CVN letter to Council (for June 8): OPPOSED to A, B, C on Internal Development Application and Permitting Modernization Task, comments on D

June 6, 2021
City of Vancouver Council
Dear Mayor Kennedy Stewart and Councillors,

Re: Internal Development Application and Permitting Modernization Task Force – First Bi-Monthly Update – Revising Design Guidelines, Tree Protection Bylaw, Zero Emission Buildings Delay


The Coalition of Vancouver Neighbourhoods (CVN) is concerned about so many different unrelated issues being combined under one report as an omnibus.  This makes it much harder to address each issue and the title of the report does not clearly reflect the content.

Reduced Approval Times Generally – The goal to reduce development and permitting approval times is essential. However, this should be done by making the process more efficient as a priority, not by reducing the City’s oversight for quality of design and finished product.

Recommendation A – To not enforce design guidelines in RS-3 and RS-3A, RS-5, RT-3, RT-6, RT-7, RT-8, RT-9 and RT-10 Zoning Districts. Strongly Opposed

* The conditional aspects of the zoning are central to their intent and should not be weakened for expediency.  Staff should streamline the approval process to reduce time without reducing the quality of design that is focused on character and heritage house retention and neighbourhood character. Quality of exterior finishes and windows, including placement for privacy, are an important part of this.

* The proposal would eliminate all landscape review in these zones so that would mean that there would be no requirement for new developments to plant trees or to place planting for privacy screening. This will seriously affect our urban forest over the long term. In one year there can be a lot of damage done. Irrigation systems should be mandatory so that landscaping survives.

* The intent of this pilot appears to be to make these changes permanent. If any temporary changes are approved, they should automatically reverse back after the 12 months.

Recommendation B & C – To amend the Tree Protection Bylaw requirements by redefining the size of trees that would be protected from over 20 cm (8 inches) diameter to over 30 cm (12 inches) while eliminating arborist reports. This would result in a reduction of the number of saved trees. This is proposed as a permanent change to the Bylaw.

* Better to ensure timely review process rather than eliminate review requirements.

* How will the city verify the actual size of trees removed without confirmation by an arborist?

* Will there still be replacement trees required when there is no third party to confirm existing?

* Much of the urban forest is on private property and many trees are at the rear of properties. Allowing trees removed for garages would mean a loss of many of the city’s biggest trees.

* Trees are a major way to mitigate climate change and also reduce run-off into our sewer system.

* Where some flexibility is required for problem trees, there needs to be checks and balances to ensure that the urban forest is retained intact.

Recommendation D – To delay by 12 months the implementation of amendments to the Building By-law, as set out in sections 19 through 42 of By-law No. 12692, relating to mandatory zero emission building construction guidelines for all new homes. While the delay for new homes is questionable given the large amount of new development in the pipeline, there does need to be a delay in how this would affect renovations to existing character and heritage buildings.

On April 29, 2020 Council directed staff to work with stakeholders to update the Bulletin 2014-007 “Conservation of Heritage Buildings and Compliance with Vancouver’s Building By-Law”, to ensure that there is flexibility in the requirements, for modest renovations and additions for heritage and character homes that achieve retention goals, enabling approaches that are compatible with a historic building. Developments and Permits staff have not been available to work on this and need more time.

Staff report:

So if this Recommendation D is not passed, there needs to be a delay in the application of zero emission building construction guidelines to heritage and character buildings in the Bulletin 2014-007 until staff can provide more detailed work on the Bulletin for zero emissions as directed by council on April 29, 2020. 

Please do not approve Recommendations A, B and C. Please also consider our comments on D above.

In future, please do not combine unrelated items into one report.

Thank you,

Larry A. Benge, Co-chair
Dorothy Barkley, Co-chair
Coalition of Vancouver Neighbourhoods

Member Groups of the Coalition of Vancouver Neighbourhoods

Arbutus Ridge Community Association
Arbutus Ridge/ Kerrisdale/ Shaughnessy Visions
Cedar Cottage Area Neighbours
Downtown Eastside Neighbourhood Council
Dunbar Residents Association
Fairview/South Granville Action Committee
False Creek Residents Association
Grandview Woodland Area Council
Granville-Burrard Residents & Business Assoc.
Greater Yaletown Community Association
Joyce Area Residents
Kitsilano-Arbutus Residents Association
Kits Point Residents Association
Marpole Residents Coalition
NW Point Grey Home Owners Association
Oakridge Langara Area Residents
Riley Park/South Cambie Visions
Shaughnessy Heights Property Owners Assoc.
Strathcona Residents Association
Upper Kitsilano Residents Association
West End Neighbours Society
West Kitsilano Residents Association
West Point Grey Residents Association