1477 W BROADWAY
REFERRAL REPORT CRITIQUE

The Referral Report for 1477 W Broadway (RBC site) has been published and will be considered by Council on Tuesday, March 1st.

We critiqued staff's rationale for pushing this rezoning last summer and published a scathing review (read here). We have now reviewed the Referral Report in detail and have, again, found stunning errors, omissions and inconsistencies which speak to staff's confidence that this rezoning is a fait accompli: 

  • Broadway Plan Decided:  ​7 times throughout the Report, City staff state that the proposed height and density of the proposal aligns with the Broadway Plan Refined Directions, even though the Broadway Plan is not finished, nor has it been approved by Council.  This demonstrates that the City is only paying lip service to the public through the Broadway Plan consultation. 

  • Outsized Dimensions: 39-storey skyscraper, 407 ft. tall, with an FSR of 12.30 (2538 Birch Street had an FSR of 10.52).  It is worth noting that, at 407 feet tall, this building will become the tallest building – at least until the next surprise is dropped by Staff – south of False Creek, and will be almost 100 feet taller than Vancouver General Hospital.

  • Disastrous MIRHPP Program:  We think there needs to be greater scrutiny of unit sizes and rents for the “affordable” MIRHPP units. The report does not disclose unit sizes, nor the final number of MIRHPP units being constructed.  This is a dangerous precedent: The City stipulates the absolute rent for each dwelling type, such as $950 for a studio.  On page 12 the Report says the average unit size is 434 sq ft.  If you are paying $950 for 434 sq ft. you are paying $2.14/ sq ft.  What happens if the unit size reduces to, say 400 sq. ft. in the MIRHPP units?  Does the rent go down? No – the developer gets to charge the same rent, and at the tenant’s rental cost per sq. ft. increases $2.33 per sq ft, for a space that is actually 7.8% smaller.  As they say, the devil is in the details, and these details favour developers.

  • Staff Defining Policy:  Staff cite the Metro Core Jobs and Economy Land Use Plan (“Metro Core Plan”, "MCP") as part of the justification for their recommendation.  While the Metro Core Plan does, we agree, suggest that additional density could be considered, nowhere does it stipulate any particular guidance – the people that approved the MCP might well have intended that it would mean an increase of, for example, an FSR of 3 to 4, rather than from an FSR of 3 to an FSR of 12. Put simply, they are trying to justify this project on the basis of a Plan which has no quantified parameters, so whatever staff says is presumably ok.

  • Flimsy Arguments:Staff claim that the project must advance to avoid access challenges during the subway opening, but their arguments are flimsy and inconsistent (read here). 

  • Millions in Giveaways: The developer (PCI) has applied for a Development Cost Levy waiver (saving $3.3M) and will not have to make any financial Community Amenity Contributions, the money used to pay for parks, childcare facilities, social housing, infrastructure, etc. If, as the report suggest, there will be 43 MIRHPP units, that equates to a subsidy of $77,733 per unit. Residents should not lose sight of the fact that this is revenue that the City will not be receiving – and will have to make this up elsewhere – meaning your property taxes.

  • Incomplete Shadow Studies: Staff claim that no major public parks or plazas are shaded by the building, however they didn't assess shadowing at the winter solstice, the darkest time of the year. Our shadow studies show that the winter shadows will have severe implications for several nearby parks and popular public areas.   

 

  • Parking Disaster: No additional parking over the 285 vehicles spaces allocated for 223 homes and 6-storeys of commercial space.  Where are people going to park in our already parking-challenged neighbourhoods? 

  • Jumping the Gun: The Report also cites as justification the Employment Lands and Economy Review, but the language in the Report makes it clear there has been no definitive final report issued.  What happens if the final report is substantially different from the interim report.  Does it mean the recommendation in this Report is invalid? Staff would be better advised to try and justify proposals on matters that have been agreed to and adopted, rather than speculate on outcomes of in-process studies they think will support their agenda.

  • Not so Green: Staff claims that this is a "green" building, but Brian Palmquist's recent analysis (read here) shows that the COV's Sustainability standards are, in some cases, non-existent, nor do they contemplate the full lifecycle GHG emissions of buildings, including construction and materials.  

 

  • No Accounting: Figure 5 on page 11 makes reference to the number of units that have been approved as part of the Housing Vancouver Targets for Market Rentals. We think the public would actually like to know how many have been constructed, as well as how many more applications the City has in the pipeline across the City.  How many are planned for Jericho and the Squamish nation lands? Can they assure residents that they aren’t going to try to meet those targets by forcing all the density into the Broadway corridor using projects such as these?

  • Confusing Public Feedback: The Virtual Open House data is a confusing mess, intended to create the illusion of engagement. Buried in Appendix F we learn that 207 respondents opposed the rezoning (vs. 197 in support, 20 mixed), but the data doesn't report where the respondents live. Based on our previous first-hand experiences, most "support" comes from outside of Vancouver.  Is that democratic?

 

  • Homes for Families: The prevailing orthodoxy amongst the brains trust in City Hall, Translink, and the Province is that it is a splendid idea to have housing above subways.  You might convince yourself of that in some instances, but ask yourself this: How much sense does it make to have family-oriented housing in a high-rise located at one of the busiest intersections in the City of Vancouver, and where the subway station will generate a very high volume of foot traffic? Has any thought been given to the possibility that this might not be the ideal location for children since, even if they want to go to Granville Park, it’s 0.5km away and requires walking down busy streets and navigating through transit-related pedestrian traffic and queues?

  • Parks and Schools: Per the Housing Vancouver Strategy, this rental building is being planned for all family types and yet, the Report provides no details on the building's amenities, access to parks, nor space in nearby schools (catchment schools and other nearby schools have no capacity). 

    • Under the section headed “Council Authority/Previous Decisions” staff have cited the “High-Density Housing for Families with Children Guidelines” as part of the justification for this project. We assume staff haven’t actually read those guidelines closely, if at all. The guidelines stipulate that “sites selected for family housing development should be within 0.8 km walking distance of an elementary school”. According to Google maps, False Creek Elementary School is 1.3km from Broadway and Granville.  Henry Hudson Elementary school is a distance of 1.6km. Taking children to either school means that parents will be climbing uphill in winter to bring their children home from school – which will be very challenging if there are several centimeters of snow on the ground.  But that’s not all!  Staff have failed to acknowledge that the closest schools are not only further away than the Guidelines contemplate,  they are both operating at full capacity! Sadly, this is not a new issue for any of us. These are the exact same mistakes/omissions staff made with respect to the rezoning of 2538 Birch and if this project is approved, the City will have doubled down on the problem.  We are at a loss to understand the City of Vancouver’s approach to housing and planning.  We can’t decide if it is simply wilful blindness on the part of staff (and council, if they approve this proposal), by being silent and pretending the problem doesn’t exist, or if they are adopting the Field of Dreams approach: If you build it, they will come (with schools).