Regina Stomps on the Housing Accelerator Pedal
Feds hint at a way to succeed at winning funding, but City of Regina plan may miss the mark
In a previous article, we looked at how the CMHC Housing Accelerator Fund impacted a Calgary debate about housing policy.
Since that time, news stories have trickled out about several other cities that have applied for funding, and the bold changes the Minister is requiring before granting them approval —
[Federal Housing Minister Sean] Fraser has been playing hardball on housing across the country. He sent letters to cities like Halifax and Mississauga, Ont., asking them to raise height limits to four storeys in central areas or near transit stations and allow four units on every lot in exchange for the money.
-CBC: Council split on fourplexes as feds press cities to relax zoning
Most recently, Mr. Fraser published a hintbook for applicants, “A Municipal Roadmap” urging municipalities to mash the button for transformative policy if they hope to out-compete other cities for a share of HAF funding.
Figuring at the top of the list is this recommendation – “1. End exclusionary zoning. Stop low-density zoning and regulation that excludes housing types such as affordable and social housing in residential areas.”
“May Regina Flourish”
To put it mildly, the record of the current Regina City Council on land use and zoning issues has been less than stellar.
During this term, Councillors moved successfully to open up a loophole in the Official Community Plan that weakens density requirements for new developments, opted not to elevate intensification to the status of a “Big Move” within the Sustainability Framework (as I advocated for at the time), and corrupted a motion intended to eliminate parking minimums by using it instead to try to increase parking minimums for apartments — which, had it passed, would have increased the costs to build rental housing, making it ultimately less affordable for the end user.
And that is merely a drive-by summary.
The previous Council was no great shakes either, but one important step forward from that time was the passage of the Regina Zoning Bylaw, 2019, which greatly simplified zoning and made other tweaks to better align with the 2013 Official Community Plan.
One proposed change that didn’t make it however was the elimination of R1 - Residential Detached zoning, the designation that requires that all housing in an area be made up of single-detached structures.
Exclusionary R1 zoning was preserved in the 2019 bylaw, and today these areas make up a large swath of Regina’s territory — with the notable exception of most of Regina’s pre-War neighbourhoods, such as Cathedral, North Central and Heritage.
You can see this for your self using this Zoning Map.
Faster Houses
This summer, Regina City Council authorized a plan to present an application to the Housing Accelerator Fund. Although we didn’t get into the nitty-gritty of the HAF program in the Calgary article, the fact that Regina submitted an application is very interesting.
Under the initial parameters of the Housing Accelerator fund, a minimum of 7 menu items are required to be selected for municipalities with a population over 10,000. The program allows for a “design your own initiative” provision, but the program’s Applicant Guide provides a fairly all-encompassing list.
A city’s policy changes must be all-new actions adopted specifically for the HAF program, and here they are (brace yourself, it’s a long list) —
Promoting high-density development without the need for rezoning (as-of-right zoning), e.g ., for housing developments up to 10 stories that are in proximity (within 1 .5km) of rapid transit stations and reducing car dependency
Allowing increased housing density (increased number of units and number of storeys) on a single lot including promoting “missing middle” housing forms typically buildings less than 4 stories
Encouraging Accessory Dwelling Units—a second smaller unit on the same property as a primary unit
Enable mixed-use redevelopment of city-owned properties, while where appropriate maintaining the current government use, e .g ., building housing on top of a library or office space
Promoting infill developments (adding new units to existing communities) with increased housing density and a variety of unit types (e .g ., duplexes or secondary suites)
Implementing rental only zoning
Implementing land use changes mandating a minimum number of family units (units with more than two bedrooms) or allowing for office conversions to residential with minimum family unit requirements
Implementing revised parking requirements such as reduced or eliminated parking spaces for new developments
Implementing disincentives, costing or fee structures to discourage such things as unit vacancy, underdeveloped/idle land, and low-density forms of housing
Ensuring that development and amenity charges – fees that cover necessary infrastructure to support new housing and amenities such as libraries and recreation centres in and adjacent to the communities where development is occurring – are clear, transparent and pre-determined (not subject to negotiation)
Aligning development charges with the costs of infrastructure and servicing – Implementing incentives, costing or fee structures, for example density bonusing, to encourage such things as affordable housing and conversions from non-residential to residential
Waiving public hearings on all affordable housing projects that conform to the official community plan
Implementing measures to address or prevent flood plain or climate change risk for example making flood plains park land and/or creating relocation programs to move housing units out of at-risk areas
Incorporating a climate adaptability plan into Official Community Plan
Promoting and allowing more housing types that serve vulnerable populations
Promoting regulated multi-tenanted housing forms (e .g ., boarding houses or single room occupancy)
Implementing inclusionary zoning (the requirement that a developer builds a certain percentage of their units at affordable (below market) prices or rents) in ways that foster development
Encouraging alternative forms of housing construction such as modular housing, manufactured housing, and prefabricated housing
Create a process for the disposal of city-owned land assets for the development of affordable housing as-of-right (not requiring rezoning)
Implementing new/enhanced processes or systems such as case management, e-permitting, land and building modelling
Implementing changes to decision making such as delegating development approval authority to municipal staff based on established thresholds or parameters
Partnering with non-profit housing providers to preserve and increase the stock of affordable housing
Updating infrastructure planning to align with official community plans, growth targets, and housing needs assessment
Reducing and streamlining urban design and character guidelines, i .e ., elimination of height restrictions, visual character requirements, view cones, setbacks, etc.
On top of choosing among these initiatives, the program requires that applicants provide a projection of how many new housing units will be built without the funding, compared to a scenario where the funding is approved.
The HAF funding is then calculated based on the projected number of new units — with no funding for additional single-detached units.
In preparation for submitting the City’s application, Regina City Council unanimously approved administration’s proposed Action Plan Initiatives on June 7, 2023. The initiatives and the accompanying report can be found here.
According to the action plan, Regina supposes that funding will allow an additional 1,100 housing units to be built. Buried in a footnote is an interesting admission that because the City intends to slow-walk the implementation of a rapid transit network (seemingly ruling out any tactical urbanist red paint schemes), none of the projected new housing will actually meet the definition of “Multi-unit housing (in proximity to rapid transit)”. Unfortunately for the city, this is the type of housing that receives the most top-up funding under HAF.
Here is Regina’s Action Plan, summarized —
Enable high-density development within the City Centre.
Enable mid- and high-rise development along urban corridors and main transit routes identified in the Transit Master Plan. (emphasis added) [Note: As shown above, because the transit won’t actually come for years, if not decades, the housing won’t actually meet the HAF’s “proximity to rapid transit” criterion]
Advance the development of missing middle housing in central neighbourhoods.
Support the provision of greater housing diversity in established neighbourhoods.
Encourage conversion of non-residential buildings to residential (i.e., office conversions).
Preserve and increase affordable housing stock in partnership with non-profit housing providers.
Support pre-development work for housing projects, in particular affordable housing.
Reduce Council approval for housing related Discretionary Use applications.
Create a process for the disposal of city-owned land assets for the development of affordable housing.
Align infrastructure planning to add capacity, increase safety, and improve the quality of the public realm in the City Centre and central neighbourhoods.
Update the Development Charges Model to support long-term housing growth
There are explanatory paragraphs for each initiative, which are intriguing in their own way. But initiative #4 caught my eye in particular —
This initiative will include adjustments to zoning and development standards in established neighbourhoods to permit incremental changes that support greater housing diversity. It is anticipated that the change will be minimal on a localized context but will support gentle density to be integrated within established neighbourhoods citywide.
Could Regina be prepared to revisit R1 - Single Detached zoning?
Other initiatives are a bit underwhelming, and seemingly laced with weasel-words. For instance, initiative Number 5: “This will include exploring options to address regulatory and financial barriers to office conversion, additional engagement with stakeholders, and may result in a pilot program to support conversions in 1-2 buildings.” And proposal number 3 which suggests : “This may include reducing and/or eliminating minimum parking requirements.”
We can also question the City’s commitment to #10, “improve the quality of the public realm in the City Centre and central neighbourhoods” given what we’re seeing with recent projects — the recent 11th Avenue renewal project where sidewalks were replaced with asphalt, the paused Saskatchewan Drive re-do which increased vehicle lanes, and the drawings for the upcoming Dewdney Avenue project, which provides for, at best, a temporary multi-use pathway, but no dedicated bike lanes.
However, other prongs of the plan hint at a return to the bolder initial aspects of the proposed 2019 Zoning By-law, such as initiative #8, reducing Council approval for Discretionary Use applications, or the remainder of item #3, which floats the possibility of “pre-approved building plans”, a concept associated with South Bend, Indiana (and no doubt other places as well).
Did Regina Get the Hint?
With the recent publication of the CMHC’s HAF Hintbook, the so-called “Top 10 Best Practices”, we might wonder if Regina’s plan has anticipated the increasing boldness of the housing minister’s criteria for approval.
Here is each HAF Top 10 Best Practice item, followed by commentary evaluating how Regina’s draft proposals fit in —
End exclusionary zoning
Stop low-density zoning and regulation that excludes housing types such as affordable and social housing in residential areas.
Encourage high density by allowing mixed-use development and high-density residential as-of-right within proximity to urban cores and transit corridors.
This includes adopting by-laws to adopt more as-of-right zoning measures, from the number of units to storeys.
My Grade: B-minus. Regina’s action plan seems to suggest some minor, unspecified tinkering with zoning in established neighbourhoods, and additional housing near maybe-someday-rapid-transit, but the introduction of city-wide fourplexes as-of-right, which increasingly seems to be a sine qua non condition for HAF approvals, doesn’t seem to be in play here.
Make municipally owned lands available for housing through strategies such as disposition, acquisition and/or pre-development.
My Grade: A-minus. Regina’s initiative #9 seems to suggest a citywide push to become a more active player in assembling sites for development, perhaps similar to Calgary and Saskatoon’s municipal land corporations.
Increase process efficiency by implementing new technologies or software to speed up development approvals, such as e-permitting.
My Grade: C. There is not much listed in Regina’s proposals. However, the city has been doing work on moving permitting online in recent years.
Prioritized/enhanced development approval process for rental and affordable housing.
My Grade: C. There are different aspects of this sprinkled throughout Regina’s proposed items, from helping with pre-development work to reducing discretionary Council approvals, and of course the possibility of of pre-approved housing designs. But it doesn’t quite hit the mark.
Comprehensive review of development charges and fee schedules including waivers, with a focus on permits associated with affordable housing.
My Grade: B-minus. Item 11 floats vague, unspecified adjustments to Regina’s development charges model, but doesn’t really seem to focus on affordable housing.
Reduce or eliminate parking standards to increase project viability, density and reduce carbon footprint.
My Grade: B. Regina proposes potential changes, applied in a patchwork manner. These changes are mentioned in several of the Action Plan items, but Regina, unlike prairie cities like Edmonton and Calgary, apparently has an institutional aversion to reducing parking minimums beyond the changes already included in the 2019 zoning bylaw.
Eliminate restrictions related to height, setbacks, building floor area and others to allow a greater variety in housing types, including accessory dwelling units.
My Grade: C-plus. A few of these changes are mentioned, but only in reference to Regina’s “City Centre” (a specific term which is not the same thing as Downtown) and the not-quite-yet-Transit corridors. Regina has already done some work on approving backyard suites, which won’t count for this application.
Develop affordable housing community improvement plans or strategies/plans for the rapid deployment of affordable housing.
My Grade: D. There is an item about potential capital grants to non-profits for the acquisition of housing stock, though the very same item admits it will not have a large impact. The projected percentage of new affordable housing units with HAF funding is projected by the City administration to be in the low-single digits.
Design and implement guidelines or pre-approved building plans for missing middle housing or specific accessory dwelling unit types such as laneway housing or garden suites.
My Grade: B-minus. As I’ve mentioned above, I’m intrigued by Regina adopting a South Bend-style program of pre-approved housing designs. This isn’t promised, however, only floated as a potential avenue. It would be interesting to see pre-approved designs for Regina’s backyard suites, as the setbacks and step-backs baked into the zoning bylaw make them difficult to build on narrow, inner-city 25-foot lots.
Develop grant programs encouraging the development of housing types that align with the Housing Accelerator Fund such as missing middle, row homes, purpose-built rental and/or that promote new/innovative construction techniques (modular, pre-fab, mass timber construction, etc.).
My Grade: D-minus. Only “infill” is mentioned as a recipient of grants and forgivable loans, none of these other specific types of housing.
Overall? I haven’t counted up the points and done a formal average, but I feel like we’d land somewhere around a C-plus.
The real question is, will Regina’s actual application make the grade?
With some of the curious recent pronouncements from certain City Councillors, I have a feeling we’re about to find out.