Local areas across Vancouver should feel concern about the matter covered in item 1 below. The City of Vancouver is looking to establish precedent for pushing the four-storey apartment form off of arterial streets for a distance of “approximately 100 metres.” If this creep tactic is not broadly challenged now, on this particular site, unwarranted precedent will have been set. Note that this application under Interim Rezoning Policy appears to be only the seventh submitted since the fall 2012 inception.
The City of Vancouver posted 3 December 2015 revisions to the rezoning application for the northwest corner of Commercial Drive at East 18th Avenue — with no notification to concerned parties who had provided previous comment on the application. Below find comments, plus the previous comments of 1 June 2015, as submitted to City of Vancouver by Jeanette Jones on 9 January 2016. The failures of the revisions to address previous concerns seem inexplicable.
Comment on 3 December 2015 Revisions to Rezoning Application for
3365 Commercial Drive and 1695-1775 East 18th Avenue
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 italics.
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 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.
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
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 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.
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.”
June 1, 2015
January 8, 2016