Download letter from Neighbourhoods for a Sustainable Vancouver in PDF: NSV – CoV RGS letter Feb 28 2011v.
Excerpt: Given the lack of consultation with the citizens of the City of Vancouver, the inadequate public hearing process and the significance of the changes the Regional Growth Strategy would entail, the City should request a delay in the further consideration of the proposed Regional Growth Strategy, further to section 857(4)(b) of the Local Government Act, to enable a proper assessment of the complex issues that the document raises and the appropriate City response. A major change of land use policy such as this should go to referendum.
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To readers: We encourage you to attend the City of Vancouver Planning and Environment Meeting of Council March 3, 2011 @ 2:00 pm and speak to this issue. (You can also watch by live video stream.) It is the most important issue for the future of land use policy in the region and the City of Vancouver affecting the next 30 years. Please send your own e-mails and letters as well. Thanks.
From: Neighbourhoods for a Sustainable Vancouver
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Subject: Metro Vancouver Regional Growth Strategy, Bylaw No. 1136, P & E Meeting of Council March 3, 2011 @ 2:00 pm
Date: Tue, 1 Mar 2011 09:43:34 -0800
Neighbourhoods for a Sustainable Vancouver
February 28, 2011
Mayor Robertson and Councillors
City of Vancouver
453 West 12 Avenue
Vancouver, B.C. V5Y 1V4
Dear Mayor and Councillors:
Re: Metro Vancouver Regional Growth Strategy, Bylaw No. 1136, January 2011
Please accept this as our comments on the proposed Metro Vancouver Regional Growth Strategy, Bylaw 1136, January 2011.
We encourage the City of Vancouver to NOT accept the currently proposed Regional Growth Strategy (RGS). There are numerous problems with the proposal that are not to the best interest of the public, private sector or the City, and is inconsistent with the Greenest City initiative.
The Regional Growth Strategy Bylaw was introduced on November 12, 2010. A public hearing was then immediately called, and completed in 3 weeks. After the public hearing, Metro Vancouver would not allow members of the public to confer with their elected officials on the RGS. To properly address the many concerns about the RGS, it requires more time to consider the alternatives to the final draft of the bylaw.
Therefore, we request that the City:
- Request a delay in the further consideration of the proposed Regional Growth Strategy, further to section 857(4)(b) of the Local Government Act, to enable a proper assessment of the complex issues that the document raises and the appropriate City response, given the shortness of the public hearing, and the significance of the changes the Regional Growth Strategy would entail;
- Provide an independent third party legal opinion of the impact of the Regional Growth Strategy on the City of Vancouver and its citizens;
- Reconsider other more effective options to achieving the stated goals of the proposed Regional Growth Strategy for the City of Vancouver and the region.
Consider a modified Liveable Region Strategic Plan (LRSP) approach:
The Regional Growth Strategy uses an expanded regulatory approach rather than what is now in the Liveable Region Strategic Plan (LRSP). The RGS proposes a regulatory approach to all areas of the region, whereas the LRSP only uses a regulatory approach for the Green Zones and a leadership approach to the rest. We feel that the RGS will be very costly to administer and will not result in the stated goal of preventing urban sprawl.
We suggest staying with an LRSP approach with slight modifications.
- Continue the existing regulatory approach for the Green Zone as per the LRSP, but with stronger protection of the Green Zones from exclusions; and
- add regulatory approach to rural lands; and
- add regulatory approach to industrial lands.
With a leadership approach:
- Use the leadership approach for everything else; and
- do not use regional land use designations other than for the regulatory approach above.
This would prevent urban sprawl while still keeping the administration of regulation fairly simplified and less bureaucratic.
The RGS would require an expanded regional administration that would likely be supported through increased regional property taxes, regional Development Cost Levies (DCLs) and regional Community Amenity Contributions (CACs). These increased fees will make housing more expensive and remove opportunities for municipalities to use these funding sources for municipal amenities to service the increased population.
If the regional plan is based on a modified LRSP approach as suggested above, the land use authority remains with the City in urban areas, and property taxes and development fees can go towards providing municipal services for the increased population rather than supporting the regional bureaucracy.
The Regional Growth Strategy does not prevent urban sprawl.
The RGS has eliminated the Green Zone in the LRSP and replaced it with the Urban Containment Boundary which is not nearly as effective. The requirements for conversion to other uses are much lower. Special Study Areas and lands adjacent to the Urban Containment Boundary can be re-designated with only a 50%+1 vote of a quorum of the Metro Board and no public hearing. Overall amendments have been changed from 100% required vote and a public hearing under the original LRSP to only a 2/3 Metro vote of quorum under the RGS. The region could amend the LRSP to add some protection of industrial land until a new regional plan can be established.
Since the Special Study Areas have a much lower approval requirement for exclusion of only a 50%+1 vote of a quorum of the Metro Board with no public hearing, the Special Study Areas fuel land speculation which increases the land value and makes it uneconomical to farm or retain as protected areas. This also applies to land adjacent to the Urban Containment Boundary that can be converted to industrial with the same threshold of 50%+1 vote and no public hearing.
The Agricultural Land Commission and the West Coast environmental Law Society have confirmed that the RGS designation of certain areas, which are currently within the ALR, as General Urban (229 hectares in Richmond, Aldergrove and Abbottsford) is illegal under the Act, and the wording in the RGS does not adequately address this. This inconsistency must be resolved for the RGS Bylaw to be legal.
Although these areas have had this same inconsistency since the Liveable Region Strategic Plan was adopted 15 years ago, the LRSP does not have defined regional land use designations as do those in the RGS Bylaw. The RGS puts much more development pressure on those lands because of the regional definition of General Urban.
The Regional Growth Strategy would also allow potential significant urban sprawl into the forested lands of the West Vancouver mountains that would ruin the iconic natural mountains that are so important to environmental protection, views from Vancouver, and to the tourist industry.
Although TransLink’s role has been somewhat reduced from the original draft, TransLink’s role is still a significant one. Allowing an unelected body to be defined in the RGS as an “Affected Local Government” with the same standing as a municipality is fundamentally wrong. The legislation that has given TransLink rights to fund transit through development under a “Hong Kong model,” and which also sets out the regulations for the Regional Growth Strategy, was created and enacted without any public consultation. The legislation needs to be changed, including a full public consultation on the matter, before a new regional plan should be considered.
The general public have not been adequately informed or included in the development of the RGS. Just because it took a long time to negotiate the RGS does not mean there has been adequate consultation. It has mostly been a back room deal negotiated by the municipal planning departments. Last summer the Directors of Planning throughout the region met weekly for 15 weeks and made many changes. When the revised RGS was released in September 2010, there were no public meetings. The public hearing was only held in 4 of 22 municipalities with very little notice or publicity. There was no hearing in the City of Vancouver, even though this was requested by members of the public. The adoption process as set out in legislation is too restrictive and not inclusive.
Given the lack of consultation with the citizens of the City of Vancouver, the inadequate public hearing process and the significance of the changes the Regional Growth Strategy would entail, the City should request a delay in the further consideration of the proposed Regional Growth Strategy, further to section 857(4)(b) of the Local Government Act, to enable a proper assessment of the complex issues that the document raises and the appropriate City response. A major change of land use policy such as this should go to referendum.
On behalf of the Steering Committee
Neighbourhoods for a Sustainable Vancouver