May 16, 2021

City of Vancouver Council

Dear Mayor Kennedy Stewart and Councillors,

Re: Motion-Increases up to 12 storeys Social Housing in the RM-3A, RM-4 and other Zoning Districts City-wide

Agenda: https://council.vancouver.ca/20210518/regu20210518ag.htm
Report: https://council.vancouver.ca/20210518/documents/b2.pdf

The Coalition of Vancouver Neighbourhoods (CVN) is opposed to this motion for many reasons.

A summary of the main reasons for opposing this motion are:

* The scale of the proposed buildings are too big at 400% of the outright height and FSR with major negative impacts on existing rentals, land inflation, demoviction and displacement;

* Staff need to provide the data as directed by Council motion in May 2020 to inform the planning for how much social housing is actually needed;

* The city’s definition of “social housing” currently allows 70% of the units at market rent but counts it as 100% social housing when it is mostly market rents. This needs reconsideration and clarification in the near future, as previously considered at Council (see Councillor Fry’s earlier Motion)

* It is undemocratic to allow major increases in height and density without public hearing and undermines community plans.

Social housing with appropriate locations, supports and amenities could be provided in every neighbourhood if the scale, form and context of each neighbourhood were properly considered. This motion doesn’t do this as the proposed scale and form would have major negative consequences for the affected communities without requiring project rezoning public hearings.

Some of the many concerns are as follows:

* The huge increase in scale of up to 400% of that allowed by current outright zoning would increase land lift for the subject property and all of the area around the site. RM-3A and RM4 would go from 3-4 storeys at 1.45 FSR to 12-13 storeys (including exempted top floor amenities) with 6 FSR.

* Staff suggested that with the six storey height limit, the new social housing was only feasible if the land were acquired at no cost, ie already a social housing site. So the new social housing would be at the expense of existing social housing but the number of sites was limited in number. With the increase to 12 storeys, it may well be that redevelopment would be possible with land purchase. This would put many more existing affordable rental units at risk of demolition.

* Going from wood frame construction to concrete would increase costs, rents, embodied GHG emissions and demolition waste in the landfill.

* Regardless of tenure, the physical scale and form would be used as a precedent for future spot rezonings, including market rentals and strata.

* This will increase development pressure, increase rental inflation, gentrification, demovictions, and displacements for existing older more affordable rental buildings. Existing rents in older buildings tend to be much lower than new rentals, sometimes even lower than typical subsidized social housing rents, while existing older units are also generally larger. Most of the city’s existing affordable rental apartment buildings are in RM zones.

* The City defines social housing projects as only requiring 30% of the units subsidized below HILs rates and the other 70% of the units could be market rentals, while 100% of the units are counted as social housing. This motion fails to clarify this important point. While it is true that further subsidies may be granted from other levels of government, there is no guarantee or requirement for this as part of the approval process and is subject to qualification and availability of future programs.

* This motion doesn’t even require a greater level of affordability. All increases in height and density should meet the affordability requirements from BC Housing (20%deep subsidy, 50% moderate subsidy, 30% some subsidy ) rather than the Vancouver Zoning and Development By-law.

* Large increases to height and density in RS, RT, and C zones citywide would have the same effects of inflating land values, increased rents and displacement as described above. Possibly even more so.

* Secondary suites are an important part of the existing affordable rental stock. Large increases in building scales for new social housing, of which 70% of the units could be market rents, will lead to displacement, gentrification and demolition of character buildings.

* Large increases to height, FSR and form without a rezoning public hearing is undemocratic and undermines security that zoning is intended to provide.

* It also undermines neighbourhood character and liveability by allowing much bigger buildings that block views, overshadow yards and buildings for gardens and potential solar panels.

* This motion undermines neighbourhood based planning and pre-empts the outcomes of the Vancouver Plan and the Broadway Plan. Any allowance for buildings of this size, with its effects on a neighbourhood, should be considered through a neighbourhood-based public consultation process. Given that the Vancouver Plan is already looking at planning options, including for social housing, it would seem that this motion is out of order.

* This motion is in conflict with existing Community Plans, including the most recent in Grandview Woodland.

Please do not approve this proposed motion.

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