improvement Association. The Vanier
Business Improvement Area has outlined its opposition to the shelter as it is not for a business
or commercial purpose which is congruent with the commercial development objectives of

62
Ibid.
63
Ibid. P. 19-21
64
See Infra.
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 13

Montreal Road.65

Second, the proposal would exacerbate socio-economic concerns outlined in the City Report,
including personal and property crime and loitering in an area of pedestrian traffic and public
transportation, negatively affecting the core benefits of a Mainstreet environment.

Third, the proposal would likely increase traffic and parking problems and burden public
transportation.

The proposed location will increase the volume of emergency vehicles attending
emergencies at the proposed location, up to two vehicles per day.66 This will increase local
disturbance at a rate far higher than expected in a residential area. And it will impede
destination and transit traffic at the entrance to the site, a main arterial road.

The proposed location will receive three trucks vehicles per hour for deliveries in the
morning peak hours. The commercial zone purpose as a truck delivery service on Ste. Anne
Street, Montfort Street and Granville Street will have significant impacts on the residential
community, especially the children and the elderly.67

Under the Montreal Road Redevelopment Plan, Montreal Road will undergo reductions of
parking spaces and bus stops.68 To accommodate the proposed shelter location, parking
spaces would likely further be reduced on Montfort Street to permit trucks to turn at the
intersection of Montreal Road and Grandville St. and the intersection of Montfort St. and
Ste-Anne St.

Twenty-seven spaces would be reserved for employee parking while 62 spaces are actually
needed.69 The 27 spaces include 3 spaces for the outreach vans and ambulance and for 13
for retail visitors.70 Four of these spaces may be unavailable when the facility is receiving
deliveries.

The proposed mega shelter would place additional stresses and challenges on the existing
and planned infrastructure of Montreal Road, undercutting forecasted benefits.

5. Cultural adaptation. Further, the proposed development does not meet the requirements of
the Montreal Secondary Plan which requires that developments compliments and improves
upon the positive qualities of the existing characteristics of the District. Excluding setbacks, the
development application does not provide specifics of any building, site design and
streetscaping elements which acknowledge the history of the French Quarter. Furthermore, the
proposed development does not offer services in French, a key aspect of the culture and
language of the community (see Table 1).

65
Michelle Nash Baker. Vanier BIA not happy with Salvation Army's plans to move to Vanier Jun. 23, 2017. Ottawa Community News.
https://www.ottawacommunitynews.com/news-story/7388449-vanier-bia-not-happy-with-salvation-army-s-plans-to-move-to-vanier/
66
Parsons. Transportation Overview of 333 Montreal Road. [Transportation Study] P.4
http://webcast.ottawa.ca/plan/All_Image%20Referencing_OP%20Amendment%20Application_Image%20Reference_2017-06-
20%20Transportation%20Oveview%20D01-01-17-0013.PDF
67
Ibid.
68
Montreal Road Transportation Planning and Functional Design Study. Public Open House. March 9, 2017.
https://documents.ottawa.ca/sites/documents.ottawa.ca/files/montreal_road_pohboards_en.pdf Montreal Road - reduction of available
parking after the upgrade of the road in 2018 from 173 to 148 - a reduction of 25 spots.
69
Supra, Salvation Army Proposal. P.10 The proposal only includes 10 parking spaces for the Thrift Store.
70
Ibid.
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 14

Furthermore, the proposal does not address the specific needs of the First Nations population in
Vanier.

Recommendation

The proposed non-conforming/compliance amendment by the applicant to permit a shelter on Montreal


Road as a Mainstreet should not be granted by the City of Ottawa. The proposal is in clear violation of
the Mainstreet restriction outlined both in the by-law and the City Report. The Salvation Army proposal
emphasizes positive impacts of the proposed shelter to itself, but negates the positive impact of policy
objectives of the Montreal Road development plan. Further, the proposal requires additional
consideration regarding height requirements, which are somewhat fluid in the proposal. The proposal
does not reflect community culture or serve the francophone or First Nations community. It does not
entail a positive commercial impact to the French Quartier community as a whole (as many service
providers pre-exist). Any amendment to Mainstreet policy must have a positive impact on the economic
development to the community. The proposed application exception does not attain these or other
positive tests and therefore must not be permitted.

B. Restrictions in Placements

Municipal Policy & Principles

The Ottawa Official Plan provides that where the zoning by-law permits a dwelling in areas designated
General Urban Area, Developing Community, Central Area, Mixed-Use Centre, and Village, the bylaw will
also permit shelter accommodation. Shelter accommodation shall be designed in a manner compatible
with the general area. The zoning by-law may include provisions to regulate the size and location of this
use.71

Further, Section 134 of the Zoning By-law Part 5 Residential Provisions provides that where located
within a Minor Institutional Zone, a shelter must be separated from any lot zoned R1, R2, R3 and R4 and
the separation must be a distance of 30 metres from each property line of the lot on which the shelter is
located and the Residentially-zoned lot.72

The City Report restricts shelters in only commercial zones (that are non-Mainstreet and non-Local
Commercial) mixed used and institutional zones.73 This means the shelters that are institutional in
nature should not be placed in residential zones. Further, the report provides, prohibiting residential
care facilities and shelters in all Local Commercial Zones throughout the city as the intensity that is not
compatible with the nature of local commercial uses.74

Salvation Army Proposal

The Salvation Army Proposal provides that the location, at the intersection of a commercial and
residential zone, would increase housing options and intensification of an urban area, although not the
standard forms of residential intensification.75

71
City of Ottawa. Official Plan Volume 1 Section 3. Designations and Land Use. http://ottawa.ca/en/node/1009706
72
City of Ottawa Zoning By-laws. 134. Source: http://documents.ottawa.ca/sites/documents.ottawa.ca/files/documents/pt_05_en.pdf
73
Supra. City Report.
74
Supra. City Report.
75
Supra, Salvation Army Proposal. P. 12-13
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 15

The proposed development would also be based on eight (8) design principles that include creating
spaces that facilitate community interaction, controlling access, providing secure and private outdoor
spaces for clients, and preserving the privacy of surrounding residents.76 The outdoor terraces are
designed to be secure, private, and internal to the site to avoid noise and privacy impacts on the
surrounding residential development.77 The proposal also provides that noise, traffic, parking, outdoor
amenity areas, massing, and loading and servicing on adjacent properties have been mitigated as noted
above through the internalization of many of these items, as well as the use of landscape elements.78

Analysis & Implications

The Salvation Army proposal violates restrictions in commercial placements. The proposed site is further
located in a Local Commercial zone, not compatible with the nature of local commercial uses and
creating a conflict with the intention of the City Report. These area-specific zoning exceptions will result
in a high concentration of social services provided in a very small area, in a residentially-zoned
neighborhood, which entails land use conflicts between these different classifications of land uses.

The Salvation Army proposal requires that the proposed shelter be located in a local commercial zone
where the intensity is not compatible with the nature of the shelter use. Further, the proposal requires a
residential zone adjacent to Montreal Road, be used as a commercial zone purpose. This is significant as
the proposed site will be undertaking activities (i.e. trucking, noise, and traffic) associated with industrial
zones causing significant impacts to quality of life in a residential zone, including substantially increased
traffic disturbance.79 This further raises significant concerns regarding children safety in a commercial
area. The zoning conflict will further limit new residential development in the rear yards of low density
housing along Ste. Anne St. and Grandville St, negatively affecting local residential housing stock.

The report fails to provide the separation distance grades from residential property lines as the
proposed shelter will be border residentially-zoned lots.80

Recommendation

The Salvation Army planning zone application should not proceed on the proposed commercial site as it
is incompatible with the local commercial uses. Second, further investigation and consideration should
be given to the use and application of side streets which will be subject to commercial deliveries in a
residential neighbourhood.

76
Ibid. P. 13-14
77
Ibid.
78
Ibid. P. 19
79
In fact, the Roadway Traffic Noise Assessment of the proposed site recommended certain conditions be included in the Purchase and Sale
Agreement and certain materials to be used to mitigate sound issues.
http://webcast.ottawa.ca/plan/All_Image%20Referencing_Zoning%20Bylaw%20Amendment%20Application_Image%20Reference_2017-06-
20%20Traffic%20Noise%20Assessment%20D02-02-17-0062.PDF
80
City of Ottawa Zoning By-laws. Section 134. Source: http://documents.ottawa.ca/sites/documents.ottawa.ca/files/documents/pt_05_en.pdf
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 16

C. Separation Distance Between Shelters

Municipal Policy & Principles

Under the City of Ottawa by-laws, a shelter is defined as the following:

Shelter means an establishment providing temporary accommodation to individuals who are in


immediate need of emergency accommodation and food, and may include ancillary health care,
counselling and social support services. (refuge) .81

The zoning by-law further provides a clear 500 metres minimum separation area between shelters.

Where it is a permitted use in a zone, in addition to the provisions of the zone in which it is
located, a shelter must be separated from any other lot containing a shelter, a distance of 500
metres from each property line of the lot on which the shelter is located. 82

Any facility that attains this definition of a shelter cannot, under the by-laws, be located within 500
metres of another shelter meeting the same definition. 83 This would include shelters that have been
in existence since 2008 under a legal non-conforming exception.

The policy objective of the above restrictions on shelters is to permit a more equitable distribution of
shelters, group homes, community health and resource centers, and residential care facilities across the
City of Ottawa.

Salvation Army Proposal

The Salvation Army proposal says that the closest nearby shelter is the St. Marys Home shelter at 780
de lEglise Street, approximately 800 metres from the subject property, and as such in compliance with
municipal by law separation distances.84

The closest shelter to the subject property is the St. Marys Home shelter at 780 de lglise Street,
approximately 800 metres from the subject property. St. Marys Home is a specialized social
service agency that provides programs and services to young pregnant women, young moms and
dad, and their infants and young children.85

This statement provides evidence that the Salvation Army acknowledges there are shelters that provides
differencing services to another clientele, but still attain the legal definition of shelter.

Analysis & Implications

The city definition of shelter contains three key aspects for a facility to attain the legal definition. First,
the patron must be in immediate need of shelter and food. This requires a facility to offer
accommodation on an immediate basis, without notice or reservation. Second, the facility must be a
refuge, and may provide other services such as ancillary health care, counselling and social support
services. This means the faculty may provide a service in addition to shelter itself, that service may be

81
City of Ottawa Zoning By-law Definitions Source: http://documents.ottawa.ca/sites/documents.ottawa.ca/files/documents/pt_01_en.pdf
82
City of Ottawa Zoning By-laws. Section 134. Source: http://documents.ottawa.ca/sites/documents.ottawa.ca/files/documents/pt_05_en.pdf
83
On Twitter, Mayor of Ottawa referred to the Chrysalis House in Kanata and the Carrington Community Health Centers as shelters consistent
with this definition. https://mobile.twitter.com/JimWatsonOttawa/status/880125494729093120?p=v
84
Supra, Salvation Army Report. P.24
85
Ibid.
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 17

held on a wide variety of social services. Third, and implicit with the definition is that the duration is
short term and free of charge. The facility offers accommodation on a short-term basis during the
emergency period. Further, that rent is not charged, so the short-term resident is provided
accommodation on a pro bono basis.86

Following the City of Ottawa definition of shelter a shelter is a facility that provides on-demand
short-term (i.e. less than one month) free accommodation with optional accompanying support
services. 87

According to a geographic assessment of the proposed site at 333 Montreal Road, there are three
facilities that attain the legal definition of shelter with a 500-metre distance of the proposed site plan
(see Annex F). 88

1. House of Welcome (Billy Buffets) (243 Granville St). This is a 12-bed facility serving men with alcohol
or drug problems, many arriving straight from a detoxification center, and are as such homeless or
without immediate shelter.89 This attains the definition of a shelter in accordance with the city by-
laws as it offers lodging on demand without notice for a short period and exceeds the definition of a
group home.90

2. Ottawa Inn Hotel (215 Montreal Rd.) This is a hotel used as an overflow homeless temporary shelter.
Hotels have been recognized by the city has functioning shelters. In 2006, the City classified these
temporary shelters as shelters in assessing capacity being used in the city. 91 This implies that the
Ottawa Inn Hotel is considered a shelter prior to the re-definition in 2008. The 2008 re-definition
did not restrict the application of temporary shelters, and following the by-law definition post 2008,
remains in compliance with the new definition.92

3. Maison Fraternite (300 Olmstead St). This male youth rehabilitation center contains five beds for
short term immediate accommodation, including counselling and nourishment, on a pro bono basis.93
As the facility is multi use, it cannot be legally classified as a group home meaning it attains the
definition of a shelter.94

86
This would mean there are no residential or rental contracts between the patron and the facility.
87
This further follows the definition of shelter used by the Salvation Army in identifying the St. Marys Home shelter. The Salvation Army may
be only identifying shelters that are funded by the city. This is a policy definition. However, there are other facilities that attain the bylaw
definition of shelter but do not receive city funding but from other public or private sources. The bylaws do not restrict shelter to only
faciliites that only receive city funding.
88
Shelters that are pre-existing prior to the 2008 bylaw amendments are grandfathered to be legally compliant to this restriction
89
See description at http://www.ementalhealth.ca/index.php?m=record&ID=9610.
90
Note that this is not defined as a Group home under the City by-laws as a group home is defined as a supervised residential use building
with three to ten persons. This facility contains twelve people, exceeding the group home definition. The City report provides shelter is also
special needs houses with no resident cap.
91
Health, Recreation and Social Services Committee Report. Emergency Shelter Standards and Review Framework. 9 Nov. 2005. Ref
N: ACS2005-CPS-HOU-0014 http://ottawa.ca/calendar/ottawa/citycouncil/hrssc/2005/11-17/ACS2005-CPS-HOU-0014.htm. The new land use
term shelter should be created in the former Ottawa and Vanier Zoning By-laws, reflecting the new Comprehensive Zoning By-law term. This
term permits ancillary health care, counselling and social support services within the principal shelter use
92
The new definition only removed the number of beds and further defined a group home from three to ten persons.
93
Maison Fraternite. Youth Services. http://www.maisonfraternite.ca/nos-services/centre-pour-adolescents/
94
According to the By-law definitions, group home means a supervised residential use building in which three to ten persons, exclusive of
their dependents and of any staff, live as a group in a single household living arrangement, and where residents require support or supervision
on a daily basis, but excludes correctional facilities and shelters. (foyer de groupe) (By-law 2014-94) Under the interpretation note, the whole of
the building must be occupied as a group home.
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 18

Implications

The proposed site of the Salvation Army shelter at 333 Montreal Road must not be within 500 metres of
any other shelter located within 500 metres of the planned site. However, using the legal definition of
shelter, the Salvation Army proposed location is within 500 meters of three other shelters in Vanier.

Recommendation

It recommended that the Salvation Army proposal not be permitted to proceed with the site selected at
333 Montreal Road as it is in clear violation of the separation distance between other functioning
shelters and that no non-compliance exceptions be granted as the community is serviced by a plethora
of pre-existing social service providers.

D. Maximum Four Shelters in Ward 12

Municipal Policy & Principles

The City Report limits the number of shelters in Ward 12 to four. The report clarifies that this means
that no new shelters will be permitted anywhere in Ward 12. The policy rationale is as follows:

The City agrees with stakeholders, including the shelter operators, that there is an over
concentration of shelters and services within Ward 12. Indeed, some shelter operators expressed
concern with the relocation of Operation Go Home across the street from a homeless mens
shelter, citing concerns with the visibility and negative impact of illegal trade outside the shelter
that might be experienced by the very youth at the highest risk of becoming homeless
themselves. Some social studies suggest that the over concentration of social services leads to
fewer positive impacts for both residents as well as for those seeking the social service, the
opposite of what would otherwise be expected to be positive impacts of efficiencies of scale,
when like services- are provided in proximity.95

This means that no new shelter will be permitted in Ward 12 until three remain.96 In fact, the City Report
forecasted that a shelter presently located in Ward 12 may consider re-location at a future date.

In addition, the four-shelter maximum will create non-compliance in the short-term, given the
small fifth hybrid group home/shelter in Ward 12. This means, that over the long term, some
shelters may need to redevelop and may relocate by looking elsewhere in the downtown or
greater urban area, within the realm of the widened permission to locate in a variety of non-
residential zones.97

The report does not list the existing shelters by name, however a list of major shelters was provided in a
2005 city report outlining emergency shelter capacity.98 This report identified eleven (11) shelter

95
Supra, City of Ottawa Report, 2008.
96
Ibid.
97
Ibid.
98
Health, Recreation and Social Services Committee Report. Emergency Shelter Standards and Review Framework. 9 Nov. 2005. Ref
N: ACS2005-CPS-HOU-0014 [Ottawa Shelter Standards Report, 2005] http://ottawa.ca/calendar/ottawa/citycouncil/hrssc/2005/11-
17/ACS2005-CPS-HOU-0014.htm
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 19

facilities in the city of Ottawa. From the shelters listed five (5) are located in Ward 12 Rideau-Vanier (i.e.
Shepherds of Good Hope (2 shelters),99 The Salvation Army, the Mission, and Youth Services Bureau).

This study acknowledged, along with the 2008 City Report, that there are already five existing shelters in
Ward 12, meaning any re-location of a shelter would void the existing legal non-compliance status and
create an illegal non-compliance application.

Salvation Army Proposal

The Salvation Army proposal is to re-locate an existing shelter at 171 George Street in the ByWard
Market to 333 Montreal Road, thereby maintaining the permitted number of shelters at four (4) within
the Ward. 100 The proposal provides that the policy rationale of a minimum of four is to lower
concentration of shelters in the ByWard market.

Analysis & Implications

The larger shelter facilities in Ottawa include: Shepherds of Good Hope (Mens shelter and Womens
shelter), the Salvation Army, the Mission and the additional Youth Services Bureau. This report has listed
shelters, supra, within a 500 metre separation distance of the proposed site in Ward 12.

The following facilities further attain the legal definition of a shelter located in Ward 12:101

1. St. Josephs Women Shelter. This is a daytime shelter for homeless women providing
nourishments and support for women in need.102

2. Evelyn Horne Young Womens Shelter. This is a 30-bed emergency shelter bed facility for women
16-20 years old who require immediate short term safe housing.103

3. La Maison damiti: This is a 30-bed emergency shelter for francophone women who are victims of
domestic abuse.104

4. La Prsence. This is a 12-bed short term stay shelter for francophone women of domestic
violence.105

5. Maison Fraternit. This is a temporary weekend shelter for women who suffer from drug and
alcohol abuse.106

6. Maison Sophia Reception House. This is a temporary shelter (3-4 weeks) for refugee claimants.107

7. Oshki Kizis Lodge: This is a 21-bed facility for First Nations persons.108

A list of legal non-compliance shelters in Ward 12 is provided in Annex F.

99
Shepherds of Good Hope contains two facility locations. A shelter for men at 230 Murray St.
and a Transitional Emergency Shelter located at 256 King Edward Ave. See http://www.shepherdsofgoodhope.com/shelter-programs/
100
Supra, Salvation Army Proposal. P.24
101
Note: Due to the sensitivity of women shelter, the location will only be provided in a confidential request
102
St. Josephs Women Shelter is a day shelter for homeless women that provide shelter and nutrition.
http://stjoeswomenscentre.org/b/about-us
103
Evelyn Young Womens Shelter. http://www.ysb.ca/index.php?page=young-women-s-shelter&hl=eng
104
La Maison damiti http://maisondamitie.ca/jai-besoin-daide/questions-frequentes/
105
La Presence https://ottawa.cioc.ca/record/OCR1664
106
Maison Fraternite womens shelter. http://www.maisonfraternite.ca/nos-services/residence-pour-femmes/
107
Maison Sophia Reception House. http://cciottawa.ca/about-us/contact-us/
108
Oshki Kizis Lodge. http://www.minlodge.com/
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 20

Following the legal definition of shelter, Ward 12 has exceeded four shelters, even with the removal of
the Salvation Army proposed facility. This is further acknowledged by the Salvation Army proposal that
lists another smaller shelter in an abutting Ward.109 As Ward 12 contains more than four legally non-
compliant shelters, recognized by the City of Ottawa,110 the Salvation Army proposal cannot be located
in Ward 12 in accordance with the by-laws.

Recommendation

Legally, the Salvation Army proposal must be rejected as there are already four legally compliant
shelters, plus additional facilities that attain the legal definition of shelter in Ward 12.

In conclusion, the Salvation proposed project development at 333 Montreal Road clearly violates the
city by-laws concerning site placement of shelters on a Mainstreet, residential zoning requirements,
separation distances and shelter numerical limits in Ward 12.

Case Law

In 2010, the Ontario Municipal Board (OMB) reviewed a shelter location submission under subsection
34(19) of the Planning Act, under the City of Kitchener by-laws.111 The appeal concerned the City of
Kitchener seeking to place a shelter outside of an area holding high concertation of people on social
assistance (i.e. 20% of the population).112 The City sought a shelter development in an area to reduce the
over-concentration of single person, low income households, residential care facilities and
social/supportive housing in accordance with city reports.113

In its ruling, the Board accepted the Citys rules and rationale of decentralizing institutions and fostering
a neighborhood mix as fully supported by provincial policy and the citys official plan.114 The Board
accepted the rationale to distribute such facilities throughout other parts of the city effectively
decentralizing institutional facilities.

This case demonstrates that the OMB may uphold city planning rules, including the separation distance
requirements, maximum shelter limits and associated reports by the city, on the policy rationale to
equally distribute shelters in in accordance with city plans, by-laws, reports and the Planning Act.

109
Supra, Salvation Army Report. P.24
110
Supra, Ottawa Shelter Standards Report, 2005. City of Ottawa Report, 2008
111
Ontario Municipal Board. January 14, 2010. OMB File No. R050129 [OMB Kitchener Case]
112
Ibid.
113
Ibid.
114
Ibid.
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 21

Summary of Proposal Breeches of City Policies and By-Laws


Ottawa Official Plan
The proposed development will empirically increase
Development of safe and healthy communities. crime and limit the capacity of existing service providers
to effectively reform citizens at risk.
The proposal concentrates low income housing in
Adequate provision of a full range of housing. Vanier, an area presently under a disproportionately
high level of low income housing.
The protection of the financial and economic well- The proposal will have an adverse effect on local
being of communities. economic development in an at risk community.
City Zoning By-Laws
The proposal does not attain the policy rationale of
Restrictions on Mainstreets. providing a net benefit to a Traditional Mainstreet
Zone.
The proposal creates quality of life challenge in mixing
Restrictions in placements. industrial use in a residential and commercial
environment.
The proposal does not take into consideration existing
Separation distance between shelters. shelter facilities in Vanier exceeding the minimum
distance requirements between shelters.
The proposal does not take into consideration existing
Maximum four shelters in Ward 12. shelter facilities in Vanier and it exceeds the maximum
number of shelters permitted in Ward 12.

Conclusion

The Salvation Army proposal requires Official Plan and zoning amendments to proceed. However, the
proposal fails in addressing key attributes of the Official Plan (or affiliated city reports) under the
provincial Planning Act. It also fails in providing convincing arguments to seek amendments under the
current zoning laws.

These factual and legal considerations demonstrate that insufficient consideration, policy due diligence
and consultation were undertaken for the proposed site plan to ensure coherence with the Ottawa
Official Plan. First, the proposal fails to ensure healthy and safe communities when it is knowingly
increasing risk of crime, prostitution and vagrancy. Second, the proposal ghettoizes Vanier with
additional low income housing, being willfully blind of the current disproportional low income housing
stock. Third, the proposal is ignorant of the economic impacts of the current socio-cultural sensitivities
of the Vanier community.

Furthermore, the Salvation Army Proposal fails to address the policy rationale for zoning requirements
in the City of Ottawa. First, the proposal seeks an exception to the rule forbidding shelters on the
Traditional Mainstreet of Montreal Road, but its rationale fails to provide any benefits to the
community. Second, the proposal imposes an industrial activity in a residential zone, inconsistent with
previous recommendations of city officials. Third, the proposal fails the shelter minimum distance test
and maximum placements in the Ward 12 by-law requirements.

We appeal to the City of Ottawa officials to give these concerns the upmost serious consideration.
Any action by the City of Ottawa to pursue this development knowingly and purposefully violating
existing planning and zoning rules, creates a clear and legal cause of action for appeal to the Ontario
Municipal Board.
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 22

ANNEX A: Planning Act: 2014 Provincial Policy Statement 115

1.1 Managing and Directing Land Use to Achieve Efficient and Resilient Development and Land Use
Patterns

1.1.1 Healthy, liveable and safe communities are sustained by:

a) promoting efficient development and land use patterns which sustain the financial well-being
of the Province and municipalities over the long term;

b) accommodating an appropriate range and mix of residential (including second units,


affordable housing and housing for older persons), employment (including industrial and
commercial), institutional (including places of worship, cemetreies and long-term care homes),
recreation, park and open space, and other uses to meet long-term needs;

1.1.2 Sufficient land shall be made available to accommodate an appropriate range and mix of land uses
to meet projected needs for a time horizon of up to 20 years. However, where an alternate time period
has been established for specific areas of the Province as a result of a provincial planning exercise or a
provincial plan, that time frame may be used for municipalities within the area.

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.

Section 1.7: Long-Term Economic Prosperity of the 2014 Provincial Policy Statement also dictates that
economic prosperity must also be respected, as outlined by the following sections:

1.7 Long-Term Economic Prosperity

1.7.1 Long-term economic prosperity should be supported by:

a) promoting opportunities for economic development and community investment-readiness;

c) maintaining and, where possible, enhancing the vitality and viability of downtowns and
mainstreets;

g) providing opportunities for sustainable tourism development;

115
Provincial Policy Statement Under the Planning Act. 2014. [Planning Act Guidelines] Part V. Ministry of Municipal Affairs and Housing
Provincial Planning Policy Branch. http://www.mah.gov.on.ca/AssetFactory.aspx?did=10463
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 23

ANNEX B: City of Ottawa Official Plan

Section 1.3 - The Ottawa 20/20 Process and the Guiding Principles116

Objectives under the Planning Act: the orderly development of safe and healthy communities.

Economic Strategy Building on the success and momentum of the Economic Generators Initiative, the
Economic Strategy establishes policies to continue growing a strong and diverse economy. It includes
plans for key Ottawa business markets: the export sector, the local market and the rural sector.

A Caring and Inclusive City - Housing policies support increased availability of affordable housing and
address the integration of a range of housing into all neighbourhoods to meet the varied needs of all
household types including families, seniors and young people.

A City of Distinct, Liveable Communities


Community design plans provide specific criteria for areas identified for intensification and ensure
planning policies respond to the specific needs and opportunities of those communities.
The qualities that make neighbourhoods special and contribute to their identity are valued in any
consideration of land-use change.

Section 3 - Designations and Land Uses117

3.1 - Generally Permitted Uses


Shelter Accommodation Where the zoning by-law permits a dwelling in areas designated General
Urban Area, Developing Community, Central Area, Mixed-Use Centre, and Village, the by-law will also
permit shelter accommodation. Shelter accommodation shall be designed in a manner compatible with
the general area. The zoning by-law may include provisions to regulate the size and location of this use.
[Amendment #76, August 04, 2010]

Montreal Road District Secondary Plan118


[Amendment #127, January 22, 2014]
1.1.1. The Main Goals for the District are to:
Foster development and redevelopment along the Traditional Mainstreets and Arterial Mainstreet
which complements and improves upon the positive qualities of the existing character of the District.

116
Ottawa Official City Plan. Section 1 - http://ottawa.ca/en/node/1009710
117
Ibid. Section 3 - http://ottawa.ca/en/node/1009706
118
Montreal Road District Secondary Plan. http://ottawa.ca/en/city-hall/planning-and-development/official-plan-and-master-plans/official-
plan/volume-2a-secondary-plans/montreal-road-district-secondary-plan
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 24

ANNEX C: Zoning By-law 2008-250 Consolidation

Definitions (sec. 54) 119

Residential care facility means an establishment providing supervised or supportive in-house care for those who
need assistance with daily living, that may also provide on-going medical or nursing care or counselling and social
support services and which may include services such as medical, counselling, and personal services. NOTE: Under
the interpretation note, this includes nursing homes, a complex for handicapped persons and homes for the aged.

Group home means a supervised residential use building in which three to ten persons, exclusive of their
dependants and of any staff, live as a group in a single household living arrangement, and where residents require
support or supervision on a daily basis, but excludes correctional facilities and shelters. (foyer de groupe) (By-law
2014-94) NOTE: Under the interpretation note, the whole of the building must be occupied as a group home.

Shelter means an establishment providing temporary accommodation to individuals who are in immediate need of
emergency accommodation and food, and may include ancillary health care, counselling and social support
services. (refuge)
120
Section 3 - Designations and Land Use

Shelter Accommodation
4. Where the zoning by-law permits a dwelling in areas designated General Urban Area, Developing Community,
Central Area, Mixed-Use Centre, and Village, the by-law will also permit shelter accommodation. Shelter
accommodation shall be designed in a manner compatible with the general area. The zoning by-law may include
provisions to regulate the size and location of this use. [Amendment #76, August 04, 2010]

Part 5 Residential Provisions (Sections 120-141)


121
Section 134

Where it is a permitted use in a zone, in addition to the provisions of the zone in which it is located, a shelter must
be separated from any other lot containing a shelter, a distance of 500 metres from each property line of the lot
on which the shelter is located.

(2) Despite subsection (1), the minimum required separation distance need not extend across a highway, grade-
separated arterial roadway, railway yard, Rideau or Ottawa Rivers, or Rideau Canal, or any other major barrier to
pedestrian or vehicular movement, and in such cases is deemed to be fulfilled by the distance between that barrier
and the affected property line or lines of the lot containing the shelter.

(3) Where located within a Minor Institutional Zone, a shelter must be separated from any lot zoned R1, R2, R3
and R4, a distance of 30 metres from each property line of the lot on which the shelter is located and the
Residentially-zoned lot.

(4) Section 122 applies.

(5) Despite anything to the contrary, a maximum of four shelters are permitted in Ward 12 as shown on Schedule
5. (By-law 2008-341).

119
City of Ottawa Zoning By-law Definitions Source: http://documents.ottawa.ca/sites/documents.ottawa.ca/files/documents/pt_01_en.pdf
120
City of Ottawa Official Plan Volume 1 Section 3. Designations and Land Use. http://ottawa.ca/en/node/1009706
121
City of Ottawa Zoning By-laws. 134 Source: http://documents.ottawa.ca/sites/documents.ottawa.ca/files/documents/pt_05_en.pdf
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 25

ANNEX D: City of Ottawa Reports

Salvation Army Planning Rationale (2017)


http://webcast.ottawa.ca/plan/All_Image%20Referencing_OP%20Amendment%20Application_Image%
20Reference_2017-06-20%20Planning%20Rationale%20D01-01-17-0013.PDF

OTTAWA CITY COUNCIL 25 JUNE 2008


RIDEAU-VANIER WARD 12 INTERIM CONTROL BY-LAW STUDY AND ZONING BY-LAW AMENDMENT
Full Council: http://ottawa.ca/calendar/ottawa/citycouncil/occ/2008/06-25/englishfinalagenda39.htm

Council Approved Zoning Amendment Report:


http://ottawa.ca/calendar/ottawa/citycouncil/occ/2008/06-25/pec/02-ACS2008-PTE-PLA-0011.htm

Planning and Environment Committee - 22 May 2008


RIDEAU-VANIER WARD12 INTERIM CONTROL BY-LAW STUDY AND ZONING BY-LAW AMENDMENT
Full Report: http://ottawa.ca/calendar/ottawa/citycouncil/occ/2008/06-25/pec/02-ACS2008-PTE-PLA-
0011.htm

Planning and Environment Committee - 17 September 2007


EXTENSION OF INTERIM CONTROL-WARD 12 RIDEAU VANIER PROHIBITION OF GROUP HOMES AND
SHELTERS Interim Control By-Law 2006-452
http://www.ottawa.ca/calendar/ottawa/citycouncil/occ/2007/11-14/pec/ACS2007-PTE-POL-
0055%20ENGLISH

Planning and Environment Committee - 28 August 2006


REGULATION OF SPECIAL NEEDS HOUSING IN RIDEAU-VANIER
http://ottawa.ca/calendar/ottawa/citycouncil/pec/2006/09-12/ACS2006-CCS-PEC-0011.htm

Health, Recreation and Social Services Committee Report. 9 Nov. 2005


EMERGENCY SHELTER STANDARDS AND REVIEW FRAMEWORK
http://ottawa.ca/calendar/ottawa/citycouncil/hrssc/2005/11-17/ACS2005-CPS-HOU-0014.htm
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 26

ANNEX E: Low Income Support Services and Housing Options in Vanier

Supportive Housing Family & Community Services Addiction Treatment Centers


Vanier
261 Montreal Ontario Addiction
Action Housing Community 290 Dupuis St 263 Montreal Road
Road - Office Treatment Centres
Services Centre
259 Ste Anne
John Howard
Ave Ottawa
Society of Partage Vanier 161, av Marier Recovery Ottawa
322 Gardener 11 Selkirk St
Ottawa
St
Multifaith 206 Onyx 242 Cantin Street 105,
265 Montreal
Housing -404 McArthur Community Maison Fraternit rue Laval
Road E, Ste 4
Initiative Ave. - Office Services 300, rue Olmstead
Les Services daccs et 338
311 McArthur
Inuit Non-Profit Heartwood 404 McArthur daiguillage en Montreal Rd, Ste 101
Ave, Ste 102 -
Housing house Ave toxicomanie dOttawa
Office
(SAATO)
Gignul Non 404 McArthur Our Lady of Assumption 317 Cody Avenue
Hopewell
Profit Housing Ave Church
Ottawa Ottawa and Soldiers Helping Soldier 265 Montreal Road
404 McArthur
Community Gatineau ACO
Ave
Housing (OCH) RN
EBO Financial
Housing and Residential Care for 300 Olmstead
Education First Nations
People with Mental Illness: St
Centre
Precision Health
Group - Maison Marie- 235 Ste Anne Wabano Centre for
9 Stevens Ave 299 Montreal Rd
Edgewood Care Louise Ave N, Apt 1 Aboriginal Health
Centre
Association pour
Chez Mre 264 Olmstead
l'intgration 235 Donald St Kagita Mikam 456 McArthur Avenue
Bruyre St
sociale d'Ottawa
Domiciliary Hostels and Long Catholic Family Ottawa Inuit Children's
310 Olmstead 230 McArthur Ave
Term Care Homes Service Ottawa Centre
Centre d'accueil 275 Perrier 780 de l'glise
St. Mary's Home Tungasuvvingat Inuit 297 Savard Avenue
Champlain Ave St
Duford Tel-Aide 300 Olmstead
151 Duford St. Francophone Services
Residence Outaouais St
Mon Plaisir 88 Marquette Centre Francophone de 270 marier ave
Youth
Residence Ave Vanier
Maison Accueil- 424 Montreal Boys and Girls 430 McArthur Centre Pauline Charron 164 Jeanne Mance St
Sagesse Road Club Ave
Centre Psychosocial 150 Montreal Rd

Number of low income/affordable housing sites in Vanier - 25


Number of residents in low income housing - 386
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 27

ANNEX F: Graphic Representation of the Shelters in Vanier

The following map outlines shelters within a 500 metre radius of the proposed development site.

The following map provides a 500 metre distance radius of existing shelters limiting additional shelter
development within this zone.
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 28

List of Shelters in Ward 12

Name Location
1 Billy Buffet House of Welcome 243 Granville St.

Evelyn Horne Young Womens (note: will be provided privately to ensure


2
Shelter projection of location)
40 Cobourg St.
3 La Maison damiti
2 Mark St
(note: will be provided privately to ensure
4 La Prsence
projection of location)
Shelter for Women - 105 Laval St.
5 Maison Fraternit
Shelter for Youth - 300 Olmstead St.

6 Maison Sophia Reception House 204 Boteler Ave.

7 the Mission 35 Waller St.

8 Ottawa Inn Hotel 215 Montreal Rd.

9 Oshki Kizis Lodge 240 Charlotte St.

Shelter for Men - 230 Murray St.


10 Shepherds of Good Hope Transitional Emergency Shelter - 256 King
Edward Ave

11 St. Josephs Women Shelter 151 Laurier Ave E

12 Youth Services Bureau 147 Besserer St


CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 29

ANNEX G: Vanier Zoning and By-Laws Committee

First Last Email


Peter Kucherepa peter@kucherepa.ca
Benjamin Gianni benjamin_gianni@carleton.ca
Louise Lapointe laplouster@gmail.com
Shuo shuo@vmstat.org
Ingrid Fish ingridfish8789@gmail.com
Chris Greenshields greenshieldsfamily@yahoo.ca
Alex Martel alex@martel-law.com
Rolland Cright rolland.cright@gmail.com
Julie Sogree Julie.Soogree@forces.gc.ca
Suzan Proulx sproulx@placelafontaine.com
Louise Lapointe laplouster@gmail.com
Adam Drackley adam.drackley@gmail.com

Additional Vanier Teams

Team A- Site Selection Criteria for the site- Neal McCarten and Samantha Strath
Team B- City of Ottawa Social Services policies and objectives- Lauren Touchant
Team C- Review of available private and government lands- Benjamin Gianni
Team D- Focus on services for the community- Catherine Labossiere
Team E- Elements of design for the proposal- Benjamin Gianni
Team F- Innovation and best practices in the sector and opportunities to improve the service offering-
David McCarron
Team G- Engagement in the community and City- Drew Dobson
Team H- Focus on Zoning Review- Peter Kucherepa, Benjamin Gianni and Louise Lapointe
Team I- Fundraising- TBD
Team J- Social impact in Vanier- Louise Levesque
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 30

ANNEX H: Media & Communications Lines

Key Messages:

The Salvation Army proposal to re-locate and construct a mega shelter at 333 Montreal Road, in Vanier, Ottawa,
Ontario, is breaking all the provincial and municipal rules and policies regarding shelter locations.

The proposed location at 333 Montreal Road does not meet the legal and policy objectives regarding shelter locations
outlined by the City of Ottawa. The violations are so egregious it demonstrates that the proposed site cannot be
considered appropriate or fitting for a mega shelter location.

The Salvation Army proposal raises concern that they did not take into proper consideration provincial laws, city by-laws
or policies regarding shelter locations. Meaning their submission is simply based on an argument of convenience, which
should raise significant concerns to the City of Ottawa.

Summary of Analysis:
The Salvation Army is proposing one of Canadas largest shelters at 333 Montreal Road. They have provided a
Context submission to the City of Ottawa seeking authority to build this new facility in Vanier.

The proposed development site does not follow the policy objectives of the Ottawa Official Plan:

The proposed development does not pursue the city objective of safe and healthy communities. The
proposed development will imperially increase crime (i.e. drugs, violence, loitering) and limit the capacity of
Counter
existing service providers in Vanier to effectively reform citizens at risk.
Ottawa
Official The proposed development concentrates low income housing in Vanier, already at disproportionate levels of
Plan low income housing, going against the city wide plan and provincial planning objectives to diversity how
income housing across all areas. This will further negatively affect housing stock in the City of Ottawa.
The proposed development lacks any economic or positive impact to Vanier, a sensitive and at risk economic
recovery area of the city.

The proposed development site clearly violates the Ottawa zoning bylaws regarding shelter developments:

The city restricts shelters from being within 500 metres of each other. There are three shelters, recognized by
the city, within 500 metres of the proposed site.
The city restricts no more than four shelters in Ward 12. There are 12 shelters in Ward 12, including 5 large
shelters. These shelters are in legal-non-compliance status, meaning they can operate but if they move out
Counter
Ottawa they cannot relocate in Ward 12. As such, it is illegal for the Salvation Army to re-locate a shelter in Ward 12.
Zoning By- The proposed location of 333 Montreal Road is on a city Mainstreet. City bylaws restrict shelters to be created
Laws on Mainstreets due to the negative externalities to the community. The Salvation Army proposal provides
that its clients will benefit from the location, but at the direct cost to the Main street community, including
negatively affecting commercial development, parking, traffic and noise.
The city further restricts shelters in a commercial and residential area. The location of 333 Montreal Road is
on a commercial and abutting residential area, which will result in significant negative impacts to the direct
commercial and residential area.

The City of Ottawa and Vanier community cannot support a proposal that breeches all shelter location rules and
Solution polices set forth by the city. This demonstrates that the site of 333 Montreal Road is not a good fit under law or
city policy, creating a clear cause of action to the Ontario Municipal Board.
CITY OF OTTAWA ZONING IMPLICATIONS OF THE SALVATION ARMY SHELTER PROPOSAL PAGE 31

About the author:

This report was authored by Peter Kucherepa HBA. J.D. M.Cert. CITP, Barrister & Solicitor, Sr. Policy Advisor and
Community Advocate. This document was assisted by the Vanier Zoning and By-Laws Committee, community
leaders and the Office of Mathieu Fleury. Peter Kucherepa holds a strong track record of community advocacy
having authored a report on the proliferation of payday loan centers in Vanier effectively changing the laws of
Ontario and city by-laws to re-develop Montreal Road. Peter Kucherepa was nominated for a Samara Political
Citizen Award for this accomplishment. This paper is his own opinion and supported by the Vanier community. It
does not reflect the opinions of his employer(s) or any level of government. He can be reached for comment at

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