Six Letters

leave a comment »

 
Comments to City of Vancouver on
Development Proposed for 3365 Commercial
Made
Prior to Referral to Public Hearing

 
The following six letters 2015-2016 show how little attention City of Vancouver planners paid to extensive, timely, reasoned comment. And perhaps how much planner arms were twisted in the back room by developer-funded civic parties. The 24 May 2016 gong show public hearing on 3365 Commercial did not have to happen. We know that these six letters are only a fraction of the correspondence that the City received from individuals, and from groups such as Cedar Cottage Area Neighbours (CCAN) and Coalition of Vancouver Neighbourhoods. This case study exposes City of Vancouver claims to engagement and consultation as amounting to little more than cynical misdirection.
 

1 of 6 2015 June 1 Jeanette Jones to Rezoning Planner
     
2 of 6 2015 June 1 Joseph Jones to Rezoning Planner
     
3 of 6 2016 January 9 Jeanette Jones to Rezoning Planner & Assistant Director of Planning
     
4 of 6 2016 January 27 Jeanette & Joseph Jones to Heritage Commission
     
5 of 6 2016 April 15 Jeanette & Joseph Jones to City Manager & City Clerk
     
6 of 6 2016 April 18 Jeanette & Joseph Jones to Mayor & Council
                                                       



 



 

From:      Jeanette Jones (xxx)
To:        yardley.mcneill@vancouver.ca;
Date:      Mon, Jun 1, 2015 at 9:57 PM
Subject:   Comment on Rezoning Application for 3365 Commercial Drive and
           1695-1775 East 18th Avenue

 

 
Comment on Rezoning Application for 3365 Commercial Drive and 1695-1775 East 18th Avenue

 
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 a few ground floor units with ground-level entries makes the entire 23-unit 4-storey wing fronting on 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 .2 metres on Commercial and .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.

 
Jeanette Jones

June 1, 2015



 



 

From:      Joseph Jones 
To:        yardley.mcneill@vancouver.ca
Date:      Mon, Jun 1, 2015 at 3:24 PM
Subject:   Comment on 3365 Commercial Drive and 1695-1775 East 18th Avenue

 

 
To: Yardley McNeill, Rezoning Planner, yardley.mcneill@vancouver.ca
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.



 



 

From:      Jeanette Jones (xxx)
To:        yardley.mcneill@vancouver.ca;
Cc:        kent.munro@vancouver.ca; 
Date:      Sat, Jan 9, 2016 at 9:34 PM
Subject:   Comment on Rezoning Application for 3365 Commercial Drive and
           1695-1775 East 18th Avenue, Revisions of December 3, 2015

 
 
Comment on Rezoning Application for 3365 Commercial Drive and 1695-1775 East 18th Avenue
Revisions of December 3, 2015

 
The changes to the application proposed in the revisions of December 3, 2015 do not adequately address the issues raised in my comments of June 1, 2015 on the original application. These comments are reproduced below, followed by a current response in blue.

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 a few ground floor units with ground-level entries makes the entire 23-unit 4-storey wing fronting on 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.

I do not know how to state this point more clearly. The proposed 4-storey wing that fronts on East 18th Avenue still violates both the intent and the form of development/location criteria of the Interim Rezoning Policy. It does not provide a suitable “transition zone between higher density arterial streets and single family areas.” The additional setback of the 4th storey does not bring the height of the building down to the 3.5 storey maximum specified by the IRP. If the City of Vancouver is determined to allow 4-storey apartment building form in this location, a detailed rationale for this decision needs to be provided in the Report to Council that will accompany the final recommendation of the Planning Department.

 
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.

The height of this building has not been reduced. Any additional setback of upper storeys seems to be confined to the back of the building. There is no substantial reduction in the mass of the building as seen from the street.

 
3.  The 6-storey building is set too close to the property line. The setback is only .2 metres on Commercial and .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.

The setback seems unchanged for either building. Front yards in Marpole’s new RM-9/RM-9N zone have a depth of 4.9 metres. In Norquay’s new RM-9A/RM-9AN zone, they have a depth of 3.7 metres (Guidelines, Section 4.4.1). This should be a minimum setback for 100% residential apartment buildings, especially when they front on residential streets.

 
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.

It does not look as if the two specified trees are being retained. Changes to the 6-storey building seem to reduce rather than expand the space allowed for the root balls of the grove of trees at the corner of Commercial and East 18th Avenue. The community considers these trees the true “heritage value” of this site.

 
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.

I have heard only one person from the neighbourhood speak in favour of retaining this house. The Heritage Commission has stated that its value (minimal at best) is conditional on its remaining in its current location. None of the costs of retaining and moving this house should be included in the applicant’s pro forma. No additional density should be granted for dubious “heritage retention.”

 
Jeanette Jones

June 1, 2015
January 8, 2016



 



 

From:	   Jeanette Jones (xxx)
To:        heritage.commission@vancouver.ca; james.boldt@vancouver.ca;
Date:      Wed, Jan 27, 2016 at 7:10 AM
Subject:   Comment on 3365 Commercial Drive

 
 
To: Members of the Vancouver Heritage Commission
cc: James Boldt, Heritage Planner

We would like to comment on the revised rezoning application submitted on December 3, 2015 for 3365 Commercial Drive and 1695-1775 E. 18th Avenue.

At its May 4, 2015 meeting, the Vancouver Heritage Commission voted no on supporting the original application of March 12, 2015. That application proposed to relocate and rehabilitate this house. The no vote responded to “the relocation of the house, its new siting, and its condition.” The minutes of the meeting state “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.”

We anticipate that the revised application may soon come before the Heritage Commission.

We do not support the relocation and rehabilitation of this house for the following reasons:

1.  The community does not believe that the heritage value of this house can justify the expense of relocating and rehabilitating it. None of the approximately 50 residents who attended a meeting of the Cedar Cottage Area Neighbours last summer included the retention of this house in their personal list of interests associated with this application.

2.  The earlier concerns expressed by the Commission have not been addressed by the revised application. Specifically,

(a) Relocation of the house. The Statement of Significance (SOS) states that “3365 Commercial Drive is valued as one of the last examples of the semi-rural, residential heritage of the surrounding area” (p. 2). Its main value will be lost if the house is moved and the “semi-rural” setting is developed.

(b) Siting of the house. The revised application has not changed the new siting of the house. It still proposes to relocate the house very close to a street. Its current location is well back from the street among large trees, as can be see in the pictures on p. 10-11 of the SOS.

(c) Condition of the house. The house has been poorly maintained, and little effort has been put into protecting its heritage value.

3.  The revised “infill project adjacent” remains incompatible with the heritage house. The townhouse building has been reconfigured and moved further away from the heritage house, resulting in more open space between the buildings. But the infill project still consists of a modernist, box-shaped, flat-roofed building that jars with the heritage house rather than complementing it. The design of the apartment buildings containing the 110 rental units is even more incompatible with the heritage house.

The SOS gave the house only 26 points out of a possible 100. The Commission later upgraded this to 31 points. Even when considered in its current location, this house garnered barely enough points to justify putting it on the Commission’s “C” list. We do not believe that any incentives should be given to the developer to preserve and relocate the heritage house at 3365 Commercial Drive.

 
Jeanette and Joseph Jones



 



 

From:      Jeanette Jones 
To:        sadhu.johnston@vancouver.ca;
Cc:        janice.mackenzie@vancouver.ca;
Date:      Fri, Apr 15, 2016 at 12:53 PM
Subject:   Council agenda item for april 19: 3365 Commercial rezoning

 
To: Sadhu Johnston, City Manager
cc: Janice MacKenzie, City Clerk

Please remove Policy Report #4 (CD-1 Rezoning — 3365 Commercial Drive and 1695-1775 East 18th Avenue) from the agenda for the Council meeting of April 19, 2016. This rezoning application includes a significant heritage component. At its meeting on May 4, 2015 the Heritage Commission 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,” and said that they would be willing to consider a revised application. A revised application was submitted to CoV by the developer in December 2015, but staff has not sent that application to the Heritage Commission for reevaluation. The application should not proceed to Council until the Commission has had a chance to review the revisions, which we believe do not adequately address the concerns expressed in the initial evaluation of May 4, 2015. The evaluation of the Commission is essential information that needs to be given to Council before they can make a decision on this application.

 
Jeanette and Joseph Jones



 



 

From:      Jeanette Jones 
To:        gregor.robertson@vancouver.ca;
           clraffleck@vancouver.ca;
           clrball@vancouver.ca;
           clrcar@vancouver.ca;
           clrdegenova@vancouver.ca;
           clrdeal@vancouver.ca;
           clrjang@vancouver.ca;
           clrlouie@vancouver.ca;
           clrmegs@vancouver.ca;
           clrreimer@vancouver.ca;
           clrstevenson@vancouver.ca;
Date:      Mon, Apr 18, 2016 at 12:30 AM
Subject:   Policy Report #4: 3365 Commercial Drive

 
 
To: Mayor and Councilors of the City of Vancouver
Re: Policy Report #4 to Council for 3365 Commercial Drive

We ask that you do not refer to Public Hearing Policy Report #4 (CD-1 Rezoning — 3365 Commercial Drive and 1695-1775 East 18th Avenue) at the Council meeting scheduled for April 19, 2016.

This rezoning application includes a significant heritage component. At its meeting on May 4, 2015 the Vancouver Heritage Commission 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 phrase “does not support” is the Heritage Commission’s strongest possible expression of non-support for an application. These words have been used only eight times in the past three years. 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 Report states that “staff have concluded that the revised proposal addresses the Commission’s concerns … ” (p. 11) 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. We do not believe that these small changes adequately address the concerns expressed in the Commission’s initial evaluation of May 4, 2015. The Statement of Significance says that the main value of the house lies in its treed “semi-rural” current location; relocation will destroy most of its heritage value. Only minimal changes have been made to its new siting. The condition of the house remains very poor. Even in its current location, this “heritage house” was given only 26 points in the Statement of Significance, barely enough to assure a place on the “C” list.

This application should not proceed any further until the Vancouver Heritage Commission has reviewed the revisions. The final evaluation of the Heritage Commission needs to be taken into account before Council can make a legitimate decision to refer the application to Public Hearing.

Jeanette and Joseph Jones
 

Advertisements

Written by eyeonnorquay

29 May 2016 at 9:37 pm

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s