3365 Commercial Drive
and 1695-1775 East 18th Avenue : Comment
1 June 2015
This application should not be approved in its current form for the following reasons:
1. The building form does not meet the criteria set out in the Interim Rezoning Policy. The IRP states that “mid-rise forms up to a maximum of 6 storeys” may be considered if they front on arterials. In this case, a 6- storey building is proposed to front on Commercial Drive. “Within approximately 100 metres of an arterial street” (i.e. behind the apartment building), the IRP permits “ground-oriented forms up to a maximum of 3.5 storeys, which is generally sufficient height to include small house/duplexes, traditional row houses, stacked townhouses, and courtyard row houses.” The intent of the IRP is “to encourage innovation and enable real examples of ground-oriented affordable housing types to be tested for potential wider application that will provide on-going housing opportunities.”
Until now, the phrase “ground-oriented forms” has been understood to mean the housing types listed above. In the case of this application, I was told at the Open House that three of the ground floor units in the 4-storey wing have ground-level entries, although only one unit is shown on the floor plan. In any case, the City seems to be implying that the presence of ground floor units with ground-level entries makes the entire 23-unit 4-storey wing fronting on East 18th Avenue a “ground-oriented building form.” Planners have referenced examples in other parts of the City.
This is a false comparison. Yes, there are multi-storey apartment buildings in Vancouver where there are a few ground floor units with private, ground-level entries that could be called “ground-oriented units.” But these units do not define the building form. An apartment building does not become a ground-oriented building form because it contains a few units that have private ground-level entries. It does not meet requirements where City policy specifies that ground-oriented housing types should be built. The 4-storey wing of the apartment building proposed in this application needs to be removed. All housing units behind the 6-storey building fronting on Commercial should be small house/duplexes, traditional row houses, stacked townhouses, or courtyard row houses, just as the IRP specifies. Otherwise there will be fewer, not more, examples of “ground- oriented affordable housing types” built under the IRP. This would defeat the clearly stated intent of the policy.
2. The 6-storey apartment building is too tall and massive for this site. The height and mass are excessive for a building in the RS-2 zone. The building should be shorter. Failing this, the 5th and 6th storeys should be set back at least 10 feet from the building edge. The building design should be improved to reduce the massing, and to add interest and variety.
3. The 6-storey building is set too close to the property line. The setback is only 0.2 metres on Commercial and 0.91 metres on East 18th Avenue. This is not enough. A greater setback would enable landscaping to soften the impact of the building, and make it fit in better with the surrounding residences.
4. More trees should be retained. At a minimum, the fir and hemlock trees (#1677 and #1678) identified by the arborist as being in “normal” condition should be kept. There should be sufficient space allowed for the root balls of the grove of trees at the corner of Commercial and East 18th Avenue so that those trees survive undamaged.
5. The “heritage” house should be removed. The house has little heritage value at present. It will have virtually none after it has had its interior gutted and its exterior finishes replaced, and has been moved from its present location onto a new foundation elsewhere on the site.
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To: Yardley McNeill, Rezoning Planner, email@example.com
From: Joseph Jones
Date: 1 June 2015
Please confirm that this comment on the 21 May 2015 open house for development proposed for the above address has been received and put on record.
1. Comments are listed here in order of decreasing expectation that they will have any impact on the specific development proposal or on City of Vancouver planning practices. This means that comment numbered two seems most likely to result in revision to the proposal, etc.
2. Under Interim Rezoning Policy, it seems inappropriate to permit development encroachment along East 18th Avenue into a long-established RS area through mere fact of parcel contiguity. The parcel fronting Commercial Drive should constitute the single locus for application of IRP. The East 18th Avenue parcels should emphasize ground-oriented access to dwellings and should give preference to rowhouse form.
3. The retention of cypress trees at the corner is highly desirable. Extensive discussion with the project arborist at the open house underlies the following recommendations. As presently structured, the development adjacent to the retained trees will result in a root loss of approximately 30%, significantly impairing the longevity of the five trees proposed for retention. Therefore the physical structure fronting Commercial Drive should be modified to mitigate root loss and to enhance that area’s provision of water and nutrients. Slight additional setback of the building should be coupled with more extensive foundation setback to accommodate existing root structure. Cantilever with design to channel rainwater under the sheltered portion should provide a viable option, especially considering the large benefit already conferred on the developer in the form of requiring no commercial space on ground floor. As necessary to achieve this additional root space, commensurate reduction in underground parking would be acceptable. The existing grove of cypress trees amounts to a major amenity. Since absolutely nothing will be coming back to the neighborhood from this proposed development, impact on already enjoyed amenity should minimized as much as possible.
4. The weakest, smallest cypress should be removed immediately to enhance the viability of the remaining four. The arborist does not anticipate a healthy future for the runt. With slight additional setback, one additional tree to the north that is scheduled for removal could be retained.
5. The setback from Commercial Drive appears to be insufficient. At an absolute minimum, it should equal that of the Porter STIR project to the immediate south of the site.
6. It is not apparent that the development or the neighborhood will benefit at all from the extreme relocation and retention of a highly dubious “heritage” facade. This supposed heritage element should in no way benefit the developer in terms of increased FSR or height or transfer allowances.
7. It seems clear that the City of Vancouver via the Property Endowment Fund is prepared to sell its parcel of land to Cressey and to extract value from the neighborhood with no return whatsoever to the affected location.
8. This IRP proposal appears to be the fifth that has been entertained by the City of Vancouver since the 2012 inception of an obviously failed policy. It does not go unnoticed that the only IRP rejection so far has occurred on the far west side of Vancouver. Even worse, this particular IRP project is the third to land in Kensington-Cedar Cottage, and lies within less than ten blocks of an IRP site on Knight Street that eliminated existing affordable apartment housing and clearly fudged on the criterion of adjacency to a shopping district. The density dumping and amenity extraction that City of Vancouver fosters in KCC is execrable planning and serves a blatantly classist agenda.
9. There is evidence that Cressey is an exploitative and abusive landlord. It is unfortunate that the City of Vancouver would permit these operators to concentrate in one local area and to subsidize them handsomely.