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Misconceptions about misconceptions

On July 5, the District released a Staff Report outlining the OCP review process so far. Attached to that report is a 7-page document, titled "Response to Misconceptions". Unfortunately, this response perpetuated a few significant misconceptions of its own. Here is the point-by-point breakdown.

"Misconception" #1

The District is currently rezoning your land

Right indeed, the District is not currently rezoning your land. But the fact is that the OCP is the “Master Bylaw” of any municipality. This means that, after a new OCP is passed, all bylaws in the municipality will eventually come to conform with the OCP. This includes the zoning bylaw.

Practically speaking, it is quite obviously impossible to build what has been proposed by the Project Team without rezoning. How could we put “townhouse density” in Deep Cove without changing the current single-family zoning? How could we put duplexes, triplexes and “cluster housing” in the Terraces without changing the current single-family zoning? How can we put “Senior’s Housing” at Panorama Recreation Centre without changing the current public assembly zoning?

If you are a property owner in an area labelled for development under the OCP and you don't want to rezone, you don't have to rezone! But if your neighbour sells next door, and the developer who buys it wants to build the density allowed in the OCP, then it's a done deal and you're living next door to "the future".

So no, the District is not rezoning your land......yet.

"Misconception" #2

The District is expropriating land for development

Apparently, the Project Team has heard that some people in the District mistakenly believe that their properties will be expropriated if this plan proceeds. They didn’t hear this on SaveNorthSaanich, because it’s not true. But it's understandable that residents might be alarmed when they see a line on a map that points directly at their property and envisions a “higher density apartment building” or “townhouse density”.

We haven’t heard of any plan to expropriate anything. Happily, this misconception really is a misconception.

"Misconception" #3

The District is removing land from the ALR

for residential and commercial uses

Many residents viewing the maps created by the Project Team are under the impression that the plan supports commercial and residential uses of ALR land. Perhaps that's because, on the maps created by the Project Team, these uses are explicitly proposed on ALR land.

For example, residents think that there is a plan to put a commercial "neighbourhood nook" at Ardmore Golf Course because the materials from the Project Team explicitly list "Ardmore Golf Course" as a location for a neighbourhood nook. Residents think that there is a plan to put an "agricultural village" housing development on ALR land on McTavish Road because the Project Team materials indicate an "agricultural village" housing development on farmland on McTavish Road.

These are not misconceptions, these are examples of people correctly reading what they have been given.

Misconception #4

We do not have to provide any new housing

The Project Team is particularly emphatic about this one, claiming: "We are required by law to meet the housing needs of our community". And, if you wanted to read a single line of legislation and leave it at that, you could be forgiven for believing this is the case. This is a complicated topic and, with our apologies, the next few paragraphs are going to be unbearably boring.

The Local Government Act says that municipalities must include "statements and map designations" regarding the "approximate location, amount, type and density of residential development required to meet anticipated housing needs over a period of at least 5 years". But what does that mean in practice?

The truth is that what we are "required by law" to do is - correctly - subject to a very wide interpretation, as other rural municipalities throughout BC have repeatedly demonstrated. The consistent position in Metchosin, for instance, is that there is more than enough capacity in the OCP as it is currently written. This capacity takes the form of lots that are eligible for subdivision or additional housing options (ie secondary suites), whether this capacity has been built out or not. The same logic is applicable in North Saanich.

And wouldn't you know it: there is a document that addresses the exact question of current capacity. It is an inventory of "zoning capacity", created by a sub-consultant, which lists exactly how many units of housing would be available if the density allowable under the current OCP was fully built out.

One would think that this would be an excellent starting place when assessing whether or not the current OCP has sufficient housing for the next five years, but this very useful document is not yet available for review. It is complete enough to be circulated around staff, as noted by the Director of Planning at a Council meeting last month, but a SNS member asked to see a copy recently and was told it will not be ready for review until the end of summer, at the earliest. Why are we spending all these thousands of dollars on fancy maps to address "anticipated housing need" when we don't even know what our current capacity for housing is? The cart is a mile and a half in front of the horse.

And then there's the data we do have. The highly-problematic Housing Needs Assessment Report ("HNAR") is the cornerstone of the current "anticipated growth" projections. Readers may recall that this report involved interviews with a tiny handful of five industry stakeholders, including Urban Development Institute and the Victoria Residential Builders Association, and absolutely no engagement with residents of North Saanich.

In other municipalities, extensive public consultation has been undertaken in establishing the housing needs of the community. In North Saanich, the consultants didn't feel the need to speak to any residents at all. How can the needs of a community be assessed without speaking to a single member of that community? This glaring deficiency was pointed out to Council by several letter-writers back in January, but Council accepted the report as-is. Of course, Council can be much more rigorous in the data they choose to rely on, but so far they've accepted what they've been given.

The HNAR also observed that "NIMBY-ism was reported to be especially strong on the Peninsula, where many wealthy homeowners who are comfortable in their housing situation and wish to maintain the rural feel, oppose some denser forms of housing". That's right folks, according to the officially-adopted Housing Needs Assessement Report, we're just rich and selfish. But maybe we shouldn't be surprised that this is the input that is recorded when the majority of the "local stakeholders" interviewed were development industry lobbyists.

Finally, the recently-released HNAR is based on 2016 census data, despite the fact that updated 2021 data will be available in a matter of months.

So, what have we got: Old data, financially-motivated stakeholders, no resident input. This is the basis for the "housing needs" that are being thrust upon this municipality, and form the basis of the "anticipated housing needs" which we are "required by law" to accommodate.

Which brings us back to the "misconception". The only way that it is a "misconception" to say that we don't need to build any more housing in North Saanich is if:

  • you accept that we should plan for future housing needs without bothering to first assess the current untapped housing potential in North Saanich,

  • you accept that these housing needs should be determined in part by talking to a tiny group of stakeholders, two of whom are the Urban Development Institute and the Victoria Residential Builders Association,

  • you accept that there should be no resident input in determining the housing needs of our municipality, and

  • you accept that housing needs should be determined using five year-old data when brand new data will be available in a few short months.

(We told you this was going to be unbearable.)

It is our position that North Saanich currently has adequate housing to fulfill the needs of this community for the next five years and beyond, and that the Housing Needs Assessment Report is fatally flawed. We urge readers to press Council on these points.

"Misconception" #5

The Regional Growth Strategy states that

the District will not address external needs for housing

Here's another one that has caused grave concerns for the Project Team. The Regional Growth Strategy ("RGS") is an umbrella planning document that covers the entire CRD. It is the document that creates the Urban Containment Boundary (you may recall reading about that elsewhere on this webpage: Drive-thru restaurants and condos are on one side of the UCB, wide open spaces and fresh air are on the other).

The RGS is also the document that says that all of North Saanich is a rural/rural residential zone. Such zones are "not intended to become future urban areas requiring extensive services. Residential uses are of a form, density and character that support rural working landscapes." (Page 13 of the link above.)

The RGS also caps development in places like North Saanich:

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

(Page 21 of the link above.)

What is the staff response to the assertion that we don't need to build any housing? A stern rebuke of our Grade 1 numbers comprehension:

"No more than 5%", staff writes, "is not zero".

To which we point out, though it seems fairly obvious: growth of 0% would be entirely in keeping with North Saanich's role in the RGS. As they say, 5% is not zero. But 5% is the prescribed maximum for all of the rural/residential policy areas combined, including Metchosin, most of Sooke, and large swaths of Central Saanich and Saanich, among other areas. There is no minimum. Growth of 0% in North Saanich is entirely allowable.

But wait! When the RGS was introduced in 2018, the so-called "Area 1" (McTavish/East Saanich area) and "Area 2" (the Tsehum Harbour area) were recent zoning creations, and still in legislative limbo. As a result, they are not designated as rural/rural residential....they are not designated as anything at all. The Project Team has pounced on this anomaly, using the missing designation as an opportunity to extend the Urban Containment Boundary into North Saanich.

You may have heard about a form email circulating from two Councillors, that says there is no proposal to move the Urban Containment Boundary. If those Councillors are going to vote that way, that's great! But moving the urban containment boundary is definitely an option that Council has asked staff to explore. Here is a question-and-answer from a North Saanich Residents Association event in February:

Question: I have heard that the OCP review will be considering whether to extend the Urban Containment Boundary to include parts of North Saanich. Please answer yes or no, is this true?

Staff response: Yes, the OCP review will consider if the urban containment policy area boundary should be extended to include parts of North Saanich. Specifically, the OCP review will consider whether Area 1 (McTavish) and Area 2 (Tsehum) should be considered for inclusion. The District’s current OCP and the Regional Context Statement in Section 16.1.6 acknowledges that Area 1 (McTavish) and Area 2 (Tsehum) are ‘outside of the RGS’ (Map 3a: Growth Management Concept Plan of the RGS) as these areas were still under policy development during the completion and adoption of the RGS in 2018. Council have directed staff to undertake a full review of the OCP including, specifically including reviewing the boundaries of Area 1 (McTavish) and Area 2 (Tsehum).

(You can even read this on the District's own website, if you'd like! It's right here.)

So yes, part of the present OCP review will involve deciding whether we want to extend the Urban Containment Boundary into North Saanich. And so we need to decide: do we want to invite the drive-thrus and the condos into the rural/rural residential municipality of North Saanich? Do we want apartment buildings and dry cleaners and offices and parking lots? We know what we think. Let Council know what you think.

To wrap it up: does North Saanich need to provide any additional housing under the RGS? Nope. But if we invite the Urban Containment Boundary in, we certainly will.

"Misconception #6

Developers initiated the OCP review process

and are leading it and controlling it.

Oh for goodness' sake. Of course developers didn't initiate the OCP process. Of course they aren't leading it.

But are they involved? Are they stakeholders, just like you and I? You bet they are.

In the "Response to Misconceptions", staff explains that developers were not particularly involved in OCP design workshop. And they weren't! They were invited, sure. But they didn't show up. Because really, why would they feel the need to be involved in the OCP design workshop, when they were consulted - to the exclusion of residents - in the Housing Needs Assessment Report? The report that sets up the entire "housing need" that the OCP is supposed to address?

The Victoria Residential Builders Association and Urban Development Institute were two of the five "local stakeholders" consulted in the development that report, which establishes the baseline for "housing need" - the need that staff say we are "required by law" to address. The other stakeholders were the Victoria Airport Authority (which does not hide its development aspirations), Habitat for Humanity Central Saanich and South Vancouver Island Housing Society. Why on earth would the development community trouble themselves with attending a design charette, when they were already involved in the creation of the report that the entire thing rests upon? Why give a hoot about what colour the paint is when you got to help build the entire house?

Staff says that "Developers, both big and small, have built the homes we live in and play a key role in building the communities we live in". Yes, indeed. And they are paid handsomely for that work. And, like any other corporate entity created to turn a profit, they will make as much money as they can, which means creating as many lots as they can, to build as many units as much as they can. This is not a bad thing, or somehow morally objectionable: this is what businesses do.

The objectionable part comes when municipalities suggest that planning cannot be achieved without consulting with outside commercial interests, or when Councils fail to protect the municipalities they are charged with stewarding from incessant development pressure.

Most members of Council are on the record insisting that developers are stakeholders.

So, are developers driving the OCP review process? Why would they? They already had their say, and now the OCP review is shepherded by a Project Team with a decidedly development-minded view. Developers don't need to drive the bus - they built the road.

"Misconception" #7

There is mass participation in surveys

and other engagement activities from non-residents.

The Project Team calls this a misconception.

Here is a list of all of the “stakeholders” who are being engaged over the course of this OCP review:

• residents, business owners, property owners, renters, local First Nations including the Tseycum, Tsartlip, Tsawout, Pauquachin and Malahat Nations

• community organizations

• institutional stakeholders

• agencies and Ministries from other levels of government

• community organizations

• developers

• “all others who live, work and play in the District”

• people who frequent businesses and amenities in North Saanich

• “future residents”

• neighbouring communities

The above wording is taken directly from the District’s ConnectNorthSaanich website.

As well, in creating the Housing Needs Assessment Report (the document upon which the Project Team is relying to justify all the density they are proposing), the following groups were consulted, on either a “regional” basis or a “local” basis:

• Community Social Planning Council

• CRD Electoral Area Director

• Cool Aid Society

• Coalition to End Homelessness

• BC Housing

• Greater Victoria Housing Society

• Pacifica Housing

• Urban Development Institute

• Aboriginal Coalition to End Homelessness Society

• Victoria Native Friendship Centre

• M’akola Housing Society

• Habitat for Humanity Central Saanich

• South Vancouver Island Housing Society

• Victoria Airport

• Urban Development Institute Capital Region

• Victoria Residential Builders’ Association

• And not one single resident of North Saanich.

So that's who they're asking. And apparently, the call has been answered. According to the Project Team, there have been no less than 92,480 unique visits* to the OCP review webpage. That is not a typo....but it is more than the entire population of Victoria, and almost eight times the population of North Saanich. Who are these visitors that are so interested in our OCP? Where are they coming from?

Of course, all of the respondents' location data in the engagement thus far (surveys, design charettes, workbooks) has been self-reported, if it has been reported at all.

We will leave it to you to decide whether there may have been some undue input from non-residents.

* "Unique visit" means a visit from a computer, phone or tablet that has not visited the site before.

"Misconception" #8

The OCP is a closed-door and non-transparent process

This is an entirely subjective question. If residents do not feel that they have been heard, or if they object to closed-door meetings to which developers are invited but residents are not, or if they are dissatisfied with the level of in-person engagement during an international pandemic, they are entitled to that opinion.

It is not a "misconception” for a person to say that they do not find a process to be sufficiently transparent or open – it is their opinion and they are entitled to express it to their elected officials without being accused of "misconceiving".

Consider this:

  • The "design charette" workshops involved rapid-fire questions that no one was prepared for and very few attendees were satisfied with, requiring two screens in order to use Menti, a third-party platform that no one had ever used before.

  • No one can assess the objectivity of anything that comes out of the Advisory Working Group, because we have no idea what information was given to that group, what questions were asked, or what responses were received. In Sidney and Central Saanich, AWG meetings are open to the public. Not so in North Saanich.

  • The engagement process works as a filter, and apart from letters addressed directly to Council, the only engagement feedback that makes it through to our elected officials is that which the Project Team chooses. Council has not seen the "raw data".

  • The OCP pop-ups in June were one of the only opportunities to engage directly with the Project Team. Lots of people attended. But the feedback received at those events - which was overwhelmingly negative, from the pictures we've seen - won't be presented to Council until some time in the Fall, because the Planning Department says it is too busy to get to it before then.

  • Workbooks were available to those of us who managed to get together with friends somehow during a time when getting together in person was literally against the law.

  • There are a lot more objectionable elements to the engagement process, but we want to get this post up in time for readers to write in to Council by the deadline (July 7 at noon). So we'll leave it at that for now.

"Misconception" #9

The project team informed the North Saanich Residents Association (NSRA) that the NSRA Housing and Density Survey for the OCP would not be considered, but the Urban Development Institute’s letter would be considered as part of the Phase 2 engagement.

This one is pretty basic. Here's the response to the NSRA's survey from the head of the Planning Department:

"Yes we will consider [the survey responses] but this is the NSRA’s survey and once again the District was not involved in developing the survey questions or endorsed the survey nor did it form part of our is only fair to everyone that we only use input that is gained from engagement activities that the project team has developed with our AWG."

Here's what the Communications Director said about the UDI report, as quoted in the Peninsula News Review (and other news outlets):

“The feedback from the Urban Development Institute will be considered as part of the current phase of engagement”

Council voted to accept both the NSRA Survey and the UDI report.

Do you know anyone on the AWG? If so, you should ask them what sort of work they did to "develop engagement activities". Too bad the meetings are closed to the public.

That's it for our response to the "Response to Misconceptions"

...but we'll address two more while we're here

As we mentioned earlier, a couple of Councillors have drafted a form response that they are sending to residents. We'd like to address a couple of points they raise in their email.

These Councillors assure us that we are at the end of stage two of a five-stage OCP review - the very beginning! The implication is that we should all calm down because it's so early in the game. The problem is, each stage of the review builds on the stage before it. If the foundation of this review is rotten, the result will be as well. The next phase has the Project Team doing a "deeper dive into these emerging concepts". Now is definitely the time to get excited.

These Councillors also say that "targeting the McTavish Neighbourhood to become “the main high-density housing and commercial centre for all of North Saanich” is something that is "NOT being proposed". But the problem is this map, which was created by the Project Team and displayed at the design charette meetings and the pop-up events:

What do you think? "Higher density apt. buildings"? "Low apt. forms"? "Retail/commercial cross roads"? Looks an awful lot like a proposal for McTavish to become the main high-density housing and commercial centre for all of North Saanich, doesn't it?

The staff report released Monday afternoon notes the "emerging concepts" envision "[development of] a Village Centre around three nodes: the McTavish Interchange, McTavish and East Saanich Road, and the Panorama Recreation Centre". (That is on page 6 of the report, but the whole thing is worth a read. Maybe pour a drink first.)

For the record, we don't think any North Saanich Councillors would deliberately mislead anyone. But heaven knows, there sure are a lot of misconceptions floating around these days.



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