Detailed, unanswered questions on the West End Community Plan – L. Green, J. Herter

West End plan, panel 13, 4-April-2013, tower height zones proposedSeven pages of questions and comments went to City Council in November from L. Green and J. Herter, West End residents, regarding the West End Community Plan. As of today (Jan 22), they still await a response from City Hall. One Councillor acknowledged receipt (Adriane Carr), but no other member of Council  replied, nor did a single person from the Planning Department or West End Plan team. We share this with readers as an example of unanswered concerns expressed to the City about the Plan. We believe there are many other cases not reported.

Vancouver City Council adopted the West End Community Plan on November 20, 2013 (and a Public Hearing will be held on January 23, 2014 on zoning amendments based on the Plan). The final version of the 200-page package of documents was made public just a matter of days before the November 20 Council meeting.

Time was very short, and the documents filled with jargon, making it difficult for the average person to go through and confidently grasp what was being proposed. But some citizens did their best. West End residents John Herter and Leslie Green, a professional planner, spent many hours of their own time going carefully through the draft Plan, compiling comments and questions, and submitted a letter to City Council on November 12. As of today (Jan 17), no one from the City has even acknowledged receipt, and John and Leslie have not received any response to their comments and questions. Nor did City staff or Council members even make any mention of letters like this during the Council meeting on November 20. This is but one example, but West Enders are left to ask if City Hall has treated the community fairly in its rush to adopt the 30-year Community Plan.

A some of the points in their letter are listed below.

This Draft Plan will shape our neighbourhood for the next 30 years. Our overall lack of support for the Draft Plan is because:

  • there is insufficient time for community members to review, digest, consider, discuss and, in some cases, provide alternative recommendations to this important Draft Plan in the context of substantial changes that could result in our community;
  • the lack of time to consider what these changes might be, for better or for worse, and to articulate these to Council;
  • the large number of important community elements that are missing from the draft plan; and
  • the large number of statements in the draft plan that require clarification and greater detail.

Their letter goes on in considerable detail relating to

  1. Process
  2. Population growth estimates
  3. What is missing from the Draft Plan and associated guidelines
  4. Livability/quality of life
  5. Inconsistencies in Section 7.1 Villages
  6. Conceptual illustration of Davie and Bute Streets
  7. Section 7.2 Neighbourhoods
  8. Section 7.3.4 Lower Davie Corridor
  9. Section 8.1 Housing Supply and Affordability 
  10. Section 17.22 Cost Estimates and 10 Year Funding Strategy
  11. Requirement for clarifications and greater certainty

Final paragraph:  We would like Council to not approve the Draft West End Community Plan and provide the planners and community members with additional time to review the Draft Plan, provide alternatives and re-submit the Draft Plan to Council.

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Full text

Comments on the Draft West End Community Plan and Associated Documents
After almost one year participating in many of the City run West End Community Plan sessions, and after reading the Draft West End Community Plan (October 2013) and associated documents (the Draft Plan), this letter is to let Council know we do not support the Draft Plan, and to provide the reasons why we have come to this decision.

This Draft Plan will shape our neighbourhood for the next 30 years. Our overall lack of support for the Draft Plan is because:
• there is insufficient time for community members to review, digest, consider, discuss and, in some cases, provide alternative recommendations to this important Draft Plan in context of the substantial changes that could result in our community;
• the lack of time to consider what these changes might be, for better or worse, and to articulate these to Council;
• the large number of important community elements that are missing from the draft plan; and
• the large number of statements in the Draft Plan that require clarification and greater detail.

The Draft Plan was issued for review on October 22, 2013 and Council has asked for our comments by November 13, allowing only 22 calendar days to respond, or 17 working days. This Draft Plan should be considered a Preliminary Draft Plan for community review and discussion. Although we diligently attended the City run planning sessions, it is difficult to relate the detailed and complex information presented in the Draft Plan with the general statements and concepts provided on the storyboards. It is unreasonable for Council to expect community members to meet the unrealistic and arbitrary deadline.

The deadline hinders, rather than promotes, community involvement in the planning process. If Council is sincerely interested in well thought out and thorough comments on this Draft Plan, an extended review period and additional community sessions for community discussion would be provided. Prior to being resubmitted to Council, this Draft Plan should go through one more iteration in the hands of the planners, taking into consideration community feedback. This important step has been omitted in the planning process.

Cynicism about the process does not benefit the either the planning process or the planning product.

However, we have minimal confidence that Council will seriously consider our suggestion to not approve this Draft Plan and to allow additional time for the community to work with the planners. For this reason, we are providing some detailed but incomplete comments, questions and concerns on the Draft West End Community Plan, Rezoning Policy for the West End, and Draft West End RM Design Guidelines for Infill Housing for Council to consider. The reason Council can consider these comments as

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incomplete is because the process does not provide us with sufficient time to identify all our concerns, write them up and deliver them to you.

Comments on the Draft West End Community Plan and Associated Documents
1. Process: There are two important milestones in a planning process: developing the draft plan and reviewing the draft plan. The development of the draft plan took 19 months and the review time allotted is 22 calendar days or 17 working days. The West End planning process does not allow sufficient time for community members to review and discuss the Draft Plan, work with planners to make changes, and submit the community‐reviewed document to Council. Reasonable community members and reviewers of this Draft Plan will not expect universal agreement of everything in the Draft Plan; however it is Council’s duty to ensure that in depth and well considered discussions on the Draft Plan occurs within the community. The effects of the decisions that Council will make are
felt by the people living in the community, not by politicians, developers or planners.

2. Population Growth Estimates: The proposed increase in population over the next 30 years raises serious concerns with us. The Draft Plan does not provide discussion on how the projected population growth of 7,000 to 10,000 people over 30 years was established, nor was there any discussion in the planning sessions about how these numbers were arrived at. Indeed, during the West End community plan learning session we attended, a senior planning staff member indicated that it had been decided the West End must take its “fair share” of population. No further description was provided and it appeared no discussion on the matter was warranted. The community is simply asked to accept this number without consideration of alternatives. The Draft Plan and background documents should provide information on what alternatives were considered, why alternatives were rejected and how the increase in population of between 7,000 to 10,000 people was chosen. Information and analysis needs to be provided on a range of population
projections and what the resulting effects on the West End would look like. The range should include:
• a population increase in line with the existing zoning;
• a mid range population increase; and
• the higher proposed population projections provided in the Draft Plan.

The West End residents deserve to understand what our neighbourhood would look like under alternative scenarios, what it would mean to us and future generations, and have input into choosing our future direction. In addition, these population growth estimates are first presented on page 101 of the Draft Plan. The population growth estimates are an important driver of many of the directions and policies contained in the Draft Plan. It is absolutely essential to provide this information at the beginning of the Draft Plan to provide context for many of the plan directions and policies.

3. What is missing from the Draft Plan and associated guidelines:
• Underlying assumptions: The Draft Plan and its reviewers would benefit greatly from
understanding the underlying assumptions that were made when developing the Draft Plan.

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• Glossary: A glossary would help non‐bureaucrats understand what the Draft Plan means.
For example, the following jargon is used in the Draft Plan: FSR, deepen housing
affordability, grain of frontage, significant adverse effect, marginal development strip,
residential floor plate, sculpt built form, hardscaped setback, grain of frontage, finer grain
building frontage, semi‐public space.
• Answering the “Except When” Scenario: The reviewers of the Draft Plan deserve to know
what City policies, plans and guidelines would over‐ride the information in the Draft Plan,
e.g., in all cases provide information to answer the situation of “except when”.
• Emergency preparedness: The Draft Plan is completely silent on links to emergency
preparedness and response in case of a natural disaster such as an earthquake. Many
questions are raised but no information is provided in the Draft Plan. Some questions that
come to mind are: What does an increase in sea level over the next 30 years mean to the
West End beyond limiting access to the Seawall during winter storms? Is this a realistic
scenario, or should the Draft Plan consider a more aggressive scenario? What does an
increase in sea level mean to budgeting for infrastructure? How will a sea level increase
affect infrastructure? Where are the emergency social services reception centres? Do these
locations require upgrade and protection which should be articulated in the Draft Plan?
• Community Plan Review: The Draft Plan is completely silent on the Plan review process.
Would this plan be reviewed every five years? Ten years? Never? How and when will the
community be able to compare the directions and policies in the plan against real life
implementation?

4. Livability / Quality of Life: The draft plan is missing a key aspect that community residents describe as livability or quality of life. Although the terms livability and quality of life are used in the Draft Plan, these terms are not defined and quantified. Section 14.0 Community Well‐Being does not address livability and quality of life. The Draft Plan does not demonstrate that West End residents have been engaged to define and index liveability concepts within our neighbourhood context. As a result, there is no practical way of reviewing and comparing plan and policy implementation against real values and concerns as defined by residents of the community.

5. Inconsistencies in Section 7.1 Villages. Overall Directions on Page 24 identifies that new building should “generally” be between 2 – 4 storeys (approximately 20 to 40 feet). Section 7.1.1 Robson Village states that building heights of to 70 feet will be allowed (approximately 7 storeys). Section 7.1.2 Denman Village states that building heights of to 60 feet (approximately 6 storeys) will be allowed. Section 7.1.3 Davie Village states that building heights of to 60 feet (approximately 6 storeys) will be allowed. Why does the overall direction provide a guide of 2 to 4 stories when clearly this is not what will be allowed?

6. Conceptual Illustration of Davie and Bute Streets, page 32: This conceptual illustration does not represent the type of community we would like to promote. We have discussed this image with several members of the GLBT community residents in the West End. All have indicated this patronizing image does not promote serious inclusiveness. The West End is a neighbourhood where people live, raise their families and go to work. A disco ball is better suited for a dance club, not a neighbourhood street. Perhaps this illustration will draw young people from the suburbs to come to the West End to party, but it does not help foster a resilient, sustainable, safe and healthy community which is one of the Draft Plan principles found in Section 2.

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7. Section 7.2 Neighbourhoods, Page 35: This section states: “Maintain a primarily 6 storey height limit”. What is a “primarily 6 storey height limit”? Is it 5 storeys? Seven stories? Ten storeys? Something else? Under what circumstances would a height of more than 6 stores be allowed? Why is this not identified in the Draft Plan?

8. Section 7.3.4 Lower Davie Corridor: The Draft Plan does not consider down zoning lower Davie, and this is a missed opportunity. Lower Davie is an important location for the entire City, and the planners have missed an opportunity to reconsider the existing zoning of this area. Lower Davie is an important part of the City’s viewscape, which has recently already been substantially reduced by the ill thought out Cactus Club location and the Alexandria development. A reduction in the allowable density on Lower Davie should be considered. By continuing to allow high rise development along lower Davie, the City will reduce the views and sun access to an important City location as an entrance to English Bay.

9. Section 8.1 Housing Supply and Affordability: Opportunities for Home Ownership: The Draft Plan identifies the most recent key demographics and characteristics of the West End as young, dense, small household size but with children, large number of single family households, mobile, stopping point for newcomers, modest income, highly mobile, and work close to home. It is likely the area is so mobile because there is a lack of opportunity for home ownership. Owners contribute greatly to community stability. However, discussion of and opportunity for home ownership within the West End is limited and brief. Greater consideration must be given to opportunities for home ownership in the Draft Plan.

10. Section 17.12 Cost Estimates and 10 Year Funding Strategy and Table 5 Cost Estimates over 30‐Year Period and Funding Strategies, and Section 18 Implementation: These sections are important to understand, review and provide input on. During the draft community plan learning sessions, the planners identified that feedback on this Section 17 and Table 5 would be most welcome, but minimal time was available to dicuss these sections. If Council sincerely wants community feedback on complex issues such as a 30‐year funding strategy (incidentally contained within a section titled Cost Estimates and 10 Year Funding Strategy), more than 22 calendar days is needed to digest, understand, discuss, consider and provide comment upon.

11. Requirement for Clarifications and Greater Certainty: The Draft Plan and associated guidelines contain many statements that need clarification. Residents must be provided with certainty with respect to the terminology in the Draft Plan; residents and developers must know in advance what the Plan means and subjective interpretations should not be allowed. Examples of areas requiring clarification include:
• Draft Plan Page 24 and in numerous other locations throughout the Draft Plan and
associated guidelines:
– New buildings should generally be between 2‐4 storeys in height. What does
“generally” mean? Would 5 storeys be considered “generally” within this range?
Would 6 or 7 or 8 be considered within this range? The Draft Plan needs to be more
specific. For instance, in the case on page 24, it should read: New buildings should
be up to 4 storeys ……. If buildings are higher than 5 storeys, the Draft Plan must
identify when this would be allowed, for instance on Robson St between Burrard

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and Jervis. The Draft Plan must also identify why deviations from the Overall
Directions would be allowed.
• FSR:
– This concept is very important for residents to understand. It is not described in the
Draft Plan nor is there any description of how FSR relates to zoning. The Draft Plan
must explicitly identify what FSR is and what it means to the zoning changes
proposed for the West End.
• Draft Plan Section 7.2 Page 35:
– This section states: “Maintain a primarily 6 storey height limit”. What is a “primarily
6 storey height limit”? Is it 7 storeys? Eight? Five? Ten? The Draft Plan must use
words that provide certainty. For instance, this statement should read: Maintain a 6
storey height limit. If more than 6 storeys are allowed, the Draft Plan must identify
why it would be allowed.
• Draft Plan Page 65 Section 9.5.1:
– How does extending parking hours along major streets improve liveability and
pedestrian comfort? How does extending parking hours implement the policy to
improve safety, minimize congestion and support a gradual reduction in car
dependency? Clearly, something is missing from this section.
• Draft Plan Page 65, Section 9.5.5:
– This section reads: “implement laneway improvements along with infill housing or
other development ….”. What is meant by other development?
• Draft Plan Page 66:
– This section reads “… introduce parking meters into some, or all, of the one and two
hour zones …..”. Which will it be? Some or all? Is the target 100%? If yes, state this
clearly, but do not soft peddle whatever the intentions are.
• Rezoning Policy for the West End:
– This should be clearly marked as a Draft document.
• Rezoning Policy page 1, last paragraph:
– This reads “…. and in other relevant Council‐approved policies guidelines and
bylaws.” What are the other relevant policies and guidelines that a reviewer should
be considering?
• Rezoning Policy page 3, Section 3.3 c):
– This section states: “… applications contribute community benefits as defined in the
West End Community Plan Public Benefits Strategy …”. Within the entire Draft West
End Community Plan, there is no definition of community benefits, nor is the term
“community benefits” used. What exactly is being referenced in this section of the
Rezoning Policy?
• Draft West End GRM Design Guidelines for Infill Housing:
– No page numbers are provided in these draft guidelines making commenting on
them quite confusing.
• Draft West End GRM Design Guidelines for Infill Housing:

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– These guidelines identify a 20 foot minimum separation in the form a shared
courtyard to be maintained between existing development and the infill. Twenty
feet is not wide enough. In some situations, e.g., Figure 2, there is the potential to
ghettoize the units that will be facing each other. These units will be subject to
noise, lack of sunshine and generally dismal and depressing viewscapes. Council
should beware of creating policies which result in instant ghettos where only the
developer benefits.
• Draft West End GRM Design Guidelines for Infill Housing ‐ Section 3.1.2 Development
Scenarios ‐ Lot Typology 01: 33 ft to 65 ft Lots and Lot Typology 02: 66 ft to 98 ft Lots:
– Is 3.5 to 4 storeys the maximum height allowed? If yes, this should clearly be stated.
If no, then situations where more that 4 storeys will be considered must be clearly
identified. What does “where appropriate” mean? In what situations would infill be
appropriate and in what situations would it not be appropriate?
• Draft West End GRM Design Guidelines for Infill Housing Section 3.1.2 Development
Scenarios Lot Typology 03: 200 ft + Lots:
– This section states: “…. 3 to 4 storey townhouse form, up to 6 storeys, will be
considered.” What is the relevance of the 3 to 4 storey statement when up to 6
storeys will be considered? If it is intended that only 3 to 4 storeys be allowed, then
this must be stated. If, under certain circumstances 6 storeys will be considered,
then what are these circumstances?
• Draft West End GRM Design Guidelines for Infill Housing Section 3.1.2 Development
Scenarios Lot Typology 04: 200 ft + Lots:
– The last sentence of the first paragraph states: “Generally, as the lot width increases
a higher density of infill development will be accommodated with the potential for
more taller forms.” Without commenting on the grammar of this sentence, what
does it mean? Is 6 storeys the maximum? Will more than 6 storeys be allowed?
These guidelines need to state what the maximum height for infills considered will
be. Situations where more that 6 storeys will be considered must be clearly
identified if it will be allowed.
• Draft West End GRM Design Guidelines for Infill Housing Section 3.1.2 Development
Scenarios Irregular Lots in the West End:
– This section must clearly lay out the maximum height that will be allowed on
irregular lots. This is an important omission in the performance criteria identified in
this section.
• Draft West End GRM Design Guidelines for Infill Housing Section 3.1.3 Scale & Height:
– What does this section mean? How do we put together the information provided in
the table (no number) with the information provided in Figure 5? What are the
definitions of Commercial Flanking Lane, Residential Land and Commercial Adjacent
Lane and how do these related to the table?
• Draft West End GRM Design Guidelines for Infill Housing Section 3.1.4 Building Frontages:

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– What does grain of frontage mean? How can we comment on something that we do
not understand the language used?
• Draft West End GRM Design Guidelines for Infill Housing Section 3.1.5 Building Separation:
– How is adequate penetration of natural light to the courtyard and dwelling spaces
determined? What is the formula? Who determines if it is adequate?
• Draft West End GRM Design Guidelines for Infill Housing Section 3.1.6 Building Setbacks:
– We searched everywhere for the Public Realm Plan, and it appears not to exist. How
can informed comments be provided on the Guidelines when one of the plans
referenced does not exist?
– This section states: “….. such that the building does not have significant adverse
effects upon the amenity of existing development, and to an extent that minimizes
overshadowing of the shared courtyard and ensures sunlight penetration to existing
and newly created open amenity space occurs daily for significant periods of time
throughout the year”. How is “significant adverse effects” defined? This cannot be a
subjective definition, but must be a definition that residents can understand and
replicate how the determination of significance was arrived at. What is a “significant
period of time throughout the year” mean? Important statements such as these
cannot be left to the subjectivity of politicians, planners and developers.
• Draft West End GRM Design Guidelines for Infill Housing Section 3.1.11 Parking
– This section states “Parking for infill developments will be incorporated within the
primary building’s parking where possible”. What does this mean? What happens if
this is not possible?

To summarize, we do not support the approval of the Draft West End Community Plan. Participating in the planning process and providing our comments to Council for consideration has taken a great deal of time and effort and we have participated in the planning process since its inception in April 2012. We believe that our effort to be engaged in the planning of our neighbourhood is worthwhile. However, because of the process followed and arbitrary timeline of 22 calendar days to review the Draft Plan, our
comments are incomplete. For instance, we have not been able to engage with our neighbours to discuss the draft plan and there are likely many more inconsistencies in the Draft Plan that we have not identified and many more questions that we would like to have answered.

We would like Council to not approve the Draft West End Community Plan and provide the planners and community members with additional time to review the Draft Plan, provide alternatives and re‐submit the Draft Plan to Council.

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