A Planner Warns

A longish read, but well worth it.  All you need to know about the Regional Growth Strategy, the OCP and why they matter to residents.  Unfortunately, the message needed to be repeated a year later.

Let's elect a Council that pays attention to professional planning advice!

 Letter to Council – Alan Osborne

July 7, 2021 

OCP Review.

Dear Mayor and Council 

This is regarding the OCP Review, on your July 12th agenda. I’d like to provide some comments both on the OCP review itself and on some of the documents included in that agenda package. 


I want to start by saying that any local politician who doesn’t look for ways to meet the housing needs in their community shouldn’t be in office. I worked on affordable housing issues for provincial and local governments, and I appreciate how challenging this can be. A key thing that I learned, however, is that at the end of the day the market determines housing prices, regardless of what the municipality plans. You only have to look at recent “small lot” developments that developers promised would be affordable. Canora Mews and Eaglehurst, are two examples. Houses in both developments ended up selling for much more than what the developers said they would. I don’t blame the developers, as they will always sell at the market price. However, anybody who tells you that the OCP can achieve affordable housing in expensive neighbourhoods is either misleading you or doesn’t understand land economics. The real estate market has determined that North Saanich is a very desirable place to live and that means it is and will be an expensive place to buy or rent. The residents I’ve spoken with understand this and that is why they are objecting, not to the need for “affordable housing”, but rather, to the reality that it can’t be built in these expensive neighbourhoods. They understand that what is being proposed will make their neighbourhood less attractive without even accomplishing the social goal of more affordable housing. 

There’s good reason why the CRD Regional Growth Strategy (2018) requires at least 95% of new housing be built inside the urban containment area. It’s because those areas have the land, transit, water, sewer and other services to accommodate new development and can do so in a way that both provides more affordable housing and at the same time meets environmental goals (e.g. contains urban sprawl). And there’s good reason why North Saanich is NOT in the urban containment area, because it was recognized that this municipality does not have land prices or servicing which will allow affordable housing to be built, nor is it the best place to build it because of the lack of transit. 

As I mentioned in an earlier letter to Council, transportation costs are typically 20% or more of the family budget, so it makes no sense for Council to allow yet more housing where families cannot use transit and are required to have two or more vehicles. Council shouldn’t ignore the need for affordable housing, but it needs to be realistic about how and where it can happen. One example of a real contribution was when Council secured land for 10 Habitat for Humanity houses off Lochside Drive. Such opportunities provide actual affordable housing and should continue to be sought out where they can, provided they are in the right locations (i.e. close to good transit). 

DEEP COVE SMALL LOT AND MULTI-FAMILY HOUSING (Good development + wrong location = bad planning) 

On July 7th on CBC Radio Victoria Mayor Lisa Helps was interviewed about the concept of giving families more affordable housing options by allowing more small lot housing and townhouse developments in some Victoria neighbourhoods. She emphasized that this was the only way to address affordable housing without adding more housing in the suburbs. She said that more housing in outlying areas would prevent us from meeting our goals for reducing GHGs because the residents in those houses would be car-dependent. She understands that while affordable housing is needed it needs to be provided where people don’t have to be dependent on cars to shop, go to work etc. 

There are three major problems with the OCP “concept” of adding small lot housing and townhouses in Deep Cove. (1) These houses would not be affordable. Ask any realtor; any new house constructed on any size lot in Deep Cove will sell far above any “affordable” housing threshold. (2) Adding more housing to Deep Cove, Ardmore, Lands End, or any rural residential area means adding more cars on the roads when the municipality is trying to reduce GHG emissions. Council cannot expect households to reduce their emissions while at the same time approving more car-dependent housing in rural areas. (3) Small lot and townhouse developments would be completely out of character with that neighbourhood. It is not “sensitive infill”, it is urban sprawl. Deep Cove residents are opposed because they know that once the precedent is set for “suburban” density in Deep Cove it will make it much harder for future Councils to say “ No” to yet more of such development. It’s the “slippery slope”. 

The planning consultants took a concept that may work in Victoria or North Vancouver and proposed it in a rural area. To put this in a simple mathematical formula: Good development + wrong location = bad planning. 


This one is challenging because while it is outside the urban containment area it does have “reasonable" transit and some services and it is the only portion of North Saanich that could allow significant housing without the new residents being car-dependent. It is also the only area of North Saanich where BC Transit has indicated there could be significant service expansion. So, it has potential, but a lot of work needs to be done, particularly with the residents in that neighbourhood, to work through the issues and options. Given how little work and consultation has been done and could be done before the OCP review is completed, it would be premature to designate this area for redevelopment in the new OCP. Rather, I think it would be wise for Council to indicate that this is an area that needs further study and consultation, and post-COVID undertake extensive consultation about the future of the area. This would also allow Council to talk to people like Mayor Helps and and others in the region, to ensure that they are all on the same page about where new and affordable housing needs to occur in the region, and more specifically whether it would be a good idea to expand the regional urban growth boundary to include this portion of North Saanich. I suspect the answer is “no”. 


I’ve heard Council members refer to the fact that some of the proposals that people are objecting to now are already allowed under the current OCP (2007). The implication is that whatever is in the current OCP is good policy and is well-supported by the community. That would be a mistake. I was around during the previous OCP review and it was also heavily criticized. As is the case today, much of the controversy surrounded the housing policies, and the proposal to allow significant "infill housing” (the current euphemism is “sensitive infill”!). I hope we have learned since the current OCP was developed. We should have learned that affordable housing is not as simple as increasing density in various neighbourhoods and “infill development” doesn’t occur without significant loss of trees. 

Secondly, as the municipality’s Select Committee on Climate Change pointed out, the current OCP was not developed with a “climate lens” and the new OCP needs such a lens. In simple terms, this means reviewing each policy in the OCP and asking questions such as “How will this policy help us meet our climate goals?” and “Will this policy get more cars off the roads or add more cars to the roads?” The current OCP is outdated and residents are understandably questioning some of the current policies. 

In the past few years Council has received significant negative feedback about some of the “infill” housing that is allowed under the current zoning and OCP, and there are many more lots that can still be developed, and many more suites still to be built. I doubt most residents appreciate how many additional houses and suites could still be built, and how many more trees will have to be removed, without any further changes to the OCP. This is a good example of where the OCP process is lacking. It’s all about opinions, with little or no data. Council should give the community clear information on how much development they can already expect to see under the current OCP over the next 5,10 and 20 years, and the impacts they can expect to see, in terms of tree removal, cars on the road, etc. and then how much more above that would occur if the proposed “concepts” were approved. 


I have a couple of comments regarding the “Responses to Misconceptions” document While this document is apparently intended to clear up “misconceptions”, there are some parts that I find misleading and I think need to be addressed. 

While it’s true that the OCP doesn’t “automatically rezone all properties” it's far from a benign document It sends a very clear signal to those wishing to develop; that Council will approve their application to rezone if they apply for what is in the OCP. When an OCP signals which properties can be redeveloped, the value of those properties increases. Property is assessed on the principle of “highest and best use” (confirmed by the selling price of similar properties). So, for example, if the OCP shows that a 2 acre parcel could at some point be rezoned to allow 20 small lot houses or 30-40 townhouses then the assessed value of that parcel should increase to reflect that increased development potential. Certainly some developers will be willing to pay significantly more for that parcel of land because they have good reason to assume that the rezoning will be approved. So let’s be clear, changes to an OCP certainly will increase property assessments and therefore also increase property taxes. And of course higher property taxes will be a financial strain for some owners and make it more likely they will either need to, or want to, sell their land to one of these developers. So it’s misleading to reassure people that “nothing will change” because of the OCP. Let’s be clear that a change to the OCP will change property values and will increase development pressure on those properties. 


The second issue I need to address in the “misconceptions” report deals with the regional growth strategy and the suggestion that it provides room for significant additional housing in rural residential areas and other areas outside of the urban containment area. I was indirectly involved when the CRD Regional Growth Strategy was initially developed. The Strategy states “Even modest population growth would undermine the regional vision if it were accommodated, as it has been since the 1950s, through further expansion into farms, forests and the countryside”. It was obvious to those involved that some continued development in rural residential areas was inevitable simply because there were still thousands of vacant lots in the various municipalities that would eventually have houses built on them. So the regional strategy couldn’t state that 100% of all new housing needed to be within the urban containment area. To allow for existing lots to be built upon the RGS states that at least 95% of new housing needed to be in the urban growth area. This wasn’t, as the “misconceptions” document suggests, a licence for North Saanich to rezone even more rural land for housing. It was a clear message to not allow further development in the “countryside”. 


My final comment is that it's disheartening to see how this OCP process has unfolded. To be blunt, there has been unnecessary stress on all parties, and much time wasted on “red flags” instead of real priorities. Watching Council’s discussions I also appreciate your frustrations as well. Council is inundated with concerns from people reacting to “concepts” that were apparently developed without Council input. Residents either don’t understand how that can be or don’t trust that it is the case. It’s clear that Council should have given direction to the “project team” before any “concepts” were developed. 

I had hoped that the community’s and Council’s time and energies would be spent addressing the most pressing issues North Saanich, changes we need to make to address climate change, to improve food security and to protect our natural environment. These are the community’s priorities. It’s not too late to get this process back on track and ensure that the new OCP reflects the community’s priorities. 

Thanks for the opportunity to comment. I appreciate all that you do for North Saanich. 

Alan Osborne

North Saanich (since 1987)

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