3365 Commercial PH
Letters of Joseph Jones and Jeanette Jones
To Mayor and Council on 20 May 2016
The following two letters respond to a proposal to approve rezoning of 3365 Commercial Drive and 1695-1775 East 18th Avenue at public hearing on 24 May 2016. Part of Norquay falls within the boundaries of Kensington-Cedar Cottage, the affected Vancouver neighborhood. Beyond this fact, the proposal would set unacceptable precedent for all of the City of Vancouver.
Joseph Jones at 3:33 pm
Public Hearing — 24 May 2016
3. REZONING: 3365 Commercial Drive and 1695-1775 East 18th Avenue
I Joseph Jones OPPOSE the Cressey proposal to develop the northwest corner of Commercial Drive at East 18th Avenue for the following reasons:
1. The various appeals to a grab-bag of supposedly applicable policies fail to stand up to scrutiny. One immediate piece of evidence for the shaky policy foundation is how the development site has been carved up into kludgy and dodgy subareas.
When I speak to Council at the public hearing, I will focus on outlining the dubious history of the Interim Rezoning Policy (effective 4 Oct 2012 | amended 2 Dec 2013 and 19 Apr 2016). A mapping of 2012-2016 IRP sites is provided as appendix to this letter.
2. The off-arterial extension of non-ground-oriented housing form, into the area along East 18th Avenue, fails to respect the Interim Rezoning Policy requirement to provide
Ground-oriented forms up to a maximum of 3½ storeys, which is generally sufficient height to include small house/duplexes, traditional row houses, stacked townhouses and courtyard row houses (p. 2 of Appendix A: Affordable Housing Choices Interim Rezoning Policy
A simulacrum end-run that proposes design “to emulate the rhythm and width of town homes” (p. 9) violates the Interim Rezoning Policy and is not acceptable. This aspect would set precedent for the entire City of Vancouver. A “3½-storey rental block” (p. 10) clearly is not a ground-oriented form.
3. There is almost no local area support for the use of heritage bonusing in this proposal. To this significant degree of non-support add the fact that the limited assessment from the Vancouver Heritage Commission has been unusually negative. Planners have tellingly avoided taking the insufficient revision of the unacceptable proposal back to the Commission. This willful misuse of “heritage” provision amounts to scam.
4. Discussion with the project arborist at an open house made it clear that keeping the “significant stand of five mature Lawson Cypress trees at the corner of the site” (p. 8) would be an empty gesture. With proposed development, the remaining trees would experience a serious 30% loss of root structure. The trees need more room, and the adjacent Lawson Cypress trees in the grove need to be retained. Unless the trees are given more space, a major existing green amenity will be eradicated (both immediately and by rapid death) from the neighborhood by this development proposal.
5. The City of Vancouver proposes to hand over to big Vision-Vancouver-donor Cressey a piece of public land owned since 1939 — “nine percent of the total subject site area” (p. 16). To allow this would amount to extraction of value from the local area with no payback. This has become a depressing and regular pattern for how the City of Vancouver deals with East Vancouver.
Perhaps that money would be applied to the $55 million purchase price for the Arbutus corridor on the favored side of town? Despite already owning most of the land needed to deliver a Renfrew Ravine linear park (connecting Norquay Park with Renfrew Ravine), the City of Vancouver continues to fail to provide any part whatsoever of the amenity package specified under the 2010 Norquay Plan. A large area of East Vancouver is undergoing massive and rapid redevelopment with none of the promised corresponding improvement to public realm.
6. The lengthy process for the site at Commercial and East 18th Avenue has seemed dominated by back room collusion between developer Cressey and the City of Vancouver. Despite extensive efforts made by local area residents to provide input, the end result has incorporated nothing significant from community feedback.
The City of Vancouver insulted a committed group of people with a stealth posting of 3 December 2015 “revisions to the application” — providing no notification to participants. In light of the foregoing comments, consider how little difference the following minor tweaks have made to address severe policy problems:
Revisions to the Application
December 3, 2015: Revised drawings were submitted on December 3, 2015 to address concerns raised by staff and the community. The overall density was reduced from 2.55 FSR to 2.40 FSR with a corresponding reduction in unit count from 118 residential units to 114 residential units. Increased setback and massing changes are proposed to the rental building, a reduction to the size of the proposed infill building on the heritage site, and the location of the underground parking ramp has been moved closer to Commercial Drive. In addition, the Transportation Study has been updated.
Appendix: Mapping of the Six Proposals under Interim Rezoning Policy 2012-2016
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Jeanette Jones at 4:49 pm
Re: May 24 Public Hearing Item 3. Rezoning: 3365 Commercial Drive and 1695-1775 East 18th Avenue
I am opposed to the Rezoning Application for 3365 Commercial Drive and 1695-1775 East 18th Avenue for two main reasons.
1. The 3.5-storey apartment building on East 18th Avenue does not meet the Form of Development/Location criteria set out in the Interim Rezoning Policy.
Within approximately 100 metres of an arterial street (i.e. 1.5 blocks), 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 [Appendix A]
The phrase “ground-oriented forms” is commonly understood to mean the housing types listed above. The list does not include low-rise apartment buildings. In the case of this application, the City of Vancouver is implying that the presence of a few units with ground-level entries makes the entire 23-unit, 3.5-storey apartment building a “ground-oriented building form.” This is contrary to accepted usage and to the Interim Rezoning Policy.
Appendix A of the IRP also states:
The intent of this Interim Rezoning Policy 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.
Building anything other than small house/duplexes, traditional row houses, stacked townhouses or courtyard row houses on East 18th Avenue would defeat the clearly stated intent of the Interim Rezoning Policy. This application is the first under the IRP to include an area off the arterial street. It will set a precedent for future IRP applications across the City of Vancouver.
2. The heritage component of this application does not have the support of the Heritage Commission or of the community.
The Vancouver Heritage Commission at its meeting on May 4, 2015 stated:
THAT the Vancouver Heritage Commission does not support the application to relocate and rehabilitate 3365 Commercial Drive due to the relocation of the house, its new siting and its condition;
FURTHER THAT the Commission is willing to consider a revised application that would address the position of the heritage house on the site with a reduced, more compatible infill project adjacent.
The expectation of the community (and very likely, of the Heritage Commission itself) has been that a revised application would go back to the Commission for further review.
However, staff failed to send the revised application, submitted by the developer in December 2015, to the Heritage Commission for reevaluation. The Staff Report states that “staff have concluded that the revised proposal addresses the Commission’s concerns … ” (p. 11) But the only revisions that have been made to the heritage component of the application are that the massing of the “infill project adjacent” has been slightly reduced and the infill project has been moved a little further toward the back of the site. I do not believe that these small changes adequately address the concerns expressed in the Commission’s initial evaluation of May 4, 2015. Only minimal changes have been made to its new siting. The condition of the house remains very poor. The current treed “semi-rural” location of the “heritage house” is responsible for most of the 26 points it was given in the Statement of Significance, barely enough to assure a place on the “C” list. Moving the house will destroy most of its heritage value.
The community does not believe that the applicant should be given any additional density for moving and rehabilitating this house. The true heritage component of this site is the grove of large trees on the corner of Commercial and East 18th Avenue. These trees remain under threat because the proposed building envelope encroaches on the space needed by their rootballs if the trees are to survive.
I ask that you DO NOT APPROVE this application for the reasons given above.