Correspondence (e): Letter from Dr. Cameron Harris
Detailed opposition from an adjacent business owner citing parking deficiencies and the feasibility of another medical clinic.
Re: Zoning Application for 258 Island Highway
Dear Mayor and Council,
I am writing to provide my perspective as both a community member and adjacent business owner regarding the proposed zoning changes for 258 Island Highway.
I would like to begin by acknowledging the considerable risks undertaken by developers, particularly in the current economic climate. These projects demand significant long-term investment and are vulnerable to changing conditions. I recognize these challenges, and they are part of what prompted me to submit this letter.
Relevant Facts
- Commercial lease area: 6,239 sq ft (579.62 m²).
- Market/grocer parking requirement: 1 space per 25 m².
- Required commercial parking under current zoning: 23 stalls.
- Commercial parking provided: 29 stalls (9 underground).
- Required residential parking: 74 stalls.
- Residential parking provided: 75 stalls.
- Parking regulations referenced from pages 41–42 of the Town’s zoning bylaw.
1. Parking Deficiencies Resulting From Rezoning
A change in use will alter parking requirements and, in most scenarios, create a parking deficit under View Royal’s parking bylaws.
Example scenario presented by the developer (½ café, ½ medical clinic):
- Café: 289 m² ÷ 15 = 19.3 stalls
- Medical office: 289 m² ÷ 20 = 14.5 stalls
- Total required: 33 stalls, exceeding the 29 provided.
Even reducing the café component to one-third of the space results in insufficient parking (31 stalls). Residential redistribution is not feasible, as only one surplus residential stall exists.
Most viable commercial uses—including café, clinic, restaurant, and health services—require more parking than a market. Only office use is comparable. Rezoning therefore significantly limits bylaw-compliant uses and may force reliance on variances.
Further, approximately 30% of commercial parking is underground without direct unit access. For medically compromised patients, this is impractical.
As the owner of two adjacent properties (Stewart and Helmcken), I experienced repeated misuse of my private parking during the construction of 258 Island Hwy, with 7–10 contractor vehicles parked daily in both lots and, at times, aggressive confrontations. Overflow caused significant disruption to my business. A zoning change that increases parking pressure risks repeating this pattern.
2. Subdividing the Commercial Space Is Effectively Permanent
Once a large commercial unit is subdivided, it is rarely reassembled. Tenants invest heavily in leasehold improvements and typically sign 10- to 15-year leases to secure that investment.
Given Fort Victoria’s indication that it does not intend to become the new town centre, large commercial spaces in View Royal are increasingly limited and should be preserved.
3. Physician Shortages Undermine the Feasibility of a New Medical Clinic
The physician shortage stems from systemic issues—fee-for-service models, administrative burden, burnout, and the inability to sell private practices—not from a lack of clinic space. Unless a physician is opening a new practice or accepting View Royal residents, a clinic at this location offers minimal community benefit but still increases traffic and parking demand.
My own experience leasing Stewart supports this. After renovating the space for medical use and listing it below market, not a single physician inquired over four months. The issue is a shortage of physicians, not a shortage of lease space.
4. Need for Additional Information Before Making a Permanent Decision
Before considering rezoning, I respectfully request Council obtain and review:
- Correspondence from prospective market tenants explaining why the space was deemed non-viable.
- Evidence that reduced lease rates or incentives were offered, given the developer’s statement that they were willing to provide “years of free rent.”
- Correspondence from prospective tenants interested in alternate uses, including potential physicians.
A zoning change of this scale should be supported by clear evidence that all reasonable efforts were made to secure the originally intended use.
5. Precedent Concerns
Approving a significant zoning change without full due diligence may set a precedent encouraging future developers to negotiate commitments they later choose not to fulfill. While economic conditions can evolve, the Town has a responsibility to verify that all reasonable options have been exhausted before altering a negotiated community benefit.
Final Position
The space was purpose-built for a market, and most alternative uses—café, medical, restaurant—carry higher parking requirements that the site cannot meet. For these reasons, I do not support rezoning.
If Council ultimately approves a change, the community should receive a use of equal public value: small markets, take-away food services, or another walkable, low-impact use. Although parking bylaw compliance may be challenging, these uses would function similarly to 264 Island Highway, where multiple businesses operate with fewer than 29 stalls.
If a medical use is considered it should be limited to physician services only (otherwise other medical related practices will fill the space) and occupy only a small portion of the footprint to minimize parking impacts.
Thank you for your consideration.
Sincerely,
Dr. Cameron Harris View Royal, BC