Realstar Management Response to Town of View Royal regarding Christie Point Redevelopment
A comprehensive response letter from the developer addressing environmental, archaeological, transportation, and community feedback concerns.
Environment
- Green Shores: while welcomed, this is not a substitute for meeting the requirements within the Environmental Development Permit Areas within the Town’s Official Community Plan.
The project does not intend for Green Shores to be a substitute for meeting the requirements of the Town of View Royal’s Environmental Development Permit Areas.
As noted on page 18 of the Environmental Overview Assessment for Christie Point by Swell Environmental, the rezoning concept has been designed to assist in preparing the project to meet the guidelines in the later stages of the design process for the two Environmental Development Permit Areas that cover the site: Natural Watercourse and Shoreline Areas (15 m from the natural boundary) and Sensitive Terrestrial Ecosystems (covering the whole site).
The project will meet the requirements for the Natural Watercourse and Shoreline, and Sensitive Terrestrial Ecosystems Development Permit Areas, and will participate in the Green Shores for Coastal Development program.
- The Environmental Report indicates that more would be added to the Green Shores section – can the Town please get updated information if this is the case?
The project is enrolled in the Green Shores for Coastal Development program. The rezoning concept plan has been screened by the Christie Point consulting team to ensure the project meets the prerequisites for certification. At the detailed design stage, the consulting team will review the points available for Green Shores and design the project to ensure that it has every opportunity to improve the shoreline conditions, and riparian and marine habitats.
- How does the applicant propose to mitigate the number of additional people which will occupy the property and potentially recreate within sensitive natural areas?
Recommendations for mitigating the increased population and larger buildings of the site are described on pages 18-24 of the Swell Environmental Environmental Overview Assessment for Christie Point.
In particular, as described on page 19, the project will protect environmentally sensitive areas (e.g. rocky outcrops, shorelines, intertidal areas, archaeological areas) through designated trails, fencing, and education:
- Pedestrian access will be controlled on the site to prevent trampling of sensitive ecosystems and erosion along shoreline, as well as minimize disturbance to birds and wildlife. This will be accomplished through establishing distinct trails and viewpoints (in the locations of some existing informal paths), fencing and signage, and resident and visitor education.
- Trails will be designed to protect sensitive ecosystems and archaeological sites, and to control pedestrian access on the site in order to minimize disturbance to birds and wildlife. Techniques such as split rail fencing and signage will restrict access, and appropriate porous surface materials (gravel, woodchip) will be used for trails within 15 m of the natural boundary of Portage Inlet.
- An education program will be developed to provide information to residents, site managers and visitors regarding the Victoria Harbour Migratory Bird Sanctuary and the extremely sensitive nature of the mudflats, shoreline, and the birds and wildlife on and around the site, including the impacts from disturbing the mudflat biofilm by dogs, people and boat traffic. Information for the materials will be coordinated with Environment Canada and the organizations involved with Portage Inlet, via the Gorge Water Way Initiative. Environment Canada will provide Migratory Bird Sanctuary signs and their Connecting Canadians to Nature Program may be an opportunity to produce additional signage and other materials for the site. Educational materials will consist of:
- Environmental Management Manual for site managers
- Welcome Pack for new residents
- Signage at key locations such as entrances to natural and restored areas, ecologically sensitive areas, possible dock, and view points.
- Christie Point website, which will include information on the ecological conditions of the site
- Resident’s pets will be restricted to only indoor cats and on leash dogs to minimize the effects of increased pet populations on birds and wildlife. A small, enclosed off leash area is proposed.
The LADR Landscape Masterplan provides the conceptual layout for the development for rezoning, including proposed fencing, trails, viewpoints, and signage. [Reference: LADR Landscape Masterplan conceptual layout]
Monitoring and enforcing the protection policies for the site will be the responsibility of the onsite Realstar staff, who will be given training and support, in addition to an Environmental Management Manual for reference.
Additional details on protecting sensitive areas throughout the site will be developed in the detailed design, and provided as part of the Development Permit application.
- Any proposed dock or works below the natural boundary will require BC FLNR lease and DFO approval before the Development Permit approval.
The Christie Point consulting team is aware of the permitting process required for a dock at the site, including:
- Approval from the Province of British Columbia to use Crown Land for a Private Moorage (and the Best Management Practices that must be followed),
- Fisheries and Oceans Canada dock criteria for Project Review, if needed, and
- Transport Canada, Navigable Waters, requirements to meet criteria for Minor Works, and Project Review, if required.
Additionally, the Christie Point design team will consult with Green Shores, the Gorge Waterway Initiative and World Fisheries Trust to design the dock to protect the mudflat areas from disturbance when non-motorized craft are launched, and to incorporate other ecological features, such as substrate for Olympia oysters, if appropriate.
- Note that there has been local opposition to using Portage Inlet for even small non-motorized craft due to the eelgrass (and other) habitats.
A Green Shores friendly dock is proposed where a previous dock was situated, to provide one location on the site for water access for non-motorized craft to discourage widespread informal launch sites around the shoreline. As noted on page 22 of Swell Environmental’s Environmental Overview Assessment for Christie Point, this will minimize the disturbance to shoreline vegetation, water fowl and the mudflat biofilm, particularly where current access occurs on sensitive mudflats. A dock area would be a key location for information to educate residents and visitors about the sensitive nature of the birds, wildlife and surrounding ecosystem, as well as provide guidelines for environmental boating etiquette.
- There is concern around Victoria Harbour Migratory Bird Sanctuary and associated shoreline development.
As illustrated in Attachment 6, the Victoria Harbour Migratory Bird Sanctuary is extensive and includes many developed shoreline areas within Victoria’s urban boundary. [Reference: Attachment 6 - Victoria Harbour Migratory Bird Sanctuary map]
Pages 22 and 23 of the Environmental Overview Assessment for Christie Point by Swell Environmental describe the bird and wildlife recommendations for the project. The re-development concept has been designed to minimize the impact to birds and wildlife by implementing the following recommendations.
- If tree or shrub removal is required, it will be done outside of the general active nesting season between March 15 and August 15, if possible. Clearing trees or shrubs for deconstruction or construction of buildings or infrastructure will be preceded by a pre-clearing Bird Nesting Survey.
- An additional bird survey will be conducted in June 2017 to identify additional species using the site, because not all species breeding on the site would have been detected during the August survey. The survey will be conducted to determine additional nesting species and the measures necessary to protect them. A winter survey may also provide additional information.
- Pedestrian use on the site will be controlled as described previously to minimize disturbance to birds and wildlife.
- Overhead wires will be adjusted to meet the following recommendation, “Any sufficiently large form of marker, which thickens the line at that point by at least 20 cm, over a length of at least 10-20 cm, placed with regular interval for at least every 5-10 m on either earth wires or the conductors is likely to lower general collision rates by 50-80%.” (Jenkins et al. 2010).
- Where possible, wildlife friendly designs will be incorporated for night-time lighting to avoid disruption of habitat and survival of birds and wildlife, especially in multi-story buildings. Specific strategies are available here: http://www.flap.org/lights.php).
- Where possible, bird collision BMPs such as window screening, anti-reflective glass and non-glass enclosures for balconies will be incorporated into the design of multi-story buildings to reduce bird injury and mortality, especially adjacent to flyways. Specific materials and strategies are available here: http://www.flap.org/commercial_new.php, http://www.flap.org/new-tech.php, http://www.flap.org/glass.php).
- Building designs reviewed by a Bird Safe consultant to ensure that they meet the standards required to reduce dangers to migratory birds and other birds and wildlife (http://flap.org/birdsafe.php).
- Where possible, the dense shrubby vegetation will be maintained and increased (as described in the Vegetation section previously), especially in locations that will restore and supplement connectivity between isolated habitat patches that can be utilized by birds and wildlife as protected corridors.
- Trees, wildlife trees, and large woody debris on the ground and shoreline will be retained, in particular, within the area 15 m from the natural boundary of Portage Inlet.
- Resident’s pets will be restricted to only indoor cats and small, on leash dogs to minimize the effects of increased pet populations on birds and wildlife. A small, enclosed off leash area is proposed within the LADR Landscape Master Plan.
- Canada Goose and Mute Swan activity will be controlled by increasing vegetation to discourage their use of open, low-growing vegetated areas (e.g. lawn and salt marsh) adjacent to the shoreline. The lawn and saltmarsh area on the eastern shore of Christie Point with intensive Canada Goose impacts will be planted with beach grasses, native shrubs and trees to reduce the ability of geese to access the site. Control activities will be coordinated with the Regional Canada Goose Management Strategy partners (https://www.crd.bc.ca/project/goose-management), who are currently conducting a number of concerted population-reduction strategies (egg addling, hazing, and culls).
- The project will coordinate with the BC Purple Martin Stewardship and Recovery Program (http://www.georgiabasin.ca/puma.htm) and the Western Purple Martin Foundation (http://www.saveourmartins.org) to install nest boxes in suitable locations within the area 15m from the natural boundary of Portage Inlet, the contact person is Wallis Reid at wmreid25@gmail.com.
- Nest boxes will be installed (small hole size, holes 1 inch or less in diameter to discourage House Sparrows and Starlings) in forested settings for native cavity-nesting birds, such as Violet-green Swallows.
- As described in Comment 40 and 56, educational activities, including working with Environment Canada for information specific to the Victoria Harbour Migratory Bird Sanctuary, will be undertaken to provide information to residents, site managers and visitors regarding the extremely sensitive nature of the bird and wildlife populations on and adjacent to the site.
Additionally, the Environmental Management Plan that will be developed prior to construction will detail the environmental protection measures to be implemented to protect trees, understory vegetation, riparian, shoreline and intertidal areas, birds and wildlife, and their habitat, and Portage Inlet during construction.
No nests of Bald Eagle, Peregrine Falcon, Gyrfalcon, Osprey, or Great Blue Heron were observed on site. Prior to any clearing or tree removal for construction the site will be assessed for the presence of nesting birds, and appropriate protection measures implemented, as needed.
- All recommendations within the Environmental Report are expected to be implemented at time of DP, as conditions, and more may be included or expanded upon.
The recommendations from the Environmental Overview Assessment for Christie Point will be developed in further detail during the detailed design of the project, and will be submitted with the Development Permit Application.
Tree Planting/Removal
- A more detailed tree retention/removal plan is required – the one provided in the report is far too low-resolution to be legible.
The attached Tree Retention Status drawing (Attachment 9) clarifies the intentions and rationale pertaining to tree removal and retention. [Reference: Attachment 9 - Tree Retention Status drawing]
- Does the arborists’ report describe tree planting areas? The environmental report indicates that ‘far greater number of trees planted than removed’ (P. 21) but no numbers are given.
The attached Tree Retention Status drawing illustrates that 144 large native trees and 22 medium native street trees are to be planted as part of the development. The arborist report recommends the removal of 11 existing trees on the property due to their poor health and dangerous condition. These trees will be removed regardless of the redevelopment. A further 3 trees will be removed to accommodate the new construction, and 5 additional trees may have to be removed, although this will be determined during construction. In total, 11 trees are to be removed immediately due to poor health and unsafe conditions, 3 to 8 trees are impacted by the redevelopment, and 166 new native trees will be planted as part of the redevelopment, for a net increase of 147 to 152 trees on site.
Locations of new plantings are illustrated in Attachment 10, the Christie Point Landscape Master Plan. [Reference: Attachment 10 - Christie Point Landscape Master Plan]
Soil Deposit/Removal
- The Town has a Soil Deposit/Removal bylaw and significant works on site (either soil brought on site or removed from site) may trigger a permit requirement. Soil includes all substrate including sand, rock, gravel etc.
The current plan is to reuse soil from excavation on site to achieve the new topography required to screen the partially-submerged parking garages. In this regard, it is currently assumed that no additional soil will need to be deposited on site as part of the development.
Archaeology
- All recommendations within the report are expected to be implemented, including the need for more work required.
All recommendations outlined in Terra Archaeology’s Archaeological Overview Assessment will be implemented, as follows:
- The scope of additional archaeological work depends on the exact nature of the approved development.
- Any additional archaeological work would need to be authorised (permitted) by the Archaeology Branch.
- Additional work will likely include archaeological monitoring of ground alterations within site boundaries and areas of archaeological potential (AAPs).
- Significant archaeological finds are unlikely, but would be thoroughly investigated should they be identified.
- A plan for handling human remains, should they be present, would be developed in consultation with local First Nations, prior to any archaeological work.
- Archaeology is a provincial requirement, regulated by the Heritage Act and Archaeology Branch. The Town does not regulate.
Realstar, under the guidance of Terra Archaeology, will comply with provincial regulations throughout the development process, including:
- An HCA Section 12 Alteration Permit (called a “SAP”) is required for any ground alterations within known site boundaries.
- Once construction and landscaping plans are finalised (or close to finalised), an individual representing the development proponent and a qualified professional archaeologist co-apply for a permit. Generally, the archaeologist drafts the application and submits it on behalf of both applicants.
- SAP applications are customised for the particular development and archaeological sites to be altered and contain detailed information about the development and concurrent archaeological studies (like monitoring).
- The Archaeology Branch typically issues a permit within 8 weeks of receiving an application. Their review includes consultation with First Nations who have an interest in the project location.
- The Archaeology Branch may require that an archaeological impact assessment (AIA) is completed prior to them issuing a SAP. However, in the case of Christie Point, this requirement is unlikely, given the extremely limited opportunity for a thorough AIA involving subsurface sampling (the project footprint is primarily covered in existing buildings and paved surfaces).
Mobility – Vehicular, Pedestrian, Cycling and Parking (both bicycles and cars)
- Paving the pathway along the Shoreline waterfront and connecting to the Island Highway bike lane is required.
Realstar is prepared to consider funding this infrastructure improvement as part of the Community Amenity Contribution associated with the application.
- Total parking provided is 522 assigned plus 72 visitor for 594 spaces for 473 units. This is a ratio of 1.26. Guest spaces count towards the total provision. To calculate the final parking required we will need a unit breakdown.
The suite mixes for each building will be determined at the time of detailed building design. For illustrative purposes, a sample suite mix for the project could be as follows:
| Suite Type | Proportion | Number |
|---|---|---|
| Studio | 5% | 24 |
| 1-bedroom | 33% | 156 |
| 2-bedroom | 50% | 236 |
| 3-bedroom | 12% | 57 |
| Total | 100% | 473 |
This sample suite mix yields a parking requirement of 648 stalls, or 1.37 stalls per unit. In this example, the sample suite mix results in a parking shortfall of 0.11 stalls per unit or 54 stalls.
Parking requirement is not established in the zone table; it is separate.
Is Realstar planning on taking advantage of the cash-in-lieu provision for parking? Up to 15% can be provided in cash at $12,000 each space.
Given the sample suite mix and proposed range of unit types, it is possible that cash-in-lieu of parking will be required to account for a potential shortfall in the number of parking stalls provided by the development. However, as in the example provided under comment #67, the shortfall is not expected to be significant.
- Can you provide a more detailed description of bicycle parking and bicycle amenities? Maintenance areas? Accommodation for oversized bicycles and trailers?
The attached Bicycle Facilities Ideas sheet (Attachment 11) illustrates potential solutions for long-term secure storage, short-term outdoor storage, and bicycle maintenance stations for residents and visitors. Accommodation of oversized bikes such as cargo, tandem, and box bikes can be provided in the secure bicycle rooms, commensurate with estimated user demand and industry best practices. [Reference: Attachment 11 - Bicycle Facilities Ideas sheet]
- Will there be storage lockers available on-site?
Storage lockers will be available within the new buildings. The number and size of these lockers will be determined at the detailed building design stage.
- Some proposed units will be beyond what is typically established as an acceptable walking distance to promote transit use (400-600m) or local shopping distances (1000m) and as such there will be a justified anticipation by some that automobile use will be significant.
A primary goal of the project’s transportation strategy is to encourage alternative forms of transportation, including cycling and walking, as much as possible. The proposal to improve pedestrian amenities, such as a continuous sidewalk on Shoreline Drive from Island Highway to Craigowan Road and the introduction of a pedestrian activated crosswalk at Shoreline Drive and Island Highway, makes nearby transit amenities and shopping areas more accessible to pedestrians.
This strategy is supported by studies by Translink and the Institute to Highways and Transportation (UK), and summarized in the following table.
Walking Thresholds to Town Centre Facilities
| Facility | Walking Thresholds |
|---|---|
| Bus Transit | 450m(a) |
| Transit Focal Point | 800m(b) |
| Leisure / Community Facilities | 600-800m(b) |
| Shops, restaurants, commercial | 800-1200m(b) |
| Employment | 2000m(b) |
(a) Translink (b) Institute to Highways and Transportation (UK)
Building Department
- From a building code perspective, much information is not included for the purpose of this application. The required details will likely accompany any building permit applications that come forward as a result of this process and those that are not submitted will be requested as required by the Building Official. Immediately from the review, the number of exits from the parkade area serving buildings E and D-2 would be an area that would require further scrutiny and clarification from the Architect.
The building designs submitted as part of the rezoning application are schematic and illustrative of general architectural intentions. The building design process will occur subsequent to rezoning application approvals and, as always, designs will include full compliance with all applicable building codes and bylaws, and Letters of Assurance from the Certified Registered Professionals (Architect and Engineers).
- The Building Code is swiftly indicating moves towards “net zero” energy efficiency. It will benefit the applicant greatly to take this into consideration and look to the future of where we will be heading with this initiative.
As a long term owner and operator, Realstar is interested in any initiatives that increase energy efficiency and lower operating costs; as such we will take this into consideration at the detailed building design stage.
- Inclusion of projects such as “Safer Homes” and/or other programs similar to it would be welcomed as they are designed to provide barrier free living for residents for years to come.
One intention of the project is to provide more accessible housing options than are currently available at Christie Point; this includes barrier free units, as required by the National Building Code, as well as fully accessible buildings, served by elevators. There are no units on the property that meet current accessibility standards.
It is the intention of the proposed redevelopment to provide full access to residential units and amenities for all residents and guests, including the elderly and those with special mobility needs. The design team is interested in pursuing strategies which align with the ‘aging in place’ goals of View Royal’s OCP, by providing accessibility and integrating barrier-free design throughout the development.
Protective Services Department
- From a re-zoning point of view I have no concerns with the proposal. As the project moves forward we may need to look at the total amount of water available, CRD issue (Pressure reducer on Shoreline Drive) as well as there will need to be some work done to insure access to building D2. Both of these issues are code requirements that will be addressed during the servicing agreement and Building Code Review for BP.
Realstar’s consultant team, specifically McElhanney Consulting Services Limited, will coordinate with CRD to confirm available fire flow and address requirements.
We trust this comprehensive response to the comments received from Town of View Royal regarding the application for the redevelopment of Christie Point is satisfactory.
We look forward to continuing to work with you, Christie Point residents, the community and the Mayor and Council on this exciting project.
Yours very sincerely,
REALSTAR MANAGEMENT
Heather Grey-Wolf Vice President, Development
List of Attachments:
- Attachment 1: Rezoning Building Height Clarification
- Attachment 2: Flood Risk Areas
- Attachment 3: Tree Planting and Growth Plan
- Attachment 4: Estimated Tree Growth
- Attachment 5: Waterfront View Analysis
- Attachment 6: Victoria Harbour Migratory Bird Sanctuary
- Attachment 7: Revised Community and Stakeholder Engagement Summary, March 2017
- Attachment 8: Christie Point Demographic and Rent Analysis
- Attachment 9: Tree Retention Status
- Attachment 10: Christie Point Landscape Master Plan
- Attachment 11: Bicycle Facilities Ideas
cc. John Rosenberg, Director, Town of View Royal, Engineering Department Deb Becelaere, Deputy Director, Town of View Royal, Engineering Department James Davison, Planner, Town of View Royal, Planning Department
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