Correspondence from Merdyn Group Holdings Ltd. Re: SSMUH Bylaw Changes

May 21, 2024

Town of View Royal 45 View Royal Avenue, Victoria BC V9B 1A6

Attention: His Worship Mayor Tobias & Members of Council

Subject: Small-Scale Multi-Unit Housing Bylaw Changes

Please accept this letter as support for the Small-Scale Multi-Unit Housing (SSMUH) approach recommended by the View Royal Housing Legislation Standing Committee (Standing Committee), and supported by Members of Council at the May 14, 2024, Committee of the Whole meeting.

The approach recommended by the Standing Committee provides considerable flexibility and should provide the framework for the creation of housing that is not currently highlighted in the housing industry, including the small-scale multi-family apartment, otherwise known as a “House-Plex”. A House-Plex can be created from four to six dwelling units and there are many examples within Greater Victoria, and it is often difficult to differentiate between a single-family dwelling and a House-Plex.

In reviewing the Standing Committee report we considered the proposed zoning particulars on the feasibility of creating House-Plex housing. We respectfully offer the following comments and suggestions to improve the proposed bylaw changes.

The proposed zoning amendment includes both a maximum building floor area and a maximum dwelling unit floor area. These restrictions in themselves are not an issue, however in multi-family buildings, including a House-Plex, there is building floor area that is required to service the building and service the needs of the residents in the building. Examples of building floor area for use outside of the dwelling unit includes utility closets, utility rooms, bike storage areas, storage lockers, maintenance closets, shared entry areas, corridors, entry and exit stairwells, and shared amenity spaces.

The current View Royal Zoning Bylaw does not provide exclusions for building floor area that is not specific to building floor area dedicated to dwelling units. The maximum building area proposed does not seem to recognize or allow for building floor area for utility needs or common areas, therefore causing building floor area to be deducted from the dwelling unit floor areas.

It is important to ensure that the dwelling unit sizes are such that the dwelling units remain functional and allow for long term tenure, and the maximum floor area of 93 m² provides adequate floor area, however if building floor area is required to be deducted from the 93 m² for common areas and amenities the net dwelling unit sizes will become less functional and more challenging to meet housing needs.

The average multi-family building requires approximately 17-20% buildable floor area that is exclusive of floor area dedicated to dwelling units.

We respectfully suggest that the proposed zoning bylaw allow for building floor area needs outside of the dwelling unit building floor areas, and we further suggest that this can be accomplished in different ways, including;

1. Option A: Increase maximum building floor area and retain dwelling unit floor area maximum area. We would suggest adding 20% to the maximum building area. As an example this would add 74 m² of additional floor area for the SSPKG B2 & B3 categories, for a total building floor area maximum of 446 m².
2. Option B: Leave as the maximum building floor area as proposed however exclude from the definition and calculation of building floor area the “common areas”, including utility closets, utility rooms, bike storage areas, storage lockers, maintenance closets, trash enclosures, shared entry areas, corridors, entry and exit stairwells, and shared amenity spaces.

Thank you for the opportunity to provide input and suggestions on the Small-Scale Multi-Unit Housing bylaw changes.

Regards,

Wayne Hopkins Merdyn Development Group