We are residents and business owners from Cedar Cottage. We are the Cedar Cottage Area Neighbours (CCAN) with 83 members.
We are opposed to this rezoning as presented through the “Affordable Housing Policy” (AHC Policy). We ask that you not approve it based on our objections as we state below.
The staff report to Council for this project says, on page 4: https://council.vancouver.ca/20210608/documents/rr5.pdf
Rezoning applications considered under the AHC Policy must meet a number of criteria such as providing 100% of the residential floor area as secured rental housing, fitting contextually with neighbouring development and meeting location requirements. The subject site is located on an arterial and within 500 m of a local shopping area, where six-storeys buildings may be considered under the AHC Policy.
This project is not on an arterial. There is a lane and City easement between this proposal and the arterial. All development over the easement is disallowed since 1963 into perpetuity. Attached is the easement document from Land Title that shows this.
The block faces for this project are on East 15th Avenue and Maddams Street, NOT the arterial. The City says that if a lot faces off an arterial, within100 m from an arterial, then it can only at most be built to 4 storeys. Following is the link to the AHC Policy, see page 2: https://bylaws.vancouver.ca/bulletin/policy-rezoning-affordable-housing-choices.pdf
Below is a excerpt including the City’s definition of a block face:
The other issue is the fact that here are already 2 of these projects within 10 blocks of each other on ANY arterial. That’s the City policy and it says that only two can be built to maintain neighbourhood character and this project will make three.
Below, A & B, explain what our issues are with this project under AHC Policy.
A. Following is the Council Report that states the ‘2 within a 10 block rule’ on any arterial, NOT just on the same arterial: http://former.vancouver.ca/ctyclerk/cclerk/20121003/documents/ptec20121003min.pdf
The Council Report on housing affordability says (on page 5 of 13):
Action 1: Implement an Interim Rezoning Policy that increases affordable housing choices in Vancouver’s neighbourhoods
• The maximum number of affordable housing rezoning applications be 20, and limited to 2 within ten blocks on any arterial, to maintain neighbourhood character;
Ø There are already 2 of these types of projects within 10 block of each other on arterials and also within a 10 block radius. There is one across the street from this proposal and a second one 7 blocks from the proposal; following are the addresses to the projects already built:
Ø 3120 to 3184 Knight
Ø 3365 Commercial Drive and 1695 to 1773 East 18th Avenue
B. The fact is that in the Council report where the last one of these projects was built in our area just off an arterial, that report relied on the point that there would be no more of these in a 10 block radius. If the City is going to use that reasoning for that project then the same reasoning should be used for this new project. Again, this project will make too many of these projects in an area. Attached is a picture showing the 2 within a 10 block radius. Following explains this point:
The City has already validated the ‘2 within a 10 block radius rule’ because they used it with the Rezoning at 3560-3570 Hull Street which is off an arterial and referred to the rezoning at Commercial Drive & East 18th Avenue as the second project. Following is the link to that report for the Public Hearing of July 10, 2018 which shows this, please read page 5: https://council.vancouver.ca/20180619/documents/p2.pdf
A maximum of 20 applications are permitted under this policy, and no more than two projects within 10 blocks along an arterial street. This is the second rezoning application within a 10-block radius (the first one approved was at 18th Avenue and Commercial Drive), thereby neutralizing this portion of Commercial Drive and the Victoria Diversion from future AHC applications.
CCAN feels that the Corporate Policy AE-028-01, Code of Conduct of Feb 9 2021 is not being followed, especially we are relying on the fact that staff must follow the established policies. Following is the code link and what it says staff must do: https://policy.vancouver.ca/AE02801.pdf
7.3 Staff are expected to: • Give effect to the lawful policies, decisions and practices of Council, whether or not the staff member agrees with or approves of them
Page 7 of the Council Report says staff have analyzed the proposal against the RT-2 District Schedule. We assert that the intent with development in this area to analyze the effect on adjacent properties and the character of the area. This development is in fact a 7 storey building in an area of single family houses and therefore the massing and density is not compatible with the neighbourhood.
This proposal will create extreme shadowing on the houses to the north of the proposal. If an amenity area is put on the roof this will create overlook to the houses and a lot of noise given there will be 82 units using this space.
Further, all the affordable housing buildings built in this area over the last few years have had vacancy signs up ever since they were built. This shows us that too many units are being built in our area for the demand.
Thank you for considering our input.