Dear Mayor Robertson and Councillors,
Re: RT5 / RT6 Zones - Proposed amendments to the Zoning and Development By-law for
Mount Pleasant and Grandview-Woodland Communities
The Grandview Woodland Area Council (GWAC) has many concerns about the proposed changes to zoning that will cover about half of our neighbourhood. Many changes are not consistent with the city's stated goals of character retention, and the public process has not adequately involved the community in many of the important details. This current proposal is not ready for enactment so we oppose it in its current form.
In previous rezoning processes, such as when Kitsilano was rezoned from RT4/RT5 to RT7/RT8, the city had a community advisory committee made up of local residents that worked with the planners on all aspects of the their new zoning.
GWAC requested a similar process when we met with the Manager of Planning and staff earlier in the year. Unfortunately there instead were only a few open houses that did not adequately allow for the needed community input to address our concerns or to explore options.
Grandview is a heritage area that is generally intact with the original buildings still existing. Most of these character houses have been converted to multiple rental units, some legal and some not. These units are important sources of affordable rentals, especially when we are in a housing crisis.
Retention of existing rentals is dependent on the fate of our character houses. Growing through incremental increases of units of conversions and infill as incentives for character house retention is the sustainable way to create more affordable housing options while not losing what we have and without inflating land values. The current proposal allows too many options for new development that undermines this, including lot assembly.
The new RT5 zone should be given the same neighbourhood character consideration for contextual design and guidelines as the RT6 in west Mt. Pleasant. We strongly disagree with the proposal to delete these guidelines for RT5.
We agree with the city's stated intention to allow densification through incentives to retain character houses. However we do not think this proposal is ready for approval yet and request an extended timeframe to meet with staff and to have the zoning proposal further amended to address the many outstanding issues with this proposed RT5 zoning. A 31% loss of character pre-1940 houses for RT5 is way too much.
Please see the attachment below for more details of some of the many outstanding issues.
Dana Cromie , Chair, Grandview Woodland Area Council
Attachment to letter from Grandview Woodland Area Council (GWAC) dated September 6, 2017
GWAC concerns about the proposed RT5 zoning changes
1. Character criteria and "underutilized" sites:
Based on the city's figures, 31% of pre-1940 houses could be demolished. This is way too much.
Grandview was generally built out prior to 1940 and most of the original houses still exist. The character criteria proposed is too onerous if the city expects that only 80% will likely qualify as character houses. Further, by increasing the definition of "underutilized" sites from 0.30 FSR to 0.45 FSR, the city expects another 14% of those considered character will not qualify based on size. So that means only 69% of the existing pre-1940 houses will qualify for character house retention incentives and that 31% will potentially be demolished. That would be a tremendous loss to the character of our neighbourhood and to affordable rental suites.
Most of these pre-1940s houses could be restored and upgraded with multiple units as a sustainable means to accommodating growth. Even small houses are ideal for bigger infill options or additions and should be retained.
- The character house criteria should be revised to ensure most pre-1940 houses qualify as character houses to be retained with incentives.
- The definition of underutilized lots should be left at the current 0.30 FSR, especially for lots with 50 ft. frontage and greater. And "underutilized" site designations should not apply at all to heritage listed properties on the register. They can always be densified through retention infill options.
We are concerned that there are more development options proposed for demolition and new construction than for character house retention incentives. This may have the unintended consequence of loss of older more affordable rentals in character houses, while increasing inflationary speculation.
It is proposed that a new duplex can have two secondary suites, a total of four units. While a character house can only have three units in a multifamily conversion dwelling (MCD) that requires full code upgrades of the original house. There is not even a retention option to have two secondary rental suites, with a main floor unit, that the Secondary Suite Program could make more affordable and feasible to do through code relaxations.
- Allowing four units for new construction on a small lot is too much. Use dwelling unit density at 74 units per ha. for MCDs and infill for character retention and 64 units per ha. for new construction as per typical RT zones such as current RT6 and RT8.
- Character houses should be allowed to have more suites under the Secondary Suite Program.
- If a character merit house is demolished for a new house, they should not be able to build a laneway house too.
- A new house can also have another small house on the same lot which undermines the retention incentives for infill, so this should not be allowed for new construction.
3. Site assembly for multifamily development:
Site assembly for new multifamily development will lead to speculative inflation and should be avoided.
In other character retention zones like RT8, no site assembly is allowed. However, this proposal allows up to two lots assembled for 50 ft. to 100 ft. frontage sites for multifamily. And the amount of new development is increased from 62 units per hectare to 74 units per hectare. Previously the 74 units per hectare was reserved only for character retention options and this should be reversed as per section on economics above.
Grandview already has many areas zoned for new apartment and townhouse development. The RT5 zone should be used primarily for character house retention conversions and infill, not new large site assemblies for multifamily development and demolition that lead to speculative land inflation.
- No assembly should be allowed in RT5. Under 4.2 Frontage, the maximum and minimum lot frontage should be the single lot frontage existing at the time of enactment of this zoning change.
4. Design guidelines:
Grandview is a heritage area since most of the original housing stock still exists. Exterior house and streetscape design are very important and need design guidelines to ensure contextually sympathetic implementation. We agree with the design guidelines being retained in RT6 west Mt. Pleasant, but disagree with guidelines being dropped for the new RT5 in east Mt. Pleasant and Grandview. The existing design guidelines have served us generally well and should be retained for now. A review for improvements, or for adding options for modernist design where appropriate, should involve detailed community input in a much more fulsome future process.
- Keep existing design guidelines for both RT6 and RT5.
5. Front yards:
Front yard setbacks should remain flexible and contextual as per current regulations and guidelines rather than changing to a rigid setback. Director of Planning has discretion to vary setbacks when required. Proposed changes specifies the front yard setback regardless of context.
- Retain current setbacks that are 20% of lot depth or the average of the two adjacent properties, with further guidance on how this should be applied in design guidelines. Specific cases can be varied.
6. Parking relaxations:
Parking relaxations should be made for character retention initiatives, but not for new construction. There is only so much street parking and relaxation priority should only be given to character retention as an incentive.
7. New RT5 zoning boundaries:
We are concerned about the locations of some of the new RT5 zoning boundaries. We would like to go over a detailed review with staff to clarify the rationale that was not part of the consultation process to date.
8. Building code relaxations and streamlined permits for character house retention:
Currently, the city makes it very difficult to renovate character houses. Incentives should include more building code relaxations and streamlined dedicated permit approvals for character house renovation and infill.