September 12, 2023
City of Vancouver
Dear Mayor Ken Sim and Councillors,
Re: RS Rezoning and Multiplexes Public Hearing
Public Hearing Agenda – Sept.14 at 1:00 pm: https://council.vancouver.ca/20230914/phea20230914ag.htm
The Coalition of Vancouver Neighbourhoods (CVN) supports increasing missing middle housing, in principle, in every neighbourhood. However, CVN has major concerns about the current proposal, both in substance and process. We therefore cannot support this proposed rezoning without major modifications and meaningful public involvement and urge you to oppose it as presented. At the very least this should be a more limited trial and properties listed on the Vancouver Heritage Register should be exempt.
Change of approach needed: Last fall’s civic election sent a clear message that the public wants a change in direction from how things were done by the previous Council. However, this proposal for multiplexes in RS zones citywide is basically the same as the motion brought forward by former mayor Kennedy Stewart last year, for multiplexes up to 6 units on a lot, which he had used as a central part of his re-election campaign. The public vote was a rejection of this approach. Not for it. While changes to RS zones could be made to simplify zoning and include multiplexes, the City should not be following Kennedy Stewart’s plan.
Lack of public consultation or notice: Staff have been consulting with the development industry on this topic for over a year and a half, but only consulting with the public in a limited number of open houses and a flawed survey conducted for just a month, before finalizing the options. The public has not received enough detail, information, or opportunities for meaningful input into the proposals. The public survey was flawed and cannot be reliably viewed by Council as public feedback. Many people refused to fill it out as it was so biased. The tens of thousands of affected properties have not been notified of the public hearing by postcard or other effective means. Very little advertizing the first week of September means most people who might be concerned or impacted are unaware of or unable to attend the afternoon Public Hearing.
Attached is an Appendix with just some of the many comments, concerns and questions that have been raised by our network that have yet to be addressed.
Steering Committee, Coalition of Vancouver Neighbourhoods
Network 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
Grandview Woodland Area Council
Greater Yaletown Community Association
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
West Southland Residents Association
APPENDIX – RS Rezoning and Multiplex Public Hearing (September 11, 2023)
Below are just some of the many unaddressed comments, concerns and questions we have about the proposals:
Lack of planning and resources for amenities and infrastructure for growth: Of particular concern is the lack of neighbourhood-based planning for adequate amenities and infrastructure for approved growth. The accumulative affects of multiplexes will be substantial, so therefore it is critical that planning includes the resources for schools, health care, daycare, community facilities, amenities and infrastructure in every neighbourhood. As we know CACs and DCLs do not begin to cover these costs for growth and there is no reason to believe that new additional proposed CACs will be any different. Many neighbourhoods are already underserved for amenities and infrastructure.
Basic electrical and sewer infrastructure insufficient: Requiring every RS lot to have its own electrical transformer (PMT) with a 12 ft x 12 ft easement at the lane and a huge underground water holding tank to prevent overflowing the sewer system illustrates how the current proposal is beyond the capacity of city infrastructure. These costs of approximately $100,000 for a transformer PMT and $25,000 for a water tank are prohibitive, as well as taking up valuable land area that makes this unfeasible.
Loss of existing affordable rental suites: The RS zones currently have a very large number of rental suites, as well as whole houses that are rented, that would be lost through this initiative.
Why rezone 60,000 RS lots for up to 6 units each when the target is only 10,000 more units?: Rather than completely overloading the city’s infrastructure, the city should take a more targeted approach. Look at how each neighbourhood can take their fair share of the 10,000 unit target and ensure that it is done in parallel with the required infrastructure. Note that the 10,000 unit target is for all missing middle units, not just multiplexes, including duplexes, suites, infill and character house retention incentive projects.
A more selective approach could produce more units while putting less pressure on services and land values: At an average of only one added unit per lot that could produce 60,000 units. For example, by making multiplexes a bit more moderate, it could actually be easier to build while not undermining the other opportunities such as for more suites, character house retention incentives, or overloading services.
For example, allowing multiplexes at up to 0.85 FSR for 3 units on standard 33’x120′ lots, 4 units on 50’x120′ lots and 6 units on corners with 60′ or more width would provide for bigger family units, more yard, trees and permeability, and a better fit for services.
Properties listed on the Vancouver Heritage Register should be exempted: To be consistent with Heritage retention policies, increasing development pressure from multiplexes should be avoided. Instead, properties listed on the Heritage register can increase development through retention incentives in a Heritage Retention Agreement (HRA).
Undermining character retention incentives – 0.85 FSR vs 1.0 FSR: The current character house retention incentives of 0.85 FSR would be undermined by allowing 1.0 FSR for multiplexes. This will lead to more demolition and lost rental affordability. The retention incentives need to be more than new construction or they will not work. This is unbalanced as proposed.
Existing character house retention incentives should remain at 0.75 FSR rather than reducing to 0.65 FSR as proposed: The proposed reduced sizes of new houses to 0.6 FSR with increased laneway house is reasonable. While avoiding very big new houses is a good idea, the existing incentives for character house retention of 0.75 FSR should not be lowered to 0.65 FSR which is inadequate.
Undermining climate policy objectives for more trees and less embodied carbon: To meet climate objectives, the need for growth should be balanced with climate objectives to increase the tree canopy. Current proposals of 1.0 FSR will leave little yard space for retaining existing trees or planting new. The higher the new FSR and larger site coverage, the more embodied carbon is produced to build a bigger building and more demolition.
Minimum unit sizes and bedroom sizes should be specified: Multiplexes in other areas have shown that some bedrooms are only 7’x8′ and some units too small for families so minimum sizes are required.
Lack of data for planning: City Council and the public continue to lack the much-needed data to determine how many units are actually required for anticipated growth in our communities. Also needed is data on how many units have already been planned or approved broken down by neighbourhood and how much impact that will have on services. This data should also inform how multiplexes are implemented.
Reduced front yard setbacks: Almost no front yards or permeable surfaces are proposed with little green space provided. Loss of trees, even large street trees where front yard setbacks are so narrow that it isn’t enough room for root systems. Instead, front yards should be retained to provide for outside space for the ground floor or front unit, to avoid putting all the outdoor space in the rear yard with little privacy between units. Front yards should continue to be a factor of the depth of the lot, as well as consideration of adjacent properties and streetscapes. Where front yards are reduced, consider stepping back the second floor to avoid cutting off all light to adjacent properties. It is unclear in the presentation materials what the proposed front yard setback would be.
Combining RS Zones: While there may be some rationale for simplifying and combining some RS zones, some zones such as RS3 and RS3A were specifically designed for the existing lot sizes, configurations and building forms of the area. These should be treated differently and retained. There should be some consideration of local area conditions and influences.
Design Guidelines should be retained and improved: The Design Guidelines help to clarify the intent of the zoning and provide important guidance to designers, builders and staff. Having this level of clarity actually helps to speed up approvals rather than leaving it open to misinterpretation that requires many revisions. To remove Design Guidelines is not practical and makes the zoning less transparent.
No required onsite parking or EV charging: No required onsite parking for up to 6 units, will overload street parking and not have electric car charging that is a disincentive to convert to an EV.
Require all new single family houses to have a secondary suite: There is no reason to be building new houses without at least one secondary suite to help offset the many suites that will be lost through demolition.
Allow 2 secondary suites through the Secondary Suite Program: Traditionally, it is common to find houses made up of 3 suites, ground level, main floor and top floor suites. Usually at least one of these suites are unauthorized. Rather than shutting down good suites, they could be legalized and made safe through the Secondary Suite Program. Code staff are reluctant to do so, but now even the province is incentivizing more secondary suites so this should be reconsidered through direction by Council.
Landscape irrigation should be required to ensure trees and shrubs survive: There is very little landscaping so to ensure it survives it is essential that there is irrigation, especially with multiple strata owners.