1715 Government Street Victoria, BC, V8W 1Z4
Mayor and Council City of Victoria No.1 Centennial Square Victoria, BC, V8W 1P6
June 22, 2018
Re: Zoning Bylaw 2018
Dear Mayor Helps and Council,
The DRA very much appreciated that Council referred the Zoning Bylaw 2017 back to staff for a second time at the COW February 1st, 2018 to respond to ongoing unaddressed concerns brought forward by the DRA.
While the DRA LUC initially discovered several properties that would have been up‐zoned by the new bylaw, we have now been assured by Staff that the bylaw has been amended so that it will now not confer any development rights that were not already in existence.
Other amendments to the previous draft bylaw have resolved concerns regarding:
• The practice of excluding exterior egress hallways from a building’s FSR which incentivized bulky and less energy efficient buildings. The Zoning Bylaw 2018 now includes these areas in the calculation of a building’s FSR; and,
• The Draft 2017 Bylaw proposed a total relaxation of parking requirements throughout Old Town without exception. The Zoning Bylaw 2018 provides a total relaxation of the parking requirements throughout Old Town for only those properties below 1100 m2 in size to incentivize the retention of the small lot form and character of Old Town and the preservation of heritage properties.
Concerns that were not addressed within the draft Zoning Bylaw 2018 are as follows:
• Cash in lieu requirement for any parking variances granted;
• Elimination of legal opportunities to elicit public amenities;
• Allowing uses such as Bars and Pubs as well as brewpubs and distilleries (which are essentially industrial uses) within residential buildings without corresponding regulation to mitigate the inevitable conflict between the uses. Currently there are few requirements/policies for specific mitigation measures to deal with odors from brewing or sound transmission linked to hours of operation;
• No constraints on maximum building size other than the size of a city block. Homogenization of zones facilitates the amalgamation of lots without a rezoning;
• A minimum unit size for downtown residences in support of livability;
• Lack of specific and concrete Design Guidelines that are enforceable and less vulnerable to interpretation; and,
• Maintaining an opaque Development Permit process where Staff interpretations of Design Guideline policy are made in private and shielded from public debate. Any Design Guideline policy that is open to interpretation must also be open to public comment; The DRA recognizes that many of the unaddressed concerns may be more appropriately mitigated through other mechanisms and seek assurances from Council that they indeed be duly considered. We very much appreciate that Council has approved a review and updating of the “Old Town Design Guidelines”, and will also consider the improvement of notification and public engagement for all Development Permit Applications.
We are committed to working with Staff in accordance with the commitments made in the City of Victoria “Engagement Framework” to insure positive results for the Downtown community on these many issues, and trust that Council will support the results.
Sincerely,
Ian Sutherland Chair Land Use Committee Downtown Residents Association cc COV Planning
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