“Our job is to see how much housing we can pack into the Broadway Corridor when they redevelop it.  But you didn’t hear that from me.”

- Bill Aube, Property Development Officer, City of Vancouver, 1/14/20

On November 4th, the City released the Broadway Plan Phase 3 - Refined Directions (read here). We have been involved in all phases of the Broadway Plan thus far, and have identified several, serious concerns regarding the Phase 1 and 2 plans, and engagement processes. These concerns were thoroughly documented and communicated to Council (read here).  The FSGAC and its friends have reviewed the Phase 3 plans and they have only deepened our concerns. The valuable input provided by residents regarding height, density, villages, transportation, schools, parks and amenities has been completely ignored, while the bureaucrats and developers have carved-up our neighbourhoods behind closed doors.  The publication of Phase 3 confirms our suspicions were correct: (1) Staff has already made its mind up about the heights for the Broadway Plan area, or (2) Staff doesn’t care what the public thinks are appropriate heights.  Below, we highlight these concerns and the painfully obvious gaps in the current information.

Phase 3 Summary

  • Increases the scope area population by up to 50,000 to around 128,000 residents (an increase of 64% compared to 78,000 residents today) by increasing the number of homes in the area from by 30,000 units.

  • Office, retail, restaurant, institutional, and industrial spaces will expand the number of jobs from 84,400 today to 126,000.

  • The tallest buildings, with heights of 30 - 40 storeys, will be in the “Centre” areas around the six new subway stations (see image here). 

  • The 2 to 3 block shoulder areas around the stations, will allow heights of 20 - 30 storeys (see image here).

  • The Villages, including West 4th Ave. (within Kitsilano), South Granville (south of 10th Ave.), and Main St. (south of 7th Ave.) will see new building heights of 4 - 6 storeys (see image here).

  • In surrounding neighbourhoods (e.g., Fairview South), height and density will be increased for purpose-built rental housing towers to replace low-rise rental buildings.

  • Single-family homes areas will see new 6-storey market rental buildings and 12 - 18 storey below-market rental towers.

  • The newly named Uptown/Cambie North "second Downtown" in the Cambie & Broadway area (where a new City Hall is planned) will have buildings 6 - 15 storeys.

  • Existing industrial areas within Mount Pleasant will see intensified industrial and office uses.

  • Broadway will be narrowed to four travel lanes to accommodate wider sidewalks.

  • Click here to see where the skyscrapers will be located.​​


  • No Council Mandate:  Not one member of the current council ran on a platform of dramatically altering the face of the Broadway Corridor.  They lack the mandate to inflict such changes with negligible consultation.

  • A Rushed Approach:  The Phase 3 engagement plans were launched days after Theresa O'Donnell, head of Planning, advised Council of the planned events. Rushing through a series of small workshops in one month is, frankly, outrageous. If every building along the proposed length of the Plan area sent just one attendee, the workshop attendee limits would soon be exhausted. 

  • One Option - Skyscrapers:  In all the public consultation we've attended,  this has been one of the biggest concerns.  Staff have only provided one option, and it's the skyscraper one. This likely reflects the “conventional wisdom” of urban planners and desires of developers, but we should expect a “mid-rise” alternative, within the current zoning.  In fact, when we asked workshop staff why only 1 option was proposed, they said that modelling showed that this was necessary to accommodate the density.  But what data is this "density" and the population and jobs projections based upon?  Theresa O'Donnell, head of Planning has stated that staff don't even know what the existing, unused zoned capacity is.  How can you plan for more density, when you don't even know what you already have? 

  • Staff Tampering & Legitimacy of the Plan:  City staff have been tampering with the Broadway Plan since early 2018, months before it was approved by Council. 

    • In the timeline that the FSGAC created in relation to the "blockbusting" rezoning of 2358 Birch Street (read here), you can see City staff writing about their expectations for more height and density as a result of the Broadway Plan, even before the process was approved and launched.  Many of the names you see in the correspondence are still actively involved in the Broadway Plan (John Grottenberg, Dan Garrison, etc.). 

    • In the Spring of 2021, Theresa O’Donnell, head of Planning, told the FSGAC that height in the Broadway Plan area had not decided. Then why is this plan full of heights and densities that are a huge departure from what the residents are willing to support?  O'Donnell was being cute:  While the Plan had not yet been "decided-on" by Council vote, clearly, staff had already made decisions.  Yes, this is the type of people working for our City.  

    • Staff have pushed additional, preemptive rezonings at 1395 W Broadway (read here) and 1477 W Broadway (read here).  Is it a coincidence that staff propose consideration of a 39-storey building at 1477 W Broadway on July 21, 2021, and then on November 4, 2021 release the Phase 3 which proposes 20-40 storeys at that same intersection?  How can we trust the Plan and the staff that are conducting it? 

  • Questionable Affordability: 

    • Affordable housing is mentioned 84 times in the Plan, but no definitions of affordability are provided. Despite affordability being a major concern, the information in the Plan is misleading because of the glaring lack of specificity. How do staff define “affordable housing”? Is it rent priced to median income, or a level below median income? If below, how far below? And what proportion of all new housing to be constructed under the Plan will be required to meet this affordability measure – 20%, 50%, or 80%? 

    • Affordable housing is conflated with market rental several times ("affordable housing e.g.  ["secured rental or social housing])", even though current market rents in new buildings are only affordable to the top 10% of wage earners. With the $340 per square foot DCE tax already in place (which matches the cost of construction) the City could get up to 100% truly affordable housing pegged to average household income, not to the top 10%. The question remains, should those billions triggered by this plan go to land speculators or city wage earners who need housing? 

    • In the workshops, staff seem quite aware of the problem of spot rezoning on property values.  They say they are trying to eliminate spot rezoning, but gave no real response when we asked why they are pushing 3 preemptive rezonings in the Plan area.

  • Disastrous MIRHPP Built-In: Staff have built the expensive, unnecessary Moderate Income Rental Housing Pilot Program ("MIRHPP") into the Plan.  In MIRHPP, the City forgoes DCLs and CACs (the money it uses to build public amenities) and concedes massive height and density for a small number of barely affordable, extremely small apartments, located in undesirable parts of developments.  The FSGAC's analysis of MIRHPP has shown that it provides a windfall for developers, making developments obscenely profitable. MIRHPP is not needed to produce affordable housing and the numbers prove it.​

  • No Money for Public Benefits:  On slide 101, the staff write that since the Plan’s focus is on affordable housing and job space, new developments will produce lower levels of the development contributions (DCLs and CACs) that are used to build parks, community centres and public places, requiring the prioritization of public benefits.  Residents will sacrifice the existing livability of their neighbourhoods and should expect little to nothing in return.    

    • No New Parks:  On slides 88-92, the Plan talks at length about parks, but conspicuously absent are any specifics about new parks. The vague, non-committal language says that the Plan "supports" improvements to existing parks and exploring new parks.  But, the Plan doesn't provide details on any new parks at all.  In fact, what it does do is talk an awful lot about existing parks, ties new parks to new developments (where is the public park space in 2538 Birch, 1395 W Broadway & 1477 W Broadway?) and says that any new parks will take years to build through piecemeal land acquisition.  In other words...expect skyscrapers tomorrow, and parks....we'll get back to you. 

    • No New Community Centres:  On slide 95 the Plan talks about upgrading existing community centres, but provides no details for new community centres, despite the plans to add 50,000 new residents and 40,000 new jobs to the scope area. ​

  • No New Schools:  The planners spend a ridiculous amount of time talking about children walking/rolling to school, which sounds great.  However, they cleverly side-step the most important piece of this puzzle: Planning for new schools that are close-by. No child is walking/rolling to school if their school is across the City.

    • The document only mentions support for renewal and expansion of schools ONCE, on slide 39, and its for an independent school

    • On slide 103, the Plan comes clean and says that schools are important but they're a provincial responsibility.  So, a plan that adds 50,000 people doesn't need to plan for new schools?   

  • Views & Shadowing:  

    • View Cones: On slides 15-17, the Plan talks at length about the importance of views to Vancouver's image, and then quickly moves-on to propose view cone changes, to allow taller buildings along Broadway.  These changes would replace cherished City views with street-end views which, ironically, would be best viewed while driving. ​

    • Shadowing:  On slides 88-92, the Plan talks about efforts to limit shadowing on parks, but note that shadowing concerns are not mentioned once in the Fairview Slopes and Burrard Slopes areas, even though shadowing is a significant concerns to these residents, because they lie down-grade from the skyscrapers proposed on Broadway.  See this City Hall Watch article for an analysis on the shadowing impacts of 1477 W Broadway (click here). 

  • New "Centres": The Plan proposes new "Centres" around the subway stations which will allow massive, new developments (think 1477 W Broadway). The Centres are extremely large and cover parts of the surrounding neighbourhoods which are currently residential and small business-oriented.  The pressure of these expanded Centres will endanger existing small businesses, raise housing costs and increase renovictions in these areas.

  • Granville Loop Development:  On slide 46, the Plan proposes development of the Southwest Granville Loop, located at the southern end of the Granville Street Bridge. The Loop has landscaping, trees, pedestrian paths, and public art, and falls within the South Granville/Burrard Slopes area of the Plan, which calls for towers 15 - 25 storeys (see image here)

  • Narrowing Broadway:  The Plan calls for a 64% increase in residents, and more jobs / workers. Yet the plan to narrow Broadway will reduce street capacity by 33%.

    • A significant amount of “rush hour” traffic is transient (ie: coming from the suburbs to downtown). The Broadway subway won’t reduce this traffic.  Broadway includes sections of Highway 99 and traffic routes from the suburbs.  The subway won’t reduce this traffic. Staff have modelled for a 1.x% / yr. increase in traffic. This doesn't make sense, and likely relies on congestion charges in the downtown core to reduce traffic.

    • There will still be buses running on Broadway.  There has not yet been a decision regarding “pull-outs” for the buses, or if they will stop in one of the two traffic lanes  (the later would be a traffic disaster).

    • Despite residents concerns about "shortcutting" in shoulder neighbourhoods, which were raised in City-led workshops, the Plan doesn't discuss the impact of squeezing traffic on Broadway, nor any protections to prevent and control traffic in shoulder neighbourhoods. 

  • Implications of Population Change:  Adding 50,000 more residents will make this area denser than all but 2 areas of Vancouver, and impact livability / quality of life.

    • We may need more office / business space but it doesn’t necessarily follow that we need an equivalent amount of residential space in the same area.  With a new subway, people are going to move where they can get the most home for their money (to the suburbs), and commute.

    • There seems to be an implicit assumption that having residents near offices reduces commuting.  This may not be a correct assumption, and the City should have research to prove or disprove the assumption.

    • What would the Plan look like if it was based on 25,000 additional residents?  No alternative options have been presented.

  • Mysterious Figures & Data: 

    • On slide 31, Phase 3 presents Metro Vancouver population data for the Burrard Peninsula, which includes Vancouver, Burnaby, New Westminster and UBC/UEL.  However, it doesn't provide any explanation for how staff have come up with the proposed 50,000 population and 40,000 job increases for the Plan area.  Staff also make the assumption that new immigrants will want to live in, Vancouver, the most expensive area of the lower mainland.  Again, no explanation or source is provided for this assertion.  In the past, staff have misrepresented "aspirational housing targets", as data-based goals - are they doing that again here?  In fact, when we asked workshop staff where the 50,000 target came from, they said that it was a given. 

    • According to our analysis, the population forecast for the Broadway plan is 50,000 people over 30 years, or 1,666 per year. Based on data, the FSGAC estimate was around 1,050 per year. So the Plan proposes an increase in household size, ie: more families in the Broadway Plan area.  Will this larger household size translate into more bedrooms and larger units in the affordable housing that City staff promise?  In the 3 preemptive developments at 2538 Birch St., 1395 W Broadway and 1477 W Broadway, this has not been the case. ​​

  • Staff Presumptions:  Phase 3 diagrams include 3 towers protruding through existing view corridors—two of these are rezonings that have not yet been approved, the 3rd was the highly controversial 2538 Birch St. Staff illustrations take the approval of 1395 & 1477 W Broadway as a given, which is a massive over reach—the diagrams are at best misleading, at worse, outright false. 

  • Guiding Principle "Encourage Contextual Design": The Broadway Plan's 9 Guiding Principles include "Encouraging Contextual Design".  New development should include architecture and building forms that respond to the evolving local context, including topography and elements of neighbourhood character (i.e. terracing, access to views and light, green and leafy streetscapes, variety of building materials, gardens, etc.), as well as the new Broadway Subway.  In early conversations, staff pointed to this principle to assuage resident concerns about excessive height, density and shadowing but, clearly this principle is was intended more to create assurance than to promote good planning. ​

  • Shoulder Neighbourhood Towers:  The Plan uses heart-warming pictures and sweet words about walkable communities, however, every sub-area includes towers—a classic hiding the tall trees in the forest floor move. This amounts to a blanket rezoning for skyscrapers, which is unacceptable. 

  • Flawed Surveys:  We have completed countless questionnaires and surveys, and the options presented in these surveys are defined to elicit the desired responses.  For instance, not one of the surveys has asked, “How tall do you think buildings in the Broadway Plan area should be?”.  And, when asked what kind of housing types you'd like, "single family dwelling" is never an option.  These omissions produce heavily manipulated and deeply flawed data that staff use to justify their proposals to Council and the public. 

  • Unanswered Questions:  

    • Where is the data?

    • What can the existing zoning produce? 

    • How does the Broadway Plan's projections dovetail with the projections for False Creek, Jericho, Senakw, Molson, Heather and elsewhere? Do we need to do this much?

    • What is the impact of all this upzoning on the large, existing rental stock in Fairview?  



The capital expenditure outlays required by the Broadway Plan and the larger Vancouver Plan will run into the hundreds of millions, if not billions, of dollars. No business, operating with budgets the size of the City of Vancouver, would undertake a planning exercise as a prelude to such major expenditures, without the benefit of all the facts. In that regard, the Plan and the participants have been hamstrung by this lack of foundational information. Transparent data, facts, as well as sound planning guidelines (e.g., seats in schools, m2 of greenspace/person), should have formed the basis of the Broadway Plan and its Guiding Principles on Day one, and should have formed the basis of every discussion. 


It is hard to understand how recommendations to Council can be considered credible when there are such obvious gaps in the public engagement process. It will be equally hard for residents to understand how Council could consider a plan in the absence of such data.