Letter dated October 21, 2025 from D. Wilson, Re: Application for Variances at 157 View Royal Avenue
A letter from Doug Wilson opposing the variances at 157 View Royal Avenue, arguing that the staff report misinterprets zoning bylaws and creates a concerning precedent.
Mayor and Council,
The staff report supporting the application for variances at 157 View Royal Ave. relies on arguments that, quite simply, do not stand up to scrutiny. I urge Council to reject the application and request a revised report that aligns with both the letter and the intent of the Town of View Royal’s bylaws.
Misinterpretation of Accessory Building Regulations
The zoning bylaw clearly limits the size of accessory buildings, as per section 4.6.6:
“The total lot coverage of all accessory buildings and/or structures on a lot must not exceed 60m² or 10% of the lot area, whichever is smaller.”
Despite this, the staff report incorrectly argues on page 5 that:
“The proposed accessory building lot coverage of 190.1m² would be well below the 10% maximum permitted in the R-1 zone.”
This is misleading. The bylaw does not permit accessory buildings up to 10% of the lot area unless that amount is less than 60m². Therefore, the proposed 190.1m² far exceeds the maximum permitted.
The report repeats this flawed rationale on page 6, stating:
“The proposed accessory building lot coverage of 190.1m² would be well below the requirement of 10% for both the existing lot (1.6%) and the minimum lot area for future subdivision (2.3%).”
Again, this misrepresents the bylaw. Professional planning staff should rely on the bylaw’s actual provisions, not a misapplied percentage.
Misrepresentation of Density in the R-1 Zone
On page 6, the report states:
“The requested variance would comply with the maximum density of 0.42:1 floor space ratio.”
It goes on to claim:
“The proposal does not exceed the maximum density provisions of the accessory building regulations and the R-1 zone.”
This mischaracterizes the purpose of the floor space ratio (FSR) and density regulations. The R-1 Zone permits a maximum floor space of 372m². The 0.42 FSR only becomes a limiting factor on smaller lots—those under 885m². The staff report uses this ratio to justify building sizes above the stated maximum, which is a misuse of the intent behind the FSR provision. The intent is to scale down development on small lots, not to allow increased density on large ones.
Inappropriate Use of Environmental Policy (Greenwashing)
On page 8, the report states that the proposal aligns with the Official Community Plan, citing Policy NE1.7:
“Maintain a healthy forest by encouraging the retention of trees.”
This is an example of greenwashing. The proposed development is on land that contains no trees. As such, claiming alignment with a policy intended to protect existing tree cover is both misleading and inappropriate for an official staff document.
Concerning Precedent
Lastly, Council should consider the precedent this decision would set. If a variance is granted to allow multiple accessory buildings grossing more than three times the permitted size, similar requests from other property owners will be difficult to deny. For perspective, the proposed 190m² (2045 ft²) of accessory buildings is also three times the average allowable size for a Garden Suite in View Royal.
Council has, in the past, rightly rejected applications that sought only to exceed maximum build constraints. That consistent approach upholds the integrity of the zoning bylaw and should be maintained.
Sincerely, Doug Wilson View Royal Avenue