CORRESPONDENCE: Concerns about CMHC Housing Accelerator Fund Program

291 View Royal Ave. Victoria BC, V9B 1B1

May 16th, 2023

Mayor and Council Town of View Royal 45 View Royal Ave. Victoria BC, V9B 1A6

Dear Mayor and Council:

This letter expresses my initial concerns about the proposed application for the Canadian Mortgage and Housing Corporation’s Housing Accelerator Fund Program that is included in the May 6th Town Council meeting agenda. Due to a short lead time on what is a complex issue these are preliminary comments.

Acceptance in this CMHC program requires the town to increase the growth rate by a minimum of 10%. Additional points towards having the application accepted are given if the goal of a 20% increase is promised.

• During the five years from 2016 to 2021 View Royal increased the number of dwellings in town by 20.5% to 5175 dwellings according to the Canada Census.
• The Housing Supply Update Report delivered to council on May 8th shows 901 new units of housing are under construction or nearing the construction phase. There are development applications in progress for another 162 units. There are rezoning applications for a further 464 units. The total is 1527 new units, a 29.5% increase over the 2021 census figure.
• This does not include all of the construction completed since the April 2021 census date. Unfortunately, the Building Permit Listing reports on the View Royal website contain far to many errors to provide an accurate statement about the number of completions.

These numbers make we wonder exactly what are we needing to accelerate?

I also want to address two of the initiatives that are being proposed to support the application for this program. Beyond the requirement to increase development by at least 10% the CMHC program requires municipal applicants to identify seven initiatives they will implement to help ensure the municipality will achieve an (undefined) appropriate density. The applicant can pick the initiatives from a list of 25 initiatives supplied by CMHC in the program documentation. Some are quite innocuous but two of the seven initiatives chosen for View Royal demand mention in these preliminary comments.

The first initiative I ask you to consider is this:

i. promoting high-density development without the need for rezoning (as-of-right zoning), e.g., for housing developments up to 10 storeys that are in proximity (within 1.5km) of rapid transit stations (i.e. Atkins Road and Helmcken Road) and reducing car dependency;

This initiative seeks to remove any right for citizens to have a voice in the development approval of virtually every property on View Royal. It is a proposal bootstrapped by describing two single bus stops on a single bus route “rapid transit stations”. The following two maps show the portion of View Royal where rezoning for any development up to ten stories will no longer allow residents to comment. The first map shows the portion of View Royal where development is allowed within the CRD Urban Containment Boundary: the two red stars show the rapid transit station locations.

The blacked out areas in the second map shows the areas withing 1.5km of the transit stations where public hearings on all rezoning proposals will no longer be required.

As the reader can see, a hand full of properties along View Royal Ave and the properties in the Aldersmith/Hallowell areas are the only properties not affected by this proposal to eliminate all citizen rights to speak out on the rezoning approval process. The overreach is stunning.

The second proposed initiative that should also concern all residents of View Royal is this:

vii. implementing changes to decision making such as delegating development approval authority to municipal staff based on established thresholds and parameters.

This initiative seeks to strip the town council of the responsibility for development approvals. When combined with the first initiative this would give municipal staff nearly unfettered authority to implement any and all development with no input from citizens or our elected council. It is worth noting that, out of the 25 initiatives listed in the CMHC application document, these two initiatives are the ones that do the most to remove all public and council oversight of development.

There are large amounts of money being dangled by CMHC to encourage relentless high-density growth in View Royal. Further increasing the extraordinary growth rate of View Royal, removing all zoning restrictions, removing every chance for citizens to have a voice in the development of the town and cutting town council out of the approval process is far too high a price to pay for the returns this program offers.

Yours,

Doug Wilson