CVN letter to Council (Mar 3 Public Hearing): Reject ‘Rezoning by stealth,’ send back to staff (Miscellaneous Amendments – Zoning and Development By-law …)

March 3, 2022
City of Vancouver Council

Dear Mayor Kennedy Stewart and Councillors,
Re: Public Hearing 3-Mar-2022 Agenda 3: Miscellaneous Amendments – Zoning and Development By-law and East Fraser Lands Official Development Plan

The Coalition of Vancouver Neighbourhoods (CVN) requests that some of the items included in this report, items A.(v)(vi) (ix), be referred back to staff for more work since they do not meet the test for miscellaneous amendments to be for “minor non-substantive changes”.

Any changes to zoning that change the unit numbers, form of development, or density (FSR), are substantive in nature. Numerous items in this report are lumped in with unrelated items and it is unclear where in the city they apply without related maps. The proposed changes affect Grandview and Mt. Pleasant in particular, among other areas as well, without consultation.

The public hearing documentation should include redline versions showing the proposed changes to the zoning bylaws and guidelines. Staff have only provided redlines for the Guidelines.  Staff should also be required to provide maps and links to the zoning bylaw schedules that are affected, as well as detailed analysis to explain implications and what these changes mean in practical terms. 

The following excerpts are just some of clauses of particular concern in the RECOMMENDATION section of the Referral Report:

v. correct an omission in section 4.7.7 in the RM-11 and RM-11N Districts Schedule by including reference to two additional sections for which more density for multiple dwellings can be achieved through the purchase of amenity or affordable housing shares;

 vi. correct an omission in sections 4.1.1. and 4.1.3 in the RM-3A District Schedule and section 4.1.1 in the RM-4 and RM-4N Districts Schedule to include seniors supportive or assisted housing as a use for which minimum site area requirements can be reduced;

ix. correct the minimum site area allowance for multiple dwellings to align with unit density in sections 4.1.2 and 4.1.3 in the RT-5 and RT-5N Districts Schedule and the RT-6 District Schedule

For example, the proposed changes in (ix) above for RT-5 & RT-6 zones would allow multiple dwellings on much smaller lots (those less than 30 ft wide), but the referral report does not explain the implications. Minimum lot sizes are set on purpose. The proposed changes cannot be presented simply as an issue to “correct”.

In (ix) the references to numbers of units regarding  “multiple dwelling” do not seem to be counting secondary suites as units. In fact, under Vancouver’s existing by-laws for RT5 duplex zoning, it already allows a secondary suite for each duplex unit, for a total of 4 units on each lot. Thus, multiple dwellings of 3 units could actually mean a total of 6 units on a lot when secondary suites are also counted.

The proposed changes would likely change the economics in favour of demolition, rather than character house retention, the latter being a key objective of current City policies in RT5 and RT6 zones.

These are just some of the implications of the staff’s proposed “minor” “miscellaneous amendments”.

Council needs to know that staff are proposing substantive changes. This would constitute rezoning by stealth.

Please refer these items back to staff with instructions to prepare the required documentation, for proper community consultation, and a report back to Council prior to bringing this forward to a public hearing.

Thank you,

Steering Committee,
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
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
Residents Association Mount Pleasant
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