Regional Growth Strategy

The CRD Regional Growth Strategy 

Guardrails for Our Community 

            The current OCP Review has trod a difficult path almost from its inception in the summer of 2020.  There are a variety of reasons for this.  One of them, and perhaps the most important, is the failure to recognize and emphasize the mandatory guidance stipulated by the Regional Growth Strategy.  These foundational concepts and policies, while not having been entirely ignored, have not been given their rightful prominence. 

            It is only after recently reading the Regional Growth Strategy again that I was fully impressed with the significant import of this policy framework embraced by all municipalities within the CRD.  Our OCP Review process has not respected these important policies.  In fact, the process to date has every appearance of attempting to sidestep the RGS as it applies to North Saanich.  As I learned, the RGS is both a foundation and framework into which each Municipality's OCP must fit quite tightly.  For me, and probably for many, a general knowledge of the RGS was not sufficient - as we often hear, “the devil is in the details.” 

            And what are these details?  Table 1 on page 6, lists 33 statements of policy and principle from the RGS document.  These spell out the seven objectives of the RGS and the principles and policies by which they can be effectively implemented.  

            The bedrock of the RGS is the Urban Containment Policy Area.  It effectively divides the CRD into two zones; the UCPA which is to be the focus for commerce and urbanization and all other areas outside of it which specifically have a rural and agricultural focus.  There is extensive language in the RGS document specifying appropriate activities for each zone. 

            The language defining the UCPA and the policies both within it and outside is very clear.  North Saanich is entirely in the area outside the UCPA, i.e., Rural/Agricultural. 

            The Regional Growth Strategy can be found here: Regional Growth Strategy | CRD 

            Some of the key defining phrases include (taken directly from the RGS): 

§  The protection of rural communities starts with clearly defining and distinguishing between urban and rural areas.

§  The Urban Containment Policy Area is intended to accommodate 95% of the region’s new dwelling units

§  New development in the Rural/Rural Residential Policy Area is not intended to exceed 5% of the region’s new dwelling units.

§  Keeping urban settlement compact will help protect the character and quality of rural communities,

§  A designated Urban Containment Policy Area aims to keep urban areas compact and to keep growth largely contained within its boundaries

§  The Regional Growth Strategy supports the development of complete communities[1] within the Urban Containment Policy Area

§  Focus employment and population growth primarily in complete communities,

§  Within the Urban Containment Policy Area, employment and population growth is to be accommodated in complete communities,

§  Increase the proportion of apartments, row houses and other attached housing types within the Urban Containment Policy Area, especially within complete communities.

§  To support quality of life and community character in rural areas, urban containment directs growth into complete communities to reduce development pressures in the Saanich Peninsula…

§  The provision of affordable housing to accommodate the anticipated population increase is the responsibility of many stakeholders

§ In rural areas, mobile homes, secondary suites and detached accessory suites may provide more affordable housing.

Table 1: a summary of the acreages in each Municipality designated as within or outside of the UCPA boundary.   North Sannich is completely outside the UCPA while Sidney is entirely inside it. 

From the foregoing, it is evident that there is a very clear distinction between the urban and rural zones within the CRD entity; it has very specific guidelines regarding growth management. 

            Our OCP Review process has tended to blur or deemphasize the very distinct border between the two areas and the very different policies and principles applicable to each.  North Saanich, like Metchosin and the Highlands, contains no land designated for Urban Policy Management.  In contrast, nearby Sidney is entirely within the UCPA.  This distinction has never been given prominence when it is actually a fundamental guiding precept in the OCP reviews of both communities. 

            The effect of this inappropriate procedural choice has seen the Project Team spend an overwhelming proportion of both their time and fiscal budgets on urban related planning and policies.  Despite Council's infrequent attempts to grab the wheel, this myopic focus has persisted.  This direction has been entrenched since the early days of Phase 2 with the effect that this Review pathway, although well off the legitimate RGS route, has taken on the appearance of being the main road.  Residents and politicians alike have been led to believe that urban problems and urban solutions are applicable in North Saanich.  This is completely at odds with the intent and language of the RGS.

 

            Furthermore, it has severely detracted from the very important work for food security and climate change priorities addressable in the OCP.  Simply put, to sidestep the RGS is to put the character of our community at risk and fall short in our obligations. 

            It is important to refocus, if there ever was a focus, on a couple of important points.  Firstly, compliance with the RGS policies and principles is not a matter of personal choice; it may even have a legal basis.  Nevertheless, the language is very clear.  Whether we as individuals like or dislike the guidance in the RGS for our community, implementing it is not optional. 

            Secondly, implementing it over the objections of some, is not entirely bad.  It means that North Saanich can, as it should, embrace and strengthen the rural and agricultural values with which it is blessed while not degrading those values with inappropriate land-use policies.  This direction should not be seen as catering to the “personal preferences of a privileged few”, but as a way to fulfill our obligations within the CRD.  Our obligations are to maintain and preserve rural values and improve and strengthen our contribution to food security for the region.  Again, this is not just a matter of opinion but a designated obligation that North Saanich has as an RGS partner. 

            Other municipalities have similar obligations.  For example, Sidney, entirely within the UCPA, provides commercial and residential assets that North Saanich cannot and should not attempt to replicate.  

These relationships among those on both sides of the UCPA Boundary are truly symbiotic.  To wilfully look away from the RGS guidance is to undermine the natural diversity within the CRD and to put at risk the benefits of symbiosis.  The mindless drive towards housing everywhere is the social equivalent of the agricultural monoculture.  Monocultures are weak and vulnerable as they lack diversity.  Socially, ignoring the Urban Containment Policy Area Boundary carries the same risks. 

Over the years, we have frequently heard the same tiresome refrain about North Saanich needing do "its share" about housing supply.  Of course, we are doing our share by contributing to food security and environmental and social well-being, benefits that Sidney and Langford are no longer able to supply.  Thankfully, we have the RGS to help us on that path – “Everything for Everybody, Just Not Everywhere." 

Recent information from the Director of Planning reveals that NS is already outperforming in providing its share of housing to the CRD.  Of the maximum 5% growth to accrue to the CRD rural lands, the District of North Saanich has absorbed “60-70% of that over the last 5 years” although our share of the CRD rural lands is only 13.6%.  Have we similarly increased our agricultural productivity?  How is the Project Team reconciling this discrepancy? 

            The map on page 5 shows graphically the arrangement of the wisely designed two RGS zones in the CRD.  Both logic and policy tilt strongly in favour of the North Saanich OCP remaining firmly aligned with the objectives and principles of the Regional Growth Strategy. 

Unfortunately, since none of the offered land use options align with the RGS, the OCP Review process has not demonstrated compliance with it in several different ways.  It is critical that North Saanich uphold its moral and contractual obligations under the RGS agreement and that the OCP Project Team be directed by Council to thoroughly review their Six Concepts and bring them fully into alignment with the spirit and intent of the Regional Growth Strategy within the remaining term of this Council. 

 

 

Chart 2: The coloured areas on this map are all UCP Areas and carry an Urban/Commercial focus.  All other areas are designated Rural/Agricultural by the RGS.  The small pie charts depict the balance between Urban and Rural areas within each Municipality -  blue represents the proportion of urban land.

RGS Defining Statements 

Table 2: this table is a tally of all references in the Regional Growth Strategy of January 2018 that define or refer to the Urban Containment Policy Area.  North Saanich is entirely outside the UCPA and is thus designated Rural/Agricultural.

 

#	Section	Page	Quote	UCPA: in/out	Comment
11	1.1	13	that Rural/Rural Residential lands are not intended to become future urban areas requiring extensive services	Outside
15	1.2	22	Rural and rural–residential communities offer a choice of rural lifestyles and outdoor recreation opportunities that complement the surrounding working landscapes and preserve ecological diversity.	Outside
16	1.2	22	New development in the Rural/Rural Residential Policy Area is not intended to exceed 5% of the region’s new dwelling units.	Outside	·   Recently, North Saanich has received 60 to 70% of the 5% allotment
17	1.2	22	… provide for land uses consistent with the Growth Management Concept Plan and adopt policies that would prevent lands designated as Rural/Rural Residential from becoming future urban areas.	Outside
20	2.2	27	Do not further extend urban sewer services outside the Urban Containment Policy Area Boundary depicted on Map 3(a).	Outside
22	3.1	29	Outside the Urban Containment Policy Area, the notion of what makes a community complete may be yet different and the criteria set out for complete communities does not apply to the Rural/Rural Residential Policy Area.	Outside	·   The RGS intention is that complete communities will be within the UCPA
25	3.2	31	In rural areas, mobile homes, secondary suites and detached accessory suites may Provide more affordable housing.	Outside
26	3.2	31	Growth management measures could have the effect of limiting the supply of new lands for the urban housing market, thereby putting upward pressure on housing prices, particularly for single detached homes.	Outside	·   This drawback is offset by the overall range of benefits accruing from the RGS concept
30	6.1	37	6.1 Foster a Resilient Food and Agriculture System, including Principles ii, iii, iv and v.	Outside
31	6.1	38	Monitor the status of agricultural land, including the amount of actively farmed land, with the objective of promoting agricultural viability and food production.	Outside
32	Community  Profiles	47	North Saanich:  The community’s long term development plans are based on the desire of residents to retain rural character and safeguard environmental qualities. The District’s policies reflect a strong commitment to preserve the agricultural land base and agricultural activities in the municipality.	Outside
33	Glossary	55	Urban Containment Policy Area Boundary The area contained within a regulatory  boundary (an urban containment boundary) marking the limit between a defined urban growth and servicing area and other areas such as rural and resource areas, where urban growth is discouraged.	Outside
2	1.1	11	A designated Urban Containment Policy Area aims to keep urban areas compact and to keep growth largely contained within its boundaries	Inside
6	1.1	11	To support quality of life and community character in rural areas, urban containment directs growth into complete communities to reduce development pressures in the Saanich Peninsula,	Inside
7	1.1	12	The Urban Containment Policy Area is intended to accommodate 95% of the region’s new dwelling units.	Inside
8	1.1	13	Within the Urban Containment Policy Area, employment and population growth is to be accommodated in complete communities,	Inside	·   Complete communities are intended to exist within the UCPA, not outside of it
9	1.1	13	Accommodating growth in complete communities is central to reducing community-based greenhouse gas emissions, reducing development pressure on rural and resource lands and keeping infrastructure affordable	Inside
10	1.1	13	Where Capital Green Lands and Renewable Resource Lands Policy Areas overlap with the Urban Containment Policy Area, the land use policy for the Capital Green Lands and Renewable Resource Lands Policy Areas shall take precedence.	Inside
12	1.1	21	Provide for land uses consistent with the Growth Management Concept Plan depicted on Map 3(a) and adopt policies to implement the Growth Management Concept Plan	Inside
3	1.1.ii	11	Focus employment and population growth primarily in complete communities,	Inside	·   Very clear guidance
4	1.1.iii	11	Increase the proportion of apartments, row houses and other attached housing types within the Urban Containment Policy Area, especially within complete communities;	Inside	·   Very clear guidance
5	1.1.iv	11	Locate a minimum of 95% of the region’s new dwelling units to 2038 within the Urban Containment Policy Area.	Inside	·   Very clear guidance
13	1.2	22	Keeping urban settlement compact will help protect the character and quality of rural communities, ensure that they remain strongly rooted in the agricultural and resource land base, and allow the rural countryside and natural landscape to remain a durable fact of life in the Capital Region.	Inside	·   Very important for North Saanich
14	1.2	22	The protection of rural communities starts with clearly defining and distinguishing between urban and rural areas.	Inside	·   Very important and clearly delineated
19	2.2	25	Keeping urban settlement compact will help create the densities needed to create efficient infrastructure services.	Inside
21	3.1	29	The Regional Growth Strategy supports the development of complete communities within the Urban Containment Policy Area	Inside	·   Not outside of it
23	3.1	29	Complete Communities Criteria [are within the UCPA]	Inside
24	3.1	30	Identify locations within the Urban Containment Policy Area that support the wellbeing of residents, consistent with the Complete Communities Criteria outlined in Objective 3.1, and adopt policies to direct growth to these locations.	Inside
27	3.2	31	The provision of affordable housing to accommodate the anticipated population increase is the responsibility of many stakeholders including the Capital Regional District, local and senior levels of government, industry and the not-forprofit sector.	Inside
28	5.1	35	Finding ways to ensure the long term, affordable supply of strategic economic resources such as water, aggregate and energy;	Inside
29	5.1	36	Ensure the long–term protection of Renewable Resource Lands…[including] lands within the Rural/Rural Residential Land Use Policy Area as well as the Urban Containment Policy Area	Inside
1	Context	8	Achieving the regional vision requires a concerted effort to largely shift to policies that encourage investment and development in complete communities within the designated growth area	Inside
18	1.2	22	Principles: I to iv

 

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[1] P 53: a “multiple-use urban community that contains within its boundaries the full range of facilities and activities necessary to meet typical household needs for employment, shopping, personal services, recreation, housing, education and other goods and services.”  North Saanich is not an urban community.

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February 28, 2021

Dear Mayor and Council:

 

RE: Issues Regarding Discussion Paper

The discussion papers that purport to address “emerging themes” do not all address the priorities that participants identified in the OCP survey.  The paper entitled Complete Communities is particularly irrelevant to future planning for North Saanich.  In referring to the Regional Growth Strategy (RGS) it fails to include specific RGS policies regarding protection of rural communities.  It makes no reference to the purpose of the RGS Urban Containment policy, which is to restrict growth in the region to certain urban areas.  

On Page 11 of the RGS there is the following statement: “Urban Containment directs growth into complete communities [my emphasis] to reduce development pressures in the Saanich Peninsula, rural Westshore, Sooke and the Juan de Fuca Electoral Area.” 

The concept of complete communities comes from terminology in the RGS and by its definition does not apply to Rural/Rural Residential communities.  Objective 3.1 of the RGS specifically directs development of complete communities “to be within the Urban Containment Policy Area”.  

Objective 1.2 of the RGS is titled “Protect the Integrity of Rural Communities”.  It reinforces the need to “ensure that they remain strongly rooted in the agricultural and resource land base, and allow the rural countryside and natural landscape to remain a durable fact of life in the Capital Region”.  The clearly expressed intention is to prevent lands designated as Rural/Rural Residential from becoming future urban areas. 

We have already seen in North Saanich that increases in density and more diversified housing options will not achieve affordable housing.  Our experiences with the prices in the Canora Mews, Eaglehurst and Regatta make it glaringly obvious that lot size decreases do not result in affordability. 

North Saanich has made extensive efforts in the past decade to increase housing options, with literally thousands of possible secondary suites and guest cottages.  In addition Areas 1 & 2 are zoned to provide 100% affordable units for new builds or subdivisions. 

The current RGS emphasizes new regional priorities for agriculture and food security, reflecting overwhelming public responses during the work done on the Regional Sustainability Strategy.   Food security and production were the top regional concerns in extensive surveys done by the CRD.  Section 6.1 of the RGS confirms the pressing need to foster resilient food and agriculture systems.  

For North Saanich, our future efforts must focus on protection and enhancement of our food and farmlands.  The principles in RGS Section. 6.1 stress avoiding urban/agricultural land use conflicts, enhancing food security and expanding food system economic opportunities.  We need to work toward our own resiliency in the face of unpredictable climate, increased pest resistance, and declining, increasingly expensive water and energy supplies.  Our major efforts need to be toward increasing food production on our lands. 

The sections in this discussion paper on Trends and Challenges, and Opportunities, generally ignore efforts already well underway in the District and offer no constructive suggestions for future efforts.  

Examples of ‘liveability’ progress already made in North Saanich include creating 12 acres of new commercial zoning in 2017, working steadily with BC Transit for the past couple of decades, accommodating three childcare locations and welcoming more, providing the land for a tri-municipal recreation centre, encouraging three popular and expanding farm market/winery/brewery/

bakery/restaurants as well as other more conventional restaurants, at least one of which is world class.  The trail system in North Saanich is second to none in the region, enhanced by the lengthy accessible Flight Path around the airport.  The list goes on. 

In summary, the term ‘complete communities’ in the RGS specifically applies to urban communities and urban containment.  It is misleading and inappropriate to use the term as a heading for a discussion paper in North Saanich.  

The RGS explicitly emphasizes the distinctive nature of rural communities and the need to protect and preserve the rural/agricultural land from the pressures of urban encroachment.   Historically, the cornerstone vision of our OCP to “Retain the present rural, agricultural and marine character of the community” has continuing and consistent broad support from our residents and should guide this OCP review. 

Alice Finall

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The RGS by the Numbers 

So That's What It Really Means! 

Introduction 

            The Regional Growth Strategy is a foundation document for municipalities within the CRD.  Prompted by an earlier period of poorly regulated and poorly planned growth, it now provides a responsible blueprint for planning.  Based upon demonstrated best practices, it distinguishes and separates growth areas from regions of rural and agricultural values.  The definitions and mapped extent of each of the two zones are very clear; compliance with the RGS is not optional. 

            Perhaps the most important policy in the document is the requirement that a minimum of 95% of urban development be within the Urban Containment Policy Area.  The remaining maximum 5% of growth can be within the non-UCPA or rural area.  The DNS is wholly within the Rural area. 

            This report explores the statistical ramifications of the RGS requirements under conditions of forecasted growth and actual growth in recent times.

Summary 

            Utilizing data from Statistics Canada and the CRD RGS Indicator Report, various metrics can be derived that characterize the actual and expected population growth until 2038. 

            Some key findings are below; more are in the following report: 

§  North Saanich's contribution to the CRD is not in housing and commercial endeavours but in agriculture, food security, marine and rural values.

§  In the CRD, the projected population increase is 4320 per year through 2038, from 2016 to 2021 it was 5770 per year

§  North Saanich has 13.6% of the rural land in the CRD

§  North Saanich's share of the projected rural population increase of 216 people per year is 29 based on its share of the rural land (all of the District is outside the UCPA)

§  Actual annual population growth in North Saanich has been 197 people, 2016-2021, well over the RGS maximum of 29.

§  This growth rate is at odds with the RGS intent and could undermine the role of North Saanich within the CRD.

§  The current emphasis in the OCP Review on urbanization is not at all supported by the RGS, especially in view of the recent excess growth through 2021.

§  The Project Team should be directed to align their efforts with the Regional Growth Strategy as it applies to our municipality.

The following sections provide the background detail which underlies the points on this page. 

Background 

            The Regional Growth Strategy is an underappreciated document that basically provides a foundation and guardrails under and around our OCP.  It is a contract among the CRD members; following it is not optional.

            The bedrock of the RGS is the Urban Containment Policy Area.  It effectively divides the CRD into two zones - the UCPA which is to be the focus for commerce and urbanization and all other areas outside of it which specifically have a rural and agricultural focus.  There is extensive language in the RGS document specifying the appropriate activities for each zone.

            The language defining the UCPA and the policies both within it and outside are very clear.  North Saanich is entirely in the area outside the UCPA, i.e., Rural/Agricultural.

Historically, there have been problems managing and directing growth within the CRD; this current RGS is a good attempt at managing growth regionally and erecting guardrails where local councils might attempt to unreasonably urbanize their patch.  The other side of this guidance, and becoming ever more important in the face of climate change and population growth pressures, is the protection afforded to the rural assets such as efficient agriculture and other rural values so highly regarded by the urban population.  Food security alone is a very good reason to strictly embrace the RGS guidance.

The implications of the RGS to each municipality are not immediately obvious.  Although it is fairly well known that a maximum of 5% of housing growth is to be directed outside of the UCPA, i.e., North Saanich and other rural areas, the numerical expressions of that guidance are rarely brought forward.  This document attempts to make clear what the RGS guidance means to North Saanich in real numbers.  Throughout the OCP Review there has been very little explanation of what the RGS is and how it specifically relates to planning in our District.  The end result has left the impression that it is one of many planning tools that may be embraced or ignored as convenient.  On the contrary, it is an important contract with all of our partner municipalities and must be respected as a fundamental tool in the OCP planning process.

The RGS and Growth Projections, 2018 - 2038 

            To understand what it means to our District, we must apply the RGS growth constraints to the population projections for the different land area designations throughout the CRD. In analyzing and portraying the metrics underlying the RGS it is important to bear in mind some assumptions on which they rest:

1. Within the RGS are two distinct and well defined zones:
1. The Urban Containment Policy Area.  The smaller of the two zones it is intended as the focus for commercial and residential activity.  It is intended to receive a minimum of 95% of the residential growth within the CRD.
2. The area outside the UCPA.  This area is quite large and is intended to only accommodate a maximum of 5% of the regional growth
2. The RGS Indicator Report for 2021 projects a population increase within the CRD of 86,400 2018 to 2038.  This amounts to 4320 people per year.
3. A maximum of 5% or 216 people of that total are to settle in the non-UCPA or rural sections of the Region per year.  The remaining 4104 should locate within the UCPA.
4. For those municipalities that have Rural land (non-UCPA), allocating to each their share of the 5% (216 people) can be done pro rata based on each municipality's share of the total non-UCPA (rural) acreage in the CRD.  For North Saanich, that pro rata share of the 216 people is 29.
5. Similarly, the urban growth can be likewise allocated using the relative sizes of the UCPA acreages applied against the 95% population increase total per year.
6. Statistics Canada summarizes the population changes from 2016 to 2021

            The upshot of this analysis can be seen in Table 1, above.  From it we can learn about the relative sizes of the urban and non-urban areas and how those contrasts can influence settlement patterns within the CRD.  The accompanying pie charts bring out several important relationships.

This chart to the right [below] of the Urban or UCPA acreages reveals that about 50% of the urban designated lands are within Saanich and Langford.  Sooke, Victoria and Colwood add another 30%.  Together, Sidney, View Royal and Esquimalt account for only about 9% of the urban lands while Metchosin, North Saanich and the Highlands have none.  Therefore, those municipalities are expected to emphasize rural and agricultural values in their OCP planning.

             The second chart, Rural Acreages, shows that Metchosin, Saanich and North Saanich contain over 50% of the rural lands in the CRD.  Sooke and Central Saanich account for a further 25%.  These lands and the others in this category are intended to attract only 5% of the population growth while emphasizing rural values, food security, etc.  While the Highlands contain 12% of the rural acreage, almost none of it is agricultural.

  

 

            This third pie chart depicts annual population growth in both the Urban and Rural RGS zones combined.  It shows the net effect of allocating 95% of the population growth to the urban areas while directing the remaining 5% to the rural areas on a pro rata basis by acreage. 

            Thus, Saanich, Langford, Sooke, Victoria and Colwood are intended to house 75% of all anticipated growth through 2038.

            North Saanich, having no land designated as urban, is allocated 29 people per year as determined by its relatively small rural acreage and the 5% maximum growth constraint.

Highlands and Metchosin also receive only small population increases, thus reducing pressure upon the rural values in those areas while also reducing urban sprawl, automobile dependency and inefficient use of infrastructure, etc.

            Sidney, view Royal and Esquimalt accommodate a relatively small proportion of the population increase, as their urban acreages are small.

            Some residents may view these population growth targets as unreasonably large or small depending upon their attitude towards population growth and housing.  But, they're the result of broadly accepted, modern planning principles and the recognition of the failure of less formal guidance in the past. 

The RGS and Actual Growth, 2016 – 2021 

 

 

 

 

Statistics Canada has now published census figures for our area.  A tally of key metrics follows in Table 2 on the following page.

	Table 2: this table summarizes key metrics covering both actual and projected population figures.

 

 

 

Actual annual growth in the CRD in the five years until 2021 was 34% greater than the estimate from 2018 until 2038.  In North Saanich it was 572% greater than forecast.  

Comment 

This apparent growth pressure could put at risk the protection of the District's rural and agricultural values.  While it may not be possible to directly limit population inflow, there certainly is no demonstrated need to encourage housing growth beyond the constraints applicable to rural lands.  Furthermore, several municipalities with abundant urban-designated land have room to increase their urban settlement levels - recall that the urban settlement level of 95% is a minimum figure.

This is simply managed by strict application of the principles and policies of the Regional Growth Strategy. 

            History indicates that rural and agricultural assets tend to be under protected in jurisdictions where land management is unregulated.  As a land use, development and housing often predominate as there are significant financial rewards for development advocacy and for "growing" houses.  Advocates for growing food and retaining natural areas traditionally are motivated by community values rather than financial rewards.  Put another way, agricultural and natural assets require public support as our economic system does not provide that naturally.  North Saanich is significantly falling short in this aspect of the OCP Review.

            The RGS provides a well-founded system to manage both commercial and non-commercial land uses so as citizens, our responsibility is to ensure that our governments maintain a balance among competing lobbyists and that ultimately there is compliance with the RGS.

We must remember that North Saanich does "contribute its share" to the CRD resource spectrum, it is just in values other than housing.  The OCP Review to date has been highly deficient in recognizing and managing our assets according to the clear direction given in the RGS.

Council has an obvious obligation to ensure that the Project Team does not stray from the guidance provided by the Regional Growth Strategy.  Will Council explain to the residents how it is upholding that obligation? 

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March 19, 2021
 
Dear Carly and Mayor and Council,
 
RE: Further issues regarding Emerging Themes discussion papers
 
Thank you, Carly, for your reply of March 10, 2021, addressing my letter to Mayor and Council of February 28, 2021.
 
In response to your third paragraph, I am pleased to confirm that I have read all of the discussion papers several times.  I also attended all of the Web Panel presentations.  The discussion papers do refer to terms in the current Official Community Plan (OCP) and the Regional Growth Strategy (RGS), and there is some overlap among the topics in the papers.  They do not provide a holistic or high level view addressing the concerns I presented in my letter of February 28.
 
Nowhere, collectively or individually, is there a reference to protection of rural communities in these discussion papers.  This is one of the main objectives of the RGS.  It needs to be the overarching principle guiding the priorities of our OCP review.  It is separate from, but supported by, the agricultural resource lands provisions referenced in my letter of February 28.
 
The focus of the 2018 RGS is long term planning and regional outlook, which accords with our OCP review outlook.  For North Saanich to align its Regional Context Statement (RCS) with respect to Areas 1 and 2 will require rescinding the sections of Bylaw 1352 that created these anomalous uses.  The objective for protection of rural communities in the 2018 RGS mitigates against retention of such urban zoning in North Saanich. 
 
These areas were legislated while the RGS was in a transitional stage.  They were not aspirations of the community; they were vigorously opposed by many residents.  The council members that supported them were all defeated at the next election.  As you state, they are not consistent nor in accord with our RGS Rural/Rural Residential land use designation.
 
Regarding Affordable Housing policies, in general truly affordable housing requires complete subsidization.  Local government cannot provide this but it may be available from federal or provincial sources under current conditions.
There are non-profit organizations that successfully create ongoing affordable housing.  Habitat for Humanity is one example. 
    
Combining a small number of affordable units with a large number of market units, by providing extensive upzoning to allow this, does not benefit a rural, agricultural municipality.  It also does not realistically address affordability needs.
 
With the updated RGS to guide this OCP review, the long term challenge for North Saanich is to preserve this as a Rural/Rural Residential community,
 
Regarding your explanation of planning terms, in my extensive experience such terms as gentle densification, sustainable development, complete communities, local area planning, affordable housing and needed infill are often used to justify urban density levels, which in rural agricultural areas translates into urban sprawl.
 
Yours truly,
 
 
Alice Finall