POLICY REPORT
URBAN STRUCTURE

TO:

Standing Committee on Planning and Environment

FROM:

Director of City Plans, the Director of the Housing Centre and the Director of Social Planning, in consultation with the Chief Building Official, the General Manager of Engineering Services, and the Director of Legal Services

SUBJECT:

Congregate Housing for Seniors

 

RECOMMENDATION

GENERAL MANAGER'S COMMENTS

COUNCIL POLICY

In June 2000, Council instructed staff to undertake public consultation and report back on proposed amendments to the definition of congregate housing, parking standards for congregate housing, and draft guidelines regarding design and function of congregate housing for seniors.

Zoning and Development By-law No. 3575 defines congregate housing as follows:

"Special Needs Residential Facility - Congregate Housing, which means any facility that provides residential units for six or more persons aged fifty-five years or over who are not a family, where shared separate kitchen and dining areas are provided and where accommodation for a resident housekeeper may be provided."

In February, 1992, Council adopted Special Needs Residential Facility Guidelines to ensure that a special needs residential facility is compatible with the surrounding neighbourhood.

SUMMARY AND PURPOSE

Congregate housing is housing and a package of non-medical services for seniors. It typically includes individual residential units, large communal areas for dining, socializing, and activities, and services such as meals, housekeeping and recreation. The projects are designed to accommodate seniors as they age. There are currently eight congregate housing projects in Vancouver, and five proposals in the rezoning or development process.

In June 2000, Council considered a report on congregate housing, and its increasing importance due to an aging society, shifts in provincial funding, and increased development interest. The report noted the difficulties in making congregate housing affordable to low and modest income seniors, in the absence of government subsidy. Without funding support, the tension between affordability and livability remains a fundamental dilemma. Council wrote to the Province asking them to consider an expansion of the Shelter Allowance for Elderly Renters program, or other funding supports.

In the June 2000 report, staff proposed a revised definition of congregate housing, detailed the requirements of this use, and introduced a set of guidelines to clarify the City's expectations regarding key features of a livable residential environment that supports seniors as they age. Revisions to existing parking standards were also proposed. Council instructed staff to consult the public and report back.

The report and guidelines were sent out to approximately 50 organizations and individuals involved in or interested in supportive housing for seniors. This mailing was followed by a public open house, and a presentation to the Seniors Advisory Committee. Seventeen responses were received, from diverse respondents, including the Vancouver Richmond Health Board, the Urban Development Institute, Simon Fraser University - Gerontology Research Centre, seniors groups, architects, and housing groups. (Complete mailing and response list in Appendix D)

Most comments were in support of the proposed amendments and the guidelines, particularly with respect to ensuring livability and aging in place design. Affordability was the overarching concern. Many respondents commented on the difficulty of providing this housing option for lower income seniors, and suggested ways to increase affordability: through increased government support and cooperation, and/or through relaxations in the design guidelines and other City requirements. Additional concerns focussed on the definition of congregate housing as a Special Needs Residential Facility (SNRF), an institutional rather than a dwelling use, and issues such as conversion of rental housing to congregate housing, congregate housing in single family zones, and strata-titling. Further, there were many comments received about various aspects of the guidelines.

The purpose of the report is to share with Council the results of the public consultation, and to seek Council approval for a revised set of guidelines that respond to the public comments. Staff note that the proposed changes to the definition of congregate housing, and the proposed amendments to the Parking By-law remain unchanged from the June 2000 report.

DISCUSSION

a) Introduction

Congregate housing for seniors is evolving in response to a diverse, aging population. The guidelines and policy directions have been developed in the context of existing and proposed congregate housing projects. Further changes to the way congregate housing is developed and operated will occur, but what those changes will look like, and what their impact will be is not known at this time. For this reason, the guidelines will need to evolve as staff gain more experience with this use.

The following pages provide a discussion of affordability and related issues, the role of government, and the definition of congregate housing, as well as revisions to the guidelines and issues requiring monitoring.

b) Affordability

Affordability is an overarching concern. The June 2000 report to Council noted that congregate housing is typically not an affordable housing option, given the high cost of land, new construction, and staffing, as well as the lack of government funding which means all costs must be met by residents. A number of respondents raised this same point and commented on ways that affordability could be increased. Two general areas were discussed: increased government support and cooperation, and relaxations in the design guidelines and other City requirements. Suggestions ranged from FSR exclusions and changes to unit size and common space requirements to waiving permit and DCL fees. At the same time, most respondents noted that attempts to achieve affordability should not compromise livability and echoed the guidelines in the importance of aging in place design.

As with other City guidelines, the congregate housing guidelines focus on design and livability issues. Their primary purpose is to ensure that all congregate projects meet livability and aging in place design criteria, resulting in residential units and common areas that are livable and functional for seniors. Aging in place design means not only design details, but adequate space in the living and bathroom areas to accommodate the use of mobility aids (e.g. walkers) and to enable a support worker to assist a resident. While the guidelines apply to all congregate projects, high end and low end, their effect is to establish minimum standards that preclude the development of inadequate or inappropriate congregate housing.

The impetus for the guidelines is the concern that the lack of funding for congregate housing could lead to the development of unlivable and dysfunctional congregate housing for low and modest income seniors. In balancing the issues of livability and affordability, the staff approach has been to allow some flexibility for projects which demonstrate affordability, but not to support relaxations to the point where livability and usability are lost. The guidelines cannot replace the need for government funding, but will assist in the assessment of affordability/livability tradeoffs in individual projects. However, the basic aging in place design considerations required in congregate housing may mean that it is generally not viable
for low and modest income seniors, except in special circumstances, such as free land and charitable contributions, in the absence of senior government subsidies.

Staff note that work is currently underway at the provincial level and by the Vancouver/Richmond Health Board, toward promoting affordability. Initiatives include the Homes BC Supportive Housing program, a recent program which has funded 15 supportivehousing projects in the Province, release of policy reports and design discussions on supportive housing and, at the Health Board level, some funding for services within congregate or supportive housing projects.

c) Role of Government

The June 2000 report resulted in letters from the City to the Provincial Ministers responsible for health and housing, urging the Province to:


As well as supporting Provincial and V/RHB involvement in funding congregate housing, some respondents identified actions the City could take. These included increased collaboration and coordination between the City, the Province and V/RHB; City waiving of DCLs, permit fees and property taxes; and City negotiation of a percentage of affordable units in all market projects.

City staff are currently participating in a review of the Province's supported housing program and City and V/RHB staff have agreed on the need to work jointly on any congregate projects the Health Board may intend to support with operating funding. Other opportunities to collaborate may present themselves. Staff do not agree with waiving development fees or property taxes for this use, based on equity with other land uses. Dedication of a percentage of units for lower income seniors, and restriction to rental tenure are approaches that the City has used in rezonings requesting significant increases in density. The City's standard policies for assisting non-market housing are available for congregate housing serving low and modest income seniors.

With respect to interim City-wide DCLs and CACs, these are typically applied to congregate housing projects. DCLs and CACs are not applied to social housing projects, but the definition generally excludes unsubsidized congregate housing. As part of the Financing Growth review, staff are currently reviewing how CAC and DCL policy might be applied to housing projects which are developed by non-profit groups and which provide some degree of affordability, but do not qualify under the present policy. This would include some congregate housing projects. It is possible that, for CACs, an in-kind contribution may be accepted, e.g. affordable congregate housing secured by a Housing Agreement.

d) Defining Congregate Housing as a SNRF

The proposed definition of congregate housing aims to better describe the congregate housing use as a form of supportive housing for seniors. One respondent agreed that the revised definition better describes the congregate housing use; two others noted concerns related to congregate housing being classified as an institutional use - Special Needs Residential Facility (SNRF), in the Zoning and Development By-law. They noted that because congregate housing is a housing option for independent seniors, the SNRF designation inappropriately links it with licensed residential facilities with higher levels of care. Congregate housing would likely be better designated as a dwelling use.

Staff agree that a review of the most appropriate land use category for congregate housing is needed, and that this should be done in the context of the overall SNRF classifications. Staff note that a full review of the SNRF classification system is warranted, since these classifications are now close to 15 years old. However, a full review would require significant staff time and is beyond current resources.

e) The Guidelines

In addition to the general comments related to affordability and livability, most respondents also had specific comments about various aspects of the guidelines. In general, most respondents were supportive of the direction of the guidelines, their focus on livability within the project, and compatibility with the surrounding land use. Some aspects of the guidelines received no comment at all, such as outdoor open space. Many of the comments were aimed at improving affordability by moderating the cost impact of the guidelines.

The following sections provide a discussion of the key topic areas covered. They are organized as follows: a summary of what the guideline currently states, comments received, and staff response.

i) Minimum Unit Size

Background: The guidelines note that the unit size and design should be suitable for people using mobility aids, and provide for aging in place. Dwelling units of at least 28 m² (300 sq.ft.) are needed to ensure that they are functionally usable, can accommodate the resident, and belongings, and provide adequate space for a support provider to assist the resident Comments: In general, most respondents felt that the minimum unit size of 28 m² (300 sq.ft.) was too small to accommodate the needs of an aging senior, but supported small units if they could ensure affordability. An additional concern was whether home support assistance could be effectively delivered in this small space. There was one comment that units as small as 200 sq.ft. should be allowed. Most respondents felt that units should include some kitchenfacilities to allow the senior to prepare beverages and snacks, regardless of the meal service provided.

Response: For now, staff recommend that no change be made to the suggested minimum unit size of 28 m². The guidelines already provide for smaller units if they can be shown to be functionally useable, and offer increased affordability. As experience with this use increases, the suitability of this guideline will become clearer, as will the suggestion for kitchen facilities in every unit (not required currently in the guidelines). Staff note that it is a considerable challenge to design a livable unit with an adequately sized bathroom and some storage space, within 28 m².

ii) Common Space Requirements

Background: The guidelines state that common areas should be adequately sized and designed to foster social interaction and activities, and to provide for visitors. Size standards for the dining and common lounge areas are included. With respect to common lounge space, the guidelines call for one large space as well as smaller common areas and single purpose rooms, and note that lounges should be provided on residential floors, especially where the units are small or where there are many units per floor.

Comments: A few respondents noted that the guidelines require too much common lounge space: it is expensive to provide, non-revenue producing, and not well used. Further, it was suggested that the requirement for lounges on residential floors should be optional where main floor lounge space is adequate. One respondent felt that the location of lounges is not as important as having a number of them, flexible in design with different functions suggested/provided, so they can serve seniors in a variety of ways: entertaining visitors, playing cards, having coffee, reading the paper, etc.

With respect to the dining room, a few people suggested that choice around dining options is very important, for example, restaurant style seating was more appropriate than timed sittings. These are operational choices and are outside the scope of the design guidelines. One person suggested that having two or three small dining rooms was more pleasant and less institutional than one large dining room.

Several respondents commented on the need for FSR exclusions. They felt that common space/non-revenue producing space should be excludable from FSR calculations, particularly where this would aid in the provision of affordable housing. This would be seen as an incentive on the part of the City to encourage developers to build this type of housing.

Response: Staff note that common space is necessary to fulfill the congregate aspects of successful congregate housing. It is part of the principal use, not an incidental amenity space.However, the guidelines have been revised to respond to these concerns. The guidelines now stipulate a total amount of common space to be provided, with less emphasis on where it is provided. With respect to the dining room, no changes to the guidelines are recommended, as they already provide for variations in size. Staff note that both of the two recently completed projects, serving lower to modest income seniors, were able to exceed the common space and dining room requirements.

As for FSR exclusions, since most congregate housing projects require rezoning, total FSR and how it is used is negotiated on an individual project basis, aided by a pro forma analysis. In this way, projects are assessed individually, and FSR is determined on a case by case basis. In this way, staff can include factors such as neighbourhood compatibility, affordability, and livability in their review. This approach is consistent with other uses that have large common spaces, such as SNRF - Community Care - Class B.

iii) Bulk Storage Space

Background: The guidelines currently note that all bulk storage space should be well lit, easy to access and have electrical outlets. It is desirable to provide it within the unit, where possible. The June 2000 report suggested that the FSR exclusion for bulk storage space that typically applies to multiple dwellings also apply to congregate housing.

Comments: Several people commented that bulk storage was a necessity for seniors - for large personal effects as well as the storage of mobility aids. They called for greater clarity and suggested that the exclusion be stated in the guidelines. It is interesting to note that one respondent felt that the bulk storage space exclusion be doubled, while one other respondent felt that bulk storage space was not needed and a useless expense.

Response: The guidelines and the amendments to the Zoning and Development By-law have been revised to include the FSR exclusion outlined in the past Council report. Further, a guideline has been included to provide for scooter storage and charging.

iv) Staffing for 24 Hour Emergency Response

Background: The June 2000 report notes that there is no category in the Building By-law specifically for the congregate housing use, which, from a fire and safety perspective, could be viewed as being in between institutional and residential, given the age and needs of the residents. To address this gap, congregate housing projects to date have been accepted under the residential classification, but with some additional enhancements, including an emergency call system that is monitored 24 hours a day by on-site staff, a fire safety plan, and having two or more fire compartments on the same floor to address the lesser mobilityof the typical congregate housing resident. The two recently completed developments have been able and willing to provide these enhancements.

Comments: Three respondents provided a range of comments on this topic. One person felt that there is a large group of seniors whose main need is to feel safe, and having a person on site at all times provides this feeling of security. This on-site person was seen as more important than meals or recreation programming, which were seen to be more appropriate for the higher support levels found in care facilities than in congregate housing. Two others felt that an emergency call system was adequate; having a person on site around the clock was very expensive, beyond what most providers of affordable projects can afford, and is not needed.

Response: The guideline requiring an emergency call system that is monitored 24 hours a day by on-site staff provides for some assistance in case of an emergency, given the advanced age of most of the residents in congregate housing. Staff envision that this monitoring function be undertaken by non-professional staff residing on site. Projects that currently provide this service tend to have resident managers who respond to emergency calls. Staff recommend proceeding with the guidelines as written, noting that the need for on-site staff for monitoring can be reassessed as experience with this use increases.

v) Parking Standards

Background: The proposed parking standards are based on net unit size. Congregate housing projects with small units and residents over age 65 could provide one space per four units; the larger units proposed in some recent applications would be required to provide more parking. Studies done in Vancouver have shown a strong correlation between unit size and vehicle ownership, and hence support a parking standard based on unit size. It should be noted that this standard determines the total number of parking spaces to be provided to meet the parking needs of the project's residents, visitors, volunteers and staff. Ensuring the provision of adequate parking will ease neighbourhood concerns about impacts.

Comments: Most respondents felt that the proposed parking standards were too high, as many seniors do not drive. Providing underground parking is very expensive, and significant savings could be achieved if the standards were lower, assisting in the development of affordable projects. One respondent noted that trading parking spaces for a greater amount of usable common space should be considered. Basing a parking standard on unit size did not seem valid to some respondents.

Response: Staff recommend proceeding with the parking by-law amendment plus
relaxations as described in the guidelines (Appendices B and C). Relaxations are already available for projects for low income or older seniors. As experience with this use increases, the suitability of the parking standards will become known.

As part of a study on disability parking standards, Council will be considering a revised standard for congregate housing, which would increase the number of parking spaces dedicated for the use of persons with a physical disability from the currently proposed one space per twenty to one space per fifteen. Should Council approve this direction, these guidelines will be revised accordingly.

F) Issues Requiring Monitoring

A number of issues identified in the June 2000 report were identified for monitoring. The following sections of the report are organized in the same manner as the section above.

i) Conversion of Rental to Congregate Housing

Background: The June 2000 report to Council noted concerns about the possible loss of rental capacity, particularly affordable rental, due to conversion of units to market congregate housing, some of which might be strata-titled.

Comments: A few respondents supported allowing conversion of seniors rental housing to seniors congregate housing, and viewing it as enhanced rental. They noted that these conversions may be necessary due to the increasing seniors population, and their desire for a range of housing options, especially options which are affordable.

Response: Staff note that congregate housing is not just enhanced rental housing; it is a different product serving a different need. The loss of rental housing remains a loss, even if it is converted to congregate housing, as both types of housing are needed. Staff will continue to monitor the interest in conversions, and impact on existing rental housing stock, and will seek replacement rental housing where possible.

ii) Congregate Housing in Single Family Zones

Background: While most current congregate housing projects are large (100 or more units), smaller projects in single family areas may become attractive as the market evolves. Staff concerns regarding the development of congregate housing projects in single family areas, within the parameters of the existing zoning, are focussed on two themes: how well the congregate housing projects fits into the neighbourhood, and how suitable the location is for seniors. The guidelines deal with latter, suitability of the location. To deal with theneighbourhood compatibility concerns, the June 2000 report proposed prohibiting lot consolidation in single family areas for the purpose of developing congregate housing, while still allowing it to be developed on existing large lots, and on lots consolidated as part of a rezoning.

Comments: Many comments were received on this direction. While all those responding agreed that congregate housing should be compatible with the character and streetscape of single family areas, they were generally opposed to the blanket prohibition approach recommended. Rather they suggested that in some cases, small or medium sized projects could be designed to fit into single family neighbourhoods, and therefore, each project should be evaluated on its own merit. Further, most respondents confirmed the importance of enabling seniors to remain in their neighbourhoods, with familiar surroundings, relationships and services, as long as proximity to transit, shops and services can be achieved. They noted that large portions of Vancouver have primarily single family dwellings, and high concentrations of seniors; in order for these seniors to age in their communities, opportunities for congregate housing should not be too restrictive.

Response: Staff agree with evaluating each individual project, and note that this is in keeping with the current zoning designation, which allows this use, conditionally, in most areas of the City. In addition, staff will continue to monitor the location of congregate housing projects.

iii) Strata-Titling of Congregate Housing Units

Background: The past report to Council noted concerns about the impacts of strata-titling and multiple ownership on the ongoing operation of congregate housing projects due to the lack of clarity regarding financial and legal relationships, and impacts related to real estate transactions. Further, the Province is working on consumer protection legislation related to supportive housing.

Comments: A few respondents provided a variety of comments regarding strata-titling. Most agreed with the concerns expressed above. In addition, one respondent added a concern about the additional cost of monthly payments which can be difficult for seniors on fixed incomes. Also mentioned was that living "under" a strata Council could curtail freedom. On the other hand, one respondent felt that strata-titled congregate housing units should be an option available to those seniors who do not wish to rent, noting that being able to own a unit is important to some people.

Response: Staff will continue to monitor tenure arrangements as projects are developed and occupied.

CONCLUSION

The comments received through the public consultation process have helped to refine the guidelines as well as confirm previous directions, and concerns. While the balance between affordability and livability formed the bulk of comments, many remarks focussed on the importance of choice to seniors, and the need to provide environments that foster independence. Staff will continue to monitor this use as it evolves to serve an increasing, diverse, aging population. Staff recommend that the application to amend the Zoning and Development By-law be referred to Public Hearing and that the application be approved.

* * * * *


APPENDIX A
Page 1 of 1

PROPOSED ZONING AND DEVELOPMENT BY-LAW AMENDMENTS

ZONING

SECTION 2 (DEFINITIONS)

2.0 Amend existing Special Needs Residential Facility (SNRF) - Congregate Housing definition, as follows;

SECTION 10 (GENERAL REGULATIONS)

Add Section 10.32, as follows:

10.32 Congregate Housing for Seniors.

10.32.1 All residential units shall contain a three piece bathroom.

10.32.2 All congregate housing projects shall provide meal service and 24 hour on site emergency response assistance.

10.32.3 For the purposes of calculating FSR, common areas such as the communal dining room, and common areas on the main and residential floors are not excludable. Only common space provided in excess of what is required in the guidelines can be considered as an exclusion within the maximum 10 percent amenity exclusion.

GUIDELINES FOR CONGREGATE HOUSING FOR SENIORS


TABLE OF CONTENTS

1. Application and Intent

2. General Design Considerations

3. Internal Design and Facilities

4. Bulk Storage

5. Circulation

6. Safety Features

7. Open Space

8. Parking and Loading

1. APPLICATION AND INTENT

Congregate housing for seniors is housing in which there are individual residential units (which could be sleeping, housekeeping or dwelling units) and large common areas, including a large communal dining room and common areas for activities and socializing. It is designed to meet the needs of an elderly population, and to accommodate aging in place. It features a package of non-medical services, typically including meals, house-keeping, laundry and activities. It does not include medical care. The City recognizes that congregate housing is an important component of the continuum of housing choice for seniors, one which allows seniors to maintain and maximize their independence.

These guidelines are intended only for congregate housing for seniors projects. Where projects fall under the Community Care Facilities Licensing Act, these guidelines will not apply.

These guidelines are to be used in conjunction with a district schedule of the Zoning and Development By-law, and official development plan by-laws for development permit applications for congregate housing for seniors. They are intended to provide direction primarily related to the livability and usability of congregate housing for seniors. The guidelines address the issues of project location and siting, unit design and features, common space design, and safety features, to allow for aging in place. In zoning districts where design guidelines exist, these too should be consulted.

The guidelines are to assist applicants in their planning and design, and City staff in their evaluation. All applications should be accompanied by an operating plan, which should include, but may not be limited to information on details such as the following:

While there is room for variety and creativity in the design of the components of congregate housing for seniors, the total package should:

The City, at its discretion, may consider exemptions in the application of guidelines when a Housing Agreement is entered into between the owner and the City where at least a portion of the units are restricted to occupancy by residents of low and modest incomes. Further, where at least a portion of the units are restricted to occupancy by residents 65 years of age or older, a parking relaxation may be considered.

2. GENERAL DESIGN CONSIDERATIONS

3. INTERNAL DESIGN AND FACILITIES

4. BULK STORAGE AREAS

5. CIRCULATION

6. SAFETY FEATURES

7. OPEN SPACE

8. PARKING AND LOADING

PROPOSED PARKING BY-LAW AMENDMENTS

SECTION 4 - Off-Street Parking

Size of Residential Unit (Net)

Less than 50 m²

1 space per 100 m²

50 m² - 70 m²

1 space per 70m²

Over 70m²

1 space per 70m² except that no more than
2.2 spaces for every unit need be provided

SECTION 5 - Loading

One standard loading space, and one additional standard loading space for every 200 residential units.

SECTION 6 - Bicycle Parking

Class A: Size of Residential Unit

Less than 50m²

A minimum of 0.10 space for every residential unit

50 m² and greater

A minimum of 0.25 spaces for every residential unit

Class B: No requirement.

SECTION 7 - Passenger Loading

Class A: A minimum of one space for any facility with 80 or more residential units up to a maximum of 159 units, a minimum of two spaces for any facility with 160 or more units up to a maximum of 199 units, and one additional space for any portion of each additional 80 units.

Class B: A minimum of one space for any facility with 15 or more residential units up to a maximum of 119 units, and a minimum of two spaces for any facility with 120 or more beds.

MAILING LIST/COMMENTS RECEIVED

The following individuals, organizations and companies received a copy of the June 2000 report to Council and draft guidelines, and were invited to comment, in written form, by telephone, or by attending an Open House. Those who commented are noted by an asterisk *.

· Arbutus Manor *
· Crofton Manor
· Southview Terrace
· Chalmers Lodge
· Abbeyfield Houses of Vancouver Society
· Chinese Mennonite Church
· Columbus Charities *
· Concert Properties Ltd.
· Hearthstone Retirement Services
· Louis Brier Home and Hospital
· Architectural Institute of B.C.
· Urban Development Institute *
· Greater Vancouver Home Builders Association
· Senior Living Group
· Hywel Jones Architects
· Isaac-Renton Architects
· Neale, Staniskis, Doll Architects *
· Studio One Architecture
· Jan Timmer, Architect
· Saar Architecture
· KG Terriss Architects
· Rick Balfour *
· Duncan Elliott Appraisals
· Nora Stevenson
· Harry Kitzmann, Health Care Facility Consultant
· James Watzke & Christine Flegal, consultants on gerontology *
· Seniors' Housing Information Program *
· West End Seniors Network
· South Granville Seniors Friendship Centre
· Strathcona Adult Day Care Centre
· 411 Seniors Society
· Seniors Summit - Housing Working Group *

· National Academy of Older Canadians Society
· Vancouver/Richmond Health Board *
· V/RHB Community Audiology Centre *
· Seniors Population Health Advisory Committee, Raven Song Community Health Centre *
· B.C. Housing
· Ministry of Health and Ministry Responsible for Seniors *
· Regional Director, Seniors' Health, Capital Health Region *
· Housing Policy Branch, Ministry of Social Development and Economic Security
· Gerontology Research Centre, SFU at Harbour Centre *
· Lower Mainland Network for Affordable Housing *
· Tenants' Rights Action Coalition *
· Special Advisory Committee on Seniors *
· Irma Matheson, Community Health Committee #6 *
· Margaret McPhee, Sunrise Community Population Health Advisory Committee *

SUMMARY OF COMMENTS RECEIVED
(On June 28, 2000, Congregate Housing Report and Guidelines)

1) Affordability

Suggested ways to deal with affordability issues include FSR exclusions, government involvement, changes to unit sizes, common space requirements, parking standards, and staffing. These are outlined in the following pages.

2) FSR Exclusions

3) Increased government leadership and involvement

4) Definition of Congregate Housing

5) Conversion of Rental to Congregate Housing

6) Aging in place vs. aging in the community

7) Congregate housing should not be disallowed in single family areas

8) Strata-title ownership of congregate housing units

9) Emergency Response Staffing

10) Residential Units

11) Common space - General

Lounges on Residential Floors -

Main Floor Lounge Space -

Dining Areas -

12) Parking requirements

13) In-suite storage / exclusion

14) Bicycle storage

15) Scooters and Wheelchairs

16) Laundry

17) Miscellaneous

* * * * *