Mill 99 - Ritchie DC2 Rezoning (LDA22-0070)

I have one more question for the City's engineers. Why if there is another proposed development (at 99 Street and 89 Avenue), and potentially one more at 99 Street and 83 Avenue, the potential traffic impacts of all these developments (including this high-density development) are not addressed together in the Traffic Impact Assessment (TIA)? These developments are very close to each other along 99 Street and their potential cumulative impacts must be addressed in the TIAs. It is the standard industry practice to investigate the cumulative impacts of site and off-site developments within the TIAs.

Can the City provide the TIAs for those developments, if there are any?

I strongly oppose this development and am appalled that the revised proposal has increased its size instead of addressing the concerns raised by our neighborhood. Adding so many living units to such a concentrated area will overload our traffic and sewer systems, which are already stretched to capacity. The city does not have the capacity to replace our aged sewer system, and eliminating the railyard to create another road to the University of Alberta Hospital is not feasible. The development will add to traffic congestion on Whyte Avenue and 99 Street and delay emergency health responses. Furthermore, it may lead to more lead in our water due to greater water volumes rushing through our aging plumbing system, which already receives regular notices about a potential lead.


Like our experienced neighborhood engineer, I want to stress that this development does not meet the criteria for Transit Oriented Development (TOD) and exceeds the height standards for transitioning to single-family homes, which should be limited to four floors. I suspect the proposal was either influenced by the developer's bribery or significant omissions in the city's planning and engineering reviews.

Again, I oppose the rezoning and the proposed development as it has very negative impacts on the Ritchie community and adjacent communities.

In response to the feedback I provide requesting a Traffic Impact Assessment (TIA), the City of Edmonton sent me an study called: Mill 99 Multi-Family Development, LDA22-0070 - 9907 – 80 Avenue NW, Mobility Review, Final Draft Report, version 5.2. April 2, 2023. This study seems to be a TIA addressing some of the concerns I presented, I assumed that is what the City implied. However, THIS STUDY HAS SIGNIFICANT ERRORS AND SIGNIFICANT OMISSIONS, WITH FINDINGS, CONCLUSIONS AND RECOMMENDATIONS THAT ARE INADEQUATE AND DO NOT REALLY ADDRESSES THE CONCERNS I RAISED OR WHAT IS EXPECTED FROM A STANDARD TIA. I am providing the key issues I found with this study based on my professional experience and expertise on TIAs, knowing the high standards for the City’s TIAs and the accepted industry practices for TIAs. These are the key concerns:

1. The study only analyses the intersection of 99 Street and 80 Avenue in Isolation of key intersections of this corridor. It uses a trip distribution and assessment that place traffic on key intersections both on 99 Street and Whyte Avenue without addressing the impacts on those intersections. The direct accesses of the development are not even included in the capacity analysis. In my professional opinion, the study must include in the capacity analysis at least the direct access on 99 Street, the direct access on 100 Street, the intersection of 99 Street and 79 Avenue, the intersection of 99 St and Whyte Avenue (a very problematic and key intersection that will be affected by the proposed development), the intersection of Whyte Ave and 100 St (as the study assumes site trips will use it), the signalized intersections along 99 Street that operates in combination to Whyte Ave and 99 St intersection (clearly, the main intersection for analysis) such as: 99 St and 83 Ave (very close traffic signal to Whyte Ave), 99 St and 85 Ave, 99 St and 87 Ave, and other signalized intersections up to 99 St and Saskatchewan Dr (As I explained before, traffic congestion extended beyond this intersection during peak hours); and on the other direction 99 St and 79 Ave (w/ Ped signal), and 99 St and 76 Ave. On Whyte Avenue, the following intersections are also clearly affected and interact with the key intersection of Whyte Ave and 99 St, these are: Whyte Ave and 100 St, Whyte Ave and 101 St, Whyte Ave and 102 St (Ped Crossing), Whyte Ave and Gateway Blvd, and Whyte Ave and Calgary Trail; with new traffic signal timing plans (scramble pedestrian phase) and 40 kph posted speed, all these intersections are experiencing even longer traffic delays than in previous years. Finally, in the other direction Whyte Ave and 97 St (Ped Crossing), and Whyte Ave and 96 St.

2. The study undertook traffic data collection in December 9, 2021; however, these traffic counts were not normalized due to seasonal fluctuations and due to Covid 19 pandemic. It is well known that during the pandemic traffic volumes significantly decrease as well as traffic patterns were unusual. This count is useless as traffic volumes along 99 Street were at least 30% lower due to Covid-19 and do not represent normal traffic conditions. As this traffic is by no mean representative of normal conditions the capacity analysis and findings based on these traffic volumes is incorrect.

3. Trip generation assumed high reductions on vehicular traffic due to modal split even when trip generation rates for high-rise buildings usually refers only to the vehicular trip generation. Even more, as this is not a Transit Oriented Development there is no justification for such high reductions. I disagree with these assumptions. Trip generation land use selected for the commercial area may underestimate morning new site trips. Furthermore, other potential land uses at this location may be even more problematic. In addition, the study does not include off-site development traffic even when the area has many off-site developments.

4. Trip assignment is not realistic. A development with direct access to 99 Street will have most traffic entering/exiting at 99 Street, it is common sense. However, as exiting maneuvers turning Left onto 99 Street are difficult, this traffic will likely use the local roads and exit on Whyte Ave. The study assumed this at 100 St. However, the proximity to Whyte Ave and 99 St will not allow this traffic to merge and weave to the left lane on time. Furthermore, reverse traffic patterns will not be the same as assumed by the study due to the difficulty for Left-turns along Whyte Ave during peak hours. Furthermore, the study mention traffic will have to use 99 Street and Whyte Avenue, but it does not provide capacity analysis for this intersection.

5. The capacity analysis uses Synchro parameters (PHF, Traffic Flow) that are not representative of either Whyte Avenue or 99 Street, which leads to wrong results. It does ignore the effect of adjacent key intersections (mentioned in my first point) that will impact traffic operations at the accesses of the development and 80 Avenue (with queue blockages, up-streamed intersections, etc.). The study assumed high pedestrian and bicycle traffic and yet at the intersection of 99 Street and 80 Avenue assumes zero conflicting pedestrian number per hour. Are there not pedestrians crossing 80 Avenue during peak hours? Furthermore, the Ped Signal at 79 Avenue already indicates that traffic volumes at 80 Avenue are metered by the adjacent intersection, which it is very ease to observe during the peak hours, and it is one big problem for 99 Street corridor and Whyte Avenue corridor in the intersections I mentioned on item 1.

6. The capacity analysis looks at the year 2026. I don’t know the reason for this. The capacity analysis must look at the proposed opening day, 10-year horizon as minimum (10-years after the opening day) and 20-year horizon ideally.

7. Because the background traffic is based on inadequate traffic counts that were not normalized for seasonal distribution and due to Covid-19 pandemic effect on traffic volumes and traffic patterns, the forecasted volumes are very low and the analysis find Level-Of-Service LOS A and B along 99 Street. This is clearly WRONG. Just looking at the background traffic right now, it is quite obvious that during peak hours the LOS along 99 Street are LOS E or/and LOS F. To those who are not familiar: LOS is a measure of “quality of service”, LOS A is free-flow operation, while LOS B is reasonable free flow operation. If that was the case during the peak hours along 99 Street then why the City has to implement traffic calming measures on the near-by local streets in Strathcona Neighbourhood? It does not make sense. The fact that short-cutting is still existing on these local streets indicates the poor quality of service during peak hours along 99 Street (and along Whyte Avenue). LOS E is when traffic operations are near or at capacity, there are no usable gaps in the traffic stream, operations are extremely volatile and any disruption causes queuing. This is what we experience driving along 99 Street during peak hours, any vehicle turning left (onto local streets or parking lots of existing developments) create a big queue, any bus stopping create a big queue, any vehicle turning right (entering local streets or parking lots of existing developments) create a big queue, gaps for vehicles turning left or right from the local streets or parking lots of existing developments are also dependent of long queues, entering the traffic stream when vehicles are stopped by the long queues or at the traffic signals. And that is why there are short-cutting issues in the adjacent local streets even now that traffic calming measures are in place. LOS F is a breakdown in flow, queues form behind breakdown points, and the Demand is higher that the capacity of the road. 99 Street and Whyte Avenue experience these conditions too. In the more optimistic scenario these corridors are at LOS E now and in 10-years likely at LOS F. I cannot believe the study claims LOS A and B along 99 Street during peak hours. That is why the traffic volumes need to be normalized and all accesses to the development and adjacent and key intersections along 99 Street and Whyte Avenue must be included in the capacity analysis and in the Synchro Traffic Model. In fact, the access to the building parking must also be included in the analysis.

8. The same problems with the LOS results are obviously on the Volume-to-Capacity v/c ratios that the Synchro model calculates for the 2026 post-development scenario. How is possible to claim v/c ratios of 0.39 or better along 99 Street during peak hours? This clearly shows that the Synchro parameters, traffic volumes, and absence of key intersections are inadequate and render unrealistic results. As example, during the PM Peak Hour, traffic queues back up until Scona Road at 95A Avenue; is it that LOS A and v/c ratios of 0.39?

9. The capacity model does not take into account the friction on local streets due to on-street parking.

10. Considering these conditions, the Synchro model usually underestimate the queues; therefore, it is common and recommended practice to undertake a SimTraffic simulation analysis, providing adequate information for all users, based on at least 5 runs, and PHF adjust to recording interval 3 and Anti-PHF adjust for recording intervals 1,2, and 4. Sorry for the technical information but it seems I need to mention it. This should be a requirement of the analysis.

11. The study claims that based on the traffic counts few pedestrians walked in the north-south direction, and none crossed 99 Street. Again, this is due the fact that the traffic count was undertaken in winter and during Covid-19 pandemic effects. This is an intersection with considerable pedestrian traffic and vulnerable users (older people, children, parents with baby-strollers, etc.) particularly during summer months. Pedestrian traffic is also very significant at the key intersections such as Whyte Avenue and 99 Street, signalized intersections, intersections with pedestrian signals and intersections with pedestrian crossing overhead lights. All in the vicinity of the proposed development and yet not included in the capacity analysis.

12. The study claims that the lack of on-street parking should not affect the proposed development site as residents would need to cross 99 Street to access those parking zones; referring to on-street parking west of 99 Street and East of 99 Street. Exactly one of the concerns I mentioned in my first comments. Furthermore, the study states “the parking garage may accommodate commercial tenant employees and resident parking. No general public parking in the parkade is being considered.” In addition to the 144 parking garage stalls, 7 full-size parking spaces are located on the south side of Building A and Building B.” This means sufficient parking for visitors and commercial is not provided. The study claims “an over-supply of parking could promote increased auto use and represents an inefficient use of space and financial resources” Again, this is not a TOD area to assume that. This means that in-situ surface parking is not provided even for the commercial land uses. This is not consistent to commercial developments provided along a very busy roadway such 99 Street. Commercial sites with high exposure are more likely to attract vehicular traffic from the main street. As I pointed out before, an example can be observed on 80 Avenue and 81 Avenue between 101 Street and 102 Street, where the demand for on-street parking due to the new 1st-floor commercial developments is higher than the supply (even when right-angle on-street parking is provided). Also notice that this area is not fully developed and have not exposure to main roadways. This also confirm that while non-commuting trips can be made by walking or biking, still these businesses attract considerable number of vehicles and required on-site parking. While on-street parking supply of the area was mentioned in the study, the area also has a high parking demand already. Without in-situ proper parking supply, the vehicular traffic wandering in the neighbourhood local streets looking for a parking spot will increase. This is undesirable increment of traffic volumes in the local streets and a safety concerns for the many children walking in our neighbourhood particularly in the vicinity of the school and playground area; just one block away from the proposed development and that is provided as a visitor and commercial parking solution in the same study. All commercial land uses along 99 Street have been requested to dedicate enough surface in-situ parking. Why this development is not?

13. The study states that the development site has convenient access to existing Edmonton Transit Service routes to provide “direct” transportation to several regions of Edmonton. I added the “”. This is not true. This is not a TOD area. And also states “The development site is well-designed to allow patrons, employees, and visitors to consider using transit as primary mode of transportation”. Again, this is not true as this is not a TOD. There are no Transit Centres or LRT stations that could provide “direct” access to several regions of Edmonton. And in the lack of Transit dedicated lanes, all buses experience even worst LOS than vehicular traffic during peak hours.

14. The study recognizes there are not sidewalks on both sides of 100 Street, between 79 and 80 Avenue, and on the east side of 100 Street between 80 and 81 Avenue. And claims pedestrians can walk on the grass and that 100 Street is not a busy roadway. During day-time there is a high demand of on-street parking along 100 Street and in the adjacent streets. Isn’t this lack of infrastructure a safety concern for the high number of residents of the proposed development?

15. The study recognized vehicle picking up waste at Building A could block a portion of the parking garage ramp for a “short period of time”, two or three times per week, and that the “unintended consequence is considered to be “manageable””. I added the “”. Again, this can be addressed with the traffic model and traffic simulation to calculate the actual queue lengths and how they will affect three times per week the traffic along 99 Street.

16. The traffic activity on the back-alley should be addressed properly with the capacity model, and by a road safety study that identify the potential road safety impact that high vehicular traffic along a back-alley can have on vulnerable users.

17. This study is not signed and stamped by a professional engineer. Furthermore, it seems to be the result of many revisions. Why the engineers of the City have not identify the SIGNIFICANT ERRORS AND SIGNIFICANT OMISSIONS, WITH FINDINGS, CONCLUSIONS AND RECOMMENDATIONS THAT ARE INADEQUATE FOR THE EXPECTATION OF A STANDARD TIA?

18. Finally, I would like to note that in the Corporate Authorization is saying that the study was prepared by the consultant, quote: “for the benefit of Casia Developments”.

Furthermore, talking about urban form, the City of Edmonton has a document that provides clear guidelines of how to deal with high-density developments in established neighborhoods, such the City TOD guideline which states:
"Building and Site Design Guidelines – describe qualities that foster the desired relationship between buildings and the street and provide appropriate transitions between shorter and taller buildings.”
“AS REDEVELOPMENT OCCURS AROUND STATION AREAS, THERE WILL BE SOME INSTANCES WHERE LOW- AND MID-RISE APARTMENTS DEVELOP ADJACENT TO EXISTING SMALLER SCALE ROW HOUSING, DUPLEX AND SINGLE-FAMILY HOMES. NEW APARTMENT DEVELOPMENTS SHOULD BE DESIGNED TO CREATE A GRADUAL TRANSITION IN HEIGHT, TO ADDRESS BOTH THE VISUAL APPEARANCE FROM THE STREET AND THE POTENTIAL IMPACTS OF SHADOW AND LOSS OF PRIVACY FOR THE SMALLER SCALE EXISTING DEVELOPMENT.”

WHY THE URBAN PLANNERS OF THE CITY HAS NOT IDENTIFIED THIS CONCERN AND REQUESTED A PROPER GRADUAL TRANSITION IN HEIGHT AS PER THE REQUIREMENT OF THE GUIDELINE? The proposed high-density building will negatively impact the visual appearance from the street and will create a big shadow on the existing smaller scale row houses even on the other side of 99 Street, and will result in the loss of privacy for the smaller scale existing developments. According to the guideline, for single-family row housing the proper transition is to 4-story buildings. This is the type of transition existing right now; there are 4-story buildings across the single-family row housing. The proposed building shall comply with the norm and be no more than a 4-Story building.

Furthermore, the same City guideline present the maximum development intensity of high-density developments in established neighborhood and fronting a collector road (maximum residential development is 125 du/ha). The proposed mix residential/commercial site area is approximately 0.33 ha; therefore a maximum of 41 dwelling units will be anticipated if the site was actually in a TOD area (where the high density is justify by the presence of LRT stations and Transit Centres, which also justify modal split assumptions on favour of transit use). The proposed high-density development is not a TOD but if it was a TOD no more than 41 dwelling units shall be allowed based on the TOD guideline. In fact, because the site is not a TOD, less than 41 dwelling units shall be provided. In TOD sites, the minimum is 42 du/ha. If that is the minimum where high-density is desirable and justify, this is the intensity that should be use in the proposed development site. If we apply that density, this site should be allowed to develop no more than 14 dwelling units providing the urban form transition as per the City guideline for this kind of developments. Yet, the developer wants to get 230 du in 0.33 ha; which is a density of 697 du/ha. No even the TOD areas have such density. AGAIN, WHY THE URBAN PLANNERS OF THE CITY HAVE NOT IDENTIFIED THAT THIS IS AN UNUSUAL HIGH DENSITY (EVEN FOR TOD SITES) THAT WILL NEGATIVELY IMPACT THE EXISTING AND ADJACENT SINGLE-FAMILY ROW HOUSES? This type of residential density is not even allowed in TOD areas next to LRTs and transit centres.

This would be a huge mistake in this area as it is a established community that will not benefit in any way other than promises from developers.

I disagree with the rezoning. The current zoning suits the community. By allowing the proposed zoning would create many traffic issues on 99 street and 80 avenue. The size and type of building that is applying to be built should be built in an area/zone that currently has this type of structure.

The Ritchie Towers Developer Clearly Has Either Not Read Previous Criticism or Not Listened: The New Proposal is Even Worse Than the Preceding One

Though the base is smaller, the main tower has increased from 14 to 19 stories. And there has been no response to the issue of parking in the neighborhood. Only 7 visitor stalls for 230 units remains ridiculous. The residents – most likely renters – would tend to be young and single (around 2/3s would be one-bedroom units) – and have many visitors, often overnight in the case of dating relationships.

This is Not a “Green” Development

It is crucial to reject the builder’s insistence that this is a visionary “green” development. Jorge Arango’s comments (thank you, Jorge, for the skilled work) make this very clear, providing technical and comparative details that suggest that this is a fraudulent claim. It does not meet the criteria of “Transit Oriented Development” (TOD) in the first place, and even by that standard it asks for higher densities than allowed. Not surprisingly, the builders have not lined up any support from environmental groups.

Street Parking and Traffic is Already Approaching a Crisis Point

On a typical morning, 80th Avenue between 99th Street and the block to the west in front of the proposed towers already has around 16 or so cars parked overnight, even though the currently empty lot takes up nearly half the block. Adding a 230 unit building to that site that includes commercial space to be accessed from 80th Avenue will inevitably lead to metered parking in a street that includes a number of houses. The block west of 99th street west of 99th street is already congested due to parking by people working on Whyte (82) Avenue, some of whom now resort to 80th Avenue.

Open Option Parking Has Some Fatal Contradictions in Particular Cases

The developers draw upon the rationale underlying Open Option Parking:

“At the June 23, 2020 City Council Public Hearing (item 3.22), City Council voted to enable Open Option Parking city-wide effective July 2, 2020. Open Option Parking means that minimum on-site parking requirements have been removed from Edmonton’s Zoning Bylaw, allowing developers, homeowners and businesses to decide how much on-site parking to provide on their properties based on their particular operations, activities or lifestyle.”

In particular cases, however, new developments can “download” the burden of increased traffic congestion on pre-existing residents and small commercial establishments in the neighborhood. The latter mostly involve services and professional offices with low traffic and can rely on street parking. The builders can decide to provide only .69 parking spaces per unit and only 7 visitor parking spaces and add 230 units because they are unjustly immune “on the bottom line” from the negative effects of increased parking and traffic congestion. In contrast, the new and existing residents, along with businesses, will find that visitors and customers cannot find parking. All of this of course contributes to a decline in property values and may force some business to close or move.

The Limited Neighborhood Support for the Proposal is Well-Intentioned but Ill-Informed

As the comments by “markster” suggest, the supportive comments are repetitive and vacuous, suggesting that they are simply ill-informed about the details of the project and its relation to existing zoning regulations. If the developers were behind these comments, they surely would have more compelling arguments and provide responses to the existing criticisms. Increasing density does not necessarily add “vibrancy” when the transportation and sewer systems collapse. Moreover, there is not a major housing crisis in Edmonton, which is why prices have been relatively stable with some of the best accommodation values of any major city in Canada. Moreover, there are many other more appropriate sites for such a high-density development.

Raymond Morrow and Joan Reynolds

Again, I oppose the rezoning and the proposed development as it has very negative impacts on the Ritchie community and adjacent communities. I already explained the negative impacts due to the anticipated trip generation, lack of infrastructure, negative impacts on road safety, negative impacts on traffic operations, potential increment of short-cutting , inadequacy of back alleys and local streets to accommodate the vehicular traffic generated by the proposed development, inadequacy of the access to the development, insufficient on-site parking supply, negative impacts on the aesthetics of the neighbourhood, negative impacts on sewer and water pipes, and likely negative impacts on the price of single-family homes in the neighbourhood. In addition, I showed the infrastructure requirements for an area of the city (in Windermere Blvd) where there are high-density developments and the traffic volumes are three time less than traffic volumes on 99 Street or on Whyte Avenue. I also explained how 99 Street has quite less infrastructure compared to Windermere Blvd. This illustrates how the negatives impacts of the proposed high-density development cannot be mitigated on 99 Street and Whyte Avenue without major upgrades to both corridors that are obviously don’t covered by the developer.

Still, I saw some comments claiming this mixed residential/commercial high-density development makes sense in our area as it is a Transit Oriented Development (TOD). However, the proposed development is not a TOD and doesn’t fit the requirements of the City of Edmonton TOD Guidelines (The Guideline) to be a TOD.

1. In the Ritchie area, where it is proposed the high-density development, there are no existing or planned transit centres or LRT stations within 400 or 800 metres. Therefore, BY DEFINITION THE DEVELOPMENTS IN THIS AREA ARE NOT TRANSIT ORIENTED DEVELOPMENTS (TOD). The Guideline shows the LRT stations and transit centres in a map in page 10. The TOD guideline provides the methodology for rezoning but the first condition is already NOT MET.

2. The Guideline states that the Public Realm is fundamental to the success of TOD. However, there are not improvements to the public realm along 99 Street and Whyte Avenue in the vicinity of the proposed development. On the contrary the development will significantly increase traffic volumes and create more conflict points for motor-vehicles, pedestrian, cyclist and vulnerable users. There are no buffer zones between the pedestrian facilities and motor vehicles. There is no cyclist accommodation along 99 Street. There is not boulevard along 99 Street consistent in the entire corridor. There are not (sufficient or at all) left-turn and right-turn bays in the corridor to accommodate high-density developments. There are no transit bays.

3. The guideline states that “Building and Site Design Guidelines – describe qualities that foster the desired relationship between buildings and the street and provide appropriate transitions between shorter and taller buildings.” Therefore, the proposed high-density development of 19 Story building is NOT proper transition in an area of 4 story buildings and one single-family houses.

The guideline states: “As redevelopment occurs around station areas, there will be some instances where low- and mid-rise apartments develop adjacent to existing smaller scale row housing, duplex and single-family homes. New apartment developments should be designed to create a gradual transition in height, to address both the visual appearance from the street and the potential impacts of shadow and loss of privacy for the smaller scale existing development.” Again, this is for TOD sites where the high-density developments are desired. Furthermore, it is clear that the proposed high-density development is not an appropriate transition according to the guideline. According to the guideline, for single-family row housing the transition is to 4 story buildings. This is the type of transition existing right now; there are 4-story buildings across the single-family row housing. The proposed building shall comply with the norm and be no more than a 4 Story building.

4. The guideline states that “The TOD Guidelines will be used to evaluate rezoning applications on sites within 400 metres of existing or planned LRT stations or transit centres.” However, there are not LRT stations or transit centres within 400 metres of the proposed high-density development. So this is not a TOD.

5. The guideline states that “the TOD Guidelines will be applied to … the modification of existing zones and overlays within the zoning bylaw. The Building and Site Design Guidelines will provide direction on what additional or new regulations should be included in: … Direct control zones. These can be applied to sites around LRT stations or transit centres.” Again, the proposed development is not located around an LRT station or transit centre.

6. According to the guideline, when evaluating sites within 400m/800m from a transit centre or LRT stations, one criteria is to review the existing traffic conditions, street grid and infrastructure. 99 Street has 19,800 vehicles per day, and Whyte Avenue has 20,400 vehicles per day in the area of the proposed development. Both are at or close to capacity. There are no Bus lanes or transit centres. Buses experience as much delay as vehicular traffic. It is unreasonable to think that people in the new developments will prefer to use transit for commuting purposes, when they will experience high delays for commuting (worsen by the new developments). Unless rapid bus transit facilities (dedicated lanes only for transit) are provided along 99 Street, there is no evidence that modal-shift will increase. As described in other comments the proposed high-density development can be estimated to generate 1,862 new trips during the day (931 entering, 931 exiting); 108 new trips during the AM peak hour (29 entering, 79 exiting); and 192 new trips during the PM peak hour (108 entering, 84 exiting), combining residential and commercial trips. Reductions to transit are typically already included in the trip generation rate for high-density buildings; so there is no justification for major reductions on the site generated traffic volumes due to transit. In addition, although minor reductions can be done to the commercial traffic due to by-pass traffic, still the site needs to have the infrastructure and surface parking to accommodate the generated trips at the site access. Again the infrastructure and proposed access to the development are inadequate. Furthermore, this site does not qualify as a TOD.

7. According to the guideline, when evaluating the land use and intensities for sites that are actually with 400 metres of transit centres or LRT stations; for sites fronting a collector road the maximum residential development is 125 du/ha (dwelling units per hectare). The proposed mix residential/commercial site area is approximately 0.33 ha; therefore a maximum of 41 dwelling units will be anticipated if the site was actually a TOD. The proposed high-density development is not a TOD but if it was a TOD no more than 41 dwelling units shall be allowed based on the TOD guideline. In fact, because the site is not a TOD less than 41 dwelling units shall be provided. In TOD sites, the minimum is 42 du/ha. If we apply that density this site should be allowed to develop only about 14 dwelling units. Yet, the developer wants to get 230 du in 0.33 ha; which is a density of 697 du/ha. No even the TOD areas have such density.

8. The guideline also explains the requirements for public realm for blocks in TOD, such as mid-block accessways of minimum 10 metres width, etc.) None of those conforms to the proposed plan. And again, this development is not a TOD. There are more requirements in the guideline that are not met in this area.

Conclusion: the proposed development has an intensity (dwelling units per hectare) way above the maximum for TOD in existing neighbourhoods; even more, the development doesn’t meet the criteria to be a TOD as there is no LRT stations or transit centres within 400 metres. It is false to say this development meet the criteria for TOD. The guideline also shows that the building height is not adequate in this area and the proposed building shall not be above 4-story building (for reasons presented in the guideline).

People move to this area of the city to be in a small quaint community, central to the hubbub of town, but away from the busy gawdy towers of downtown. This is not right for this area. Thanks

I oppose the rezoning and the proposed development as it has very negative impacts on the Ritchie community and adjacent communities.

This application for rezoning has been in process since many years back. The developer was already allowed to have a higher density that the typical for the area; and yet, the developer asked for an increase (150 dwelling units in 2022). I already presented the technical objections to the City, and yet to my surprise the developer is asking even for a higher increase on density (230 dwelling units). Even more, no formal public engagement has been organized explaining how to solve the negatives impacts this development will have in our community and our transportation system.

I am a Civil Engineer with a Master in Science in the area of Transportation Engineering from the University of Manitoba, Canada. I have over 14-years of professional experience in Transportation Engineering for development projects, such as the proposed in our area. I am an expert in Transportation and Parking Impact Assessments, traffic modelling and analysis, traffic calming and road safety. In addition, I am an expert in traffic monitoring and worked as research associate and Manager of the Manitoba Highway Traffic Information System (MHTIS) from 2005 to 2008. I can provide an overview of the anticipated potential impacts of the proposed residential/commercial development, as follows.

1. Lack of infrastructure to meet the existing and additional capacity demand. Both 99 Street and Whyte Avenue are already at capacity resulting in AM and PM peak and off-peak hours traffic congestion during weekdays and weekends, traffic shortcutting on local streets (despite the traffic calming projects on the Strathcona Neighbourhood), and speeding on local streets. Most intersections along 99 Street are at or close to capacity with very long delays and queue lengths blocking adjacent intersections, extending for many blocks. Left-turns along 99 St are problematic and required Left-turn auxiliary bays. Left-turns from local streets into 99 St are even more problematic with almost no gaps for safety maneuvers. The mix of vulnerable users with traffic congestion results in challenges to safety and the capacity to accommodate existing traffic. 99 Street requires improvements to accommodate existing traffic but it lacks the Right-Of-Way for additional thru lanes, auxiliary turn lanes, while maintaining the pedestrian and bicycle infrastructure.

Similarly, most intersections along Whyte Avenue are at or close to capacity with very long delays and queue lengths blocking adjacent intersections, extending for many blocks. Recent improvements on traffic signals along Whyte Avenue are towards providing better accommodation of pedestrians and bicycles, resulting in longer delays for vehicular traffic. It is unclear the impacts to emergency response vehicles particularly to reach the University Hospital. There is no other main link that connects through on the East-West directions, forcing additional traffic into 99 Street to reach 63 Avenue or to the local streets to reach Saskatchewan Drive. Similarly, there are no other close North-South links other than 99 Street.

This shows the lack of transportation infrastructure to meet current needs. Despite this facts, new developments have been completed on Strathcona Neighborhood, and there are at least two other significant size developments along 99 Street between Saskatchewan Drive and Whyte Avenue. These developments will add more traffic to a road network that cannot handle the demand. That is why there is still traffic short-cutting to the local streets even when the City has completed various traffic calming projects in the area.

On a high level review, the proposed residential/commercial development has the potential to generate the following amount of trips (using trip generation rates from the ITE Trip Generation Manual, version 11): approximately 1,862 new trips during the day (931 entering, 931 exiting); 108 new trips during the AM peak hour (29 entering, 79 exiting); and 192 new trips during the PM peak hour (108 entering, 84 exiting), including residential and commercial new trips. This new traffic will most likely use 99 Street and Whyte Avenue; however, both 99 Street and Whyte Avenue are at or close to capacity, meaning there is more traffic than what can be accommodated by the existing infrastructure. Furthermore, other developments (known as off-site developments) in the area will add even more traffic.

The negative impacts are the aggravation of Level-Of-Service on the main arterials (99 Street and Whyte Avenue) which applies both corridors, not just the development’s adjacent streets. The negative impact on vehicular traffic capacity will also negatively impact the mobility, accessibility and road safety of vulnerable users (i.e. pedestrians, cyclists, etc.) which are very characteristic in this area and extend to seniors, local children, school children, parents with baby strollers, cyclists with children, etc.

Before even consider a development of this magnitude, the developer should provide a Traffic Impact Assessment and road safety analysis, that includes off-site developments, weekday and weekend analysis, peak and off-peak analysis and roadway and traffic control improvements for 99 Street and Whyte Ave, that result in acceptable traffic operations. Also, the analysis should include not only adjacent intersection but intersections that are clearly affected by the development (in example, along 99 Street, peak hour congestion is happening from north of Saskatchewan Drive to south of 51 Avenue, possible south of Whitemud Drive). The solutions to mitigate the impacts of the development should ensure many of these intersections are properly analysed in the study and integrated solutions are provided.

The proposed high-density development can be compared to buildings on Windermere Blvd and Ambleside Drive SW but without the transportation infrastructure to properly accommodate high density developments. As example, Windermere Blvd at Ambleside Drive SW has high-density developments which required four lanes per direction (on Windermere Blvd) including auxiliary left-turns and auxiliary right-turns, traffic signals at the high-density building locations, pedestrian facilities separated from traffic by ample buffer-zones, as well as setbacks for the high-density buildings; with four lane boulevards on the side streets (Ambleside Drive SW) where vehicles access parking lots separated from pedestrian and bicycle traffic, through two-lane internal roadways. That is the infrastructure required for high-density developments even when traffic volumes are quite smaller than those of 99 Street. By comparison, at the location of these high-density buildings, Windermere Blvd has 6,700 vehicles per day and the side street 2,300 vehicles per day according to the City of Edmonton Flow Map for 2020 (almost as much traffic the proposed development will generate along without including existing developments). By comparison, 99 Street has 19,800 vehicles per day, and Whyte Avenue has 20,400 vehicles per day in the area of the proposed development. That is about 3 times more traffic than on Windermere Blvd; but quite less infrastructure. It is quite obvious the existing infrastructure on 99 Street and Whyte Avenue is quite less compared to the infrastructure provided in Windermere Blvd for high-density developments and 3 times less traffic. Therefore, the proposed high-density development is proposed on a 3 time more congested roadway, with less infrastructure (lanes for vehicles traffic, buffer zones, pedestrian facilities and building set-backs, ample access two-way roadways with high visibility, four-lane roadways boulevard side streets, etc.), and with impacts on parking, vulnerable users, road safety, traffic operation, travel times, neighbourhood aesthetics, etc.

2. Constrains on Right-Of-Way which made very unfeasible and very costly to introduce real countermeasures to the negative vehicular traffic impacts. As mentioned before, how additional lanes can be provided to meet traffic demand? Furthermore, even for medium-density developments and commercial development along Whyte Avenue (in the Bonny Doom area) can be observed that service roads have been provided for such developments parallel to Whyte Avenue. As described also in the case of Windermere Blvd, those are the kind of roadway improvements that should be provided for a mix commercial and high-density residential development in order to accommodate traffic demands and provide a safe environment for the area residents. However, how this type of roadway cross-section can be provided for the proposed development at cost of the developer?

3. The high-density development will likely result in detriment on the mobility, accessibility, and road safety of vulnerable users (i.e. pedestrians, cyclist, children, seniors, etc.).

4. Increase and aggravation of short-cutting local and non-local traffic throughout the neighborhood local streets.

5. Negative impact on the adjacent local street classification. The anticipate higher traffic volumes, both for the residential and commercial land uses, will likely change in practice the local street classification to a collector requiring higher traffic control (i.e. full traffic signals) and the introduction of turning lanes. This issue has many negative impacts on vulnerable users, traffic operations at the local streets, road safety, neighborhood quality of life, and priced of the single-family houses, among others. As example, in the case of Windermere Blvd the access to the high-density development provides a four-lane side street connecting to a service road to access the high-density development parking.

6. Aggravation of the current road safety standard (intersection conflict points) with the introduction of accesses with high vehicular traffic (residential and commercial) which more likely have a negative road safety impact on pedestrians and cyclists (vulnerable users), and vehicular traffic.

Most commonly, the access/exit to each property within our neighborhood is provided through the back alleys and is therefore spread out, creating less traffic delays and fewer less-frequent road safety conflicts (e.g. potential conflicts between traffic along the back alleys such as pedestrians, cyclists and vehicles and the traffic entering/exiting from the typical residential single-family detached home). These back alleys with low traffic volumes also allow for reasonable safe accommodation of pedestrian and cyclists, such as children in their bicycles. However, for the proposed development the access/exit to the site, either to the front road or the back alley, will experience higher traffic volumes that those of one alley in our neighbourhood. This is an undesirable situation as vehicles entering/exiting the proposed development will likely ended being backed-up, negatively impacting the traffic operations at near-by intersections, back alleys, and adjacent properties. This is also a considerable high increase of vehicular traffic on the back alley. This situation is will make the back alleys and local roadways to be unsafe for pedestrians and cyclists (including school routes to the various schools in the area). Buildings of this magnitude usually have accesses provided on ample spaces, where pedestrian traffic is minimal and with high visibility. Nothing of that is provided in this case.

7. Aggravated parking demand for both residential and commercial uses not met by the parking supply. The proposed development will generate high demand for new parking, in both the residential and commercial land uses, which will affect availability of on-street parking not only at the adjacent local roadway but also at the near-by local streets. Additional traffic generated by the commercial development, given the exposure to the main arterial, will generate more friction between parked vehicles and local traffic, adding to congestion.

The on-street parking demand that is created due to commercial land uses is typically higher as can be observed in many commercial developments that have been allowed in the area. An example can be observed on 80 Avenue and 81 Avenue between 101 Street and 102 Street, where the demand for on-street parking due to the new 1st-floor commercial developments is higher than the supply (even when right-angle on-street parking is provided). Also notice that this area is not fully developed.

Typically, there is the assumption that the commercial land uses will not require that much parking demand in a mix-land use area. However, as it seen in the case example described above, the on-street parking demand is not met by the on-street parking supply even when the commercial land uses don’t have direct exposure to the main arterial/roadways, such as Whyte Avenue and 99 Street. Furthermore, the proposed development does have direct exposure to 99 Street and has the potential to attract even more traffic due to future commercial businesses, which reasonable will require a big surface parking, which is not provided in this case.

Commercial and visitor parking demand of the proposed building will likely compete for the on-street parking stalls of the adjacent residential areas, the problem spilling over to even many blocks away from the proposed development, creating further shortage of on-street parking supply and higher friction between parked vehicles and local traffic, and traffic generated by the commercial development wandering on the residential local streets looking for available on-street parking. Please notice that the need for parking generated by small businesses along 99 Street north of Whyte Avenue is already resulting in on-street parking allowed along 99 Street and on adjacent local streets, and in some cases surface parking lots had being provided to accommodate for this.

8. The green areas provided by the proposed development are quite insufficient compared to the standards of our neighborhood. Our current neighborhood has a higher rate of trees per dwelling unit while the proposed high-density development will have significantly less. The amount and size of the trees in our neighborhood is a desirable feature of our neighborhood that cannot be overlooked; it makes the neighborhood environment of a higher quality and provides aesthetics very desirable to its current residents. Walking on our local streets is pleasant as the landscape is dominated by the trees rather than concrete and glass. All this is practically lost with the proposed high-density development which not only will generate the pollution equivalent to eight blocks in less than one quarter of a block but will change the urban form dominated by gorgeous full grown big trees to an urban form dominated by a concrete landscape. It is safe to say this change on the aesthetics of the area will negatively impact the property value of the single-family houses in the area with economical loses for us, the residents and owners of single-family houses in the neighborhood.

9. This development already got an exception to increase the number of floors which is above the standards of the neighbourhood. However, the developer goal seems to be maximizing their profits, so now it is proposing buildings that are compared to those on Windermere Blvd and Ambleside Drive SW but without the transportation infrastructure to properly accommodate high density developments. Again, Windermere Blvd is a concrete and glass aesthetics, with four lanes per direction including auxiliary left-turns and auxiliary right-turns, traffic signals at the high-density building locations, pedestrian facilities separated from traffic by ample buffer-zones, as well as setbacks for the high-density buildings; with four lane boulevards on the side streets where vehicles access parking lots separated from pedestrian and bicycle traffic, through two-lane internal roadways. Yet, the roadways supporting the high-density developments carries 3 time less traffic than 99 Street or Whyte Avenue. Furthermore, those roadways have higher number of lanes, ample buffer zones to protect pedestrian facilities also separated from the actual buildings. Access to those high-density developments are provided by 4-lane roadways (no local streets or back-alleys), and 2-lane service roads. So, the proposed high-density development will have access to a back alley and local streets almost directly into 99 Street which carries 3 times more traffic and has considerable less lanes and cross-section. This will result in the negative impacts explain in previous items in addition to negative impacts on the neighbourhood aesthetics. The materials provided should explain how the transportation system (99 Street, side roadways, building accesses, etc.) will be improved by the developer to sustain a high-density development to reasonable standards like those of Windermere Blvd, mitigating the negatives impacts created by the high-density development.

10. With so many new proposed dwelling units using the sewer and water system we will overwhelm our already overburdened and dated sewer and water systems. The proposed high-density residential building will generate the demand on the sewer and water systems equivalent to that of more than eight residential blocks plus commercial land uses. This demand will be overflowed to our existing old sewer and water systems in just one quarter of a block, or 3% the infrastructure needed for eight blocks.

The proposed development may be design to do not get any negative impact to its residents; however, if the sewer system overflows the potential negative impact will likely be on the existing single-family resident homes which are less protected. Basement sewer back-up and flooding may become a new reality for our neighborhood. Additionally, our sewer is already frequently plagued by noxious odors. As of right now, every year, there is the need to bring “cleaning” trucks to do maintenance to the sewer system in the vicinity and at the intersection of 99 Street and 80 Avenue, where the high-density development is proposed. The high-density developments will most likely worse these issues.

The water system is also old in the area with constant notices from the City that lead may be on our drinkable water. This is due to the old pipes still being in place that carry water to and from our properties, which may contain lead. What is the impact that the new high density development will have with a higher demand for drinking water? Does more water volumes and flow through these already aged pipes will likely increase the rate at which lead will fall from the pipes into our water? Upgrades to the system would be very costly and likely prohibitive.

11. The property value of the low density properties in the area will most likely be negatively impacted. The less desirable urban form (dominated by big concrete landscapes rather than welcoming homes surrounded by big trees and plenty of green areas); considerable high traffic volumes with not equivalent roadway dedication, most likely traffic overflowing onto the existing roadways (including main arterials, local streets and back alleys); the negative impact on the outdated sewer and water systems; and the negative impact on the safety and quality of life of residents of the area will also negatively impact the value of the properties in the area.

12. If a high-density high-rise residential development, such as the proposed, is approved in the area despite all the negative impacts and lack of feasible mitigation measures, the door will be open for more developers to do the same. The same developer of this proposed residential/commercial development is a clear example of this negative impact. Initially, they have requested to be allowed to build a 5 story building (I believe going from 3 story building to 5 story building, which passed under-noticed by the residents in the area), which they were allowed by the City without public consultation and without providing clear explanation to the adjacent neighborhood residents about how the negative traffic impacts of such development will be properly addressed in the very constrained and at capacity transportation system in our area. Yet, the developer was looking to increase the size of the development in about 500% by 2022. Despite the fact, I did presented my concerns to the City; the developer is now looking for a further increase, about 767%. All these without proper public consultation. This online public consultation is not a proper way to get feedback from the community as the project is vaguely explained while there is no explanation of what are the negatives impacts and what feasible countermeasures will provided the developer (if any). It seems the developer has been in contact with the Ritchie Community League which by no means represents the community of the adjacent neighbourhood. I tried to present my concerns to the Community League in a formal presentation but I was asked only for a letter with my concerns in 2022. It is my understanding that the developer offered to help the Community League with projects they may have (as I was informed by the developer’s consultant in a phone call in 2022); however, that won’t solve the issues of real concern like the required and very costly improvements for the 99 Street and Whyte Avenue, aesthetics, road safety, walkability, bike-ability, environmental quality, infrastructure and property value of our homes; which are the real concern for the neighborhood. I see comments in this website affirming the high-density development will benefit the area but they don’t explain how. It will not benefit the area as it is quite obvious comparing this high-density development context in a very high congested 99 Street to a high-density development context in Windermere Blvd where traffic is three times lower and the supporting infrastructure overwhelmingly better and adequate for high-density developments.

this development looks like a slay moment

This project aligns with the City Plan.

This type of development helps with housing shortage concerns. This gives future residents an opportunity to live near the local shops and Mill Creek School.

I support the increase in height of the tower as this improves vibrancy on Whyte Ave because this brings more people to interact with local businesses. Also, it adds business space in the building.

This is also a benefit for the municipal government as this adds housing without adding more roads to maintain (no additional tax burden). Residents get to live right next to a bus stop and near future mass transit along Whyte Ave, which gives people lots of options for mobility.

One concern is cars. Since this is a transit-oriented development, please set a maximum for parking available.

Another concern is living space. This should be livable for families. Please don't add setbacks as this is a potential space for people and businesses. Please allow for more 2+ bedroom suites.

In response to the comment made by ‘markster,’ I live walking distance from this development and am in no way associated with the developer.

I would just like people to have places to live and for our local businesses to succeed.

Electronic and social media is the only mode of communication between the community and the City. This web based engagement process should be only a part of the consultation with the community. I appreciate consultation with the Richie Community League, but do they represent any constituency? I understand that persons can attend the Council meeting and SDAB if necessary, if they have the time and ability to take a day off of work, travel downtown and pay the fees associated with the SDAB.
Where is the public engagement and consultation? Has the developer or the City made a concerted effort to engage members of the community? What would such engagement reveal? This is a crucial part of this project which has not been described in the documents. It appears that the bus routes and building access is much more important than the opinions of the community residents who actually live in the vicinity. Public engagement should be the first step in development, not the last.
Perhaps the developer and the city should establish an information kiosk at the site to solicit comments on their project. Perhaps the proponents should do some door knocking and actually talk to people and document their concerns. Are they afraid to find out the community opinion? Do the proponents prefer to plan the development in isolation with consultants from their offices in Canmore?
These towers are an inappropriate development in the middle of a low rise and residential area. People have invested their lives in the community based on current zoning conditions. Planning in the City of Edmonton has degenerated to Rezoning properties for special interests. Existing zoning means nothing, just change it.

It will be great to have the blank spot, empty lot that this location is filled. As it is along 99 Street and on 80 Ave this will be in an area which is already multi-family living including condos, and walk up apartment buildings, so the location seems to make sense. I like the idea of commercial at the base of the tower. However, I am unsure if it will be utilized there is already plenty of empty commercial at the base of some of the new towers closer to the tracks and it isn't really helping to activate the streets. It is too bad that transit (i.e., buses) in the area have been cut back to 1 possible route because with this influx of residents it may be more difficult for people to travel in the area.

Generally, I am in support of this proposal and think it is a good opportunity to improve and create density along 99 Street.

The purpose of land use planning is to communicate a common vision for an area. It establishes a framework for individuals and corporations wanting to live or to provide goods and/or services in a certain geographic area. Zoning sets the rules for all current and future property owners. It provides security in that every development will meet an agreed upon standard. Ad hoc, piecemeal re-zoning such as is proposed here represents a total disregard for the those who have invested in their properties. It is a slap in the face to those who complied with the existing rules and expected others to do the same. If approved, this would be further evidence of a lack of vision on the part of the City of Edmonton as well as a lack of respect to existing residents. If increasing the density of development is a longterm goal, it should have a coordinated, longterm plan. Not piecemeal rezoning.
I DO NOT support this proposal.

I support this proposed redevelopment. It's in line with the city plan and will bring some much needed density and street activation on 99street. Hope this one goes through

There are definitly some comments here that are not made by residents. These so called comments/feedabck - you tell tell, come from the same idea. Even the words use are similar. I suspect that all submitted in the same day are from the developer since there is no proof way to validate who is leaving the feedback in the first place.

Be carefull about mis-information here.

I really like the concept behind this project. It's crucial to think about its impact on future generations, especially as we expand the city. The project makes perfect sense since it's located close to Whyte Ave and on a main street. It aligns with Edmonton's plan for a 15-minute city and would contribute to a livelier community. The development is excellent because it will utilize an empty lot along a major road. Having more people living in the area would also benefit the local businesses in Old Strathcona.

Love the look of this project! It is imperative that we look ahead to the future of this city and the forward-thinking vision of where we want our city to be in a few decades time.

This lot makes sense for the density that is being proposed, though attention must be paid to what is the plan for parking, etc?

This coincides with the plans for the type of road 99th is and would only help foster a more vibrant neighbourhood. Much moreso than an empty lot along such a main road.

This is a fantastic project! I hope greatly that it is approved.

Projects like this will allow us to achieve our goals of 50% of population growth being infill development and 50% of trips made being by active or public transportation as laid out in the City Plan.

Increased density in the area will also benefit the local businesses of Old Strathcona.

We are in a housing crisis and it is important that we approve projects to increase the number of dwellings in our city. Housing is a basic human right and we will need a lot more of it as our city continues to grow.