Victoria City CouncilVictoria City Hall10 February 2020Re: Next Generation House Conversion Regulations
Dear Mayor and Councillors,
Cities for Everyone advocates for more affordable and inclusive housing and transportation options in our region. We are glad that Victoria is developing New Generation of House Conversion Regulations designed to allow more infill housing to be built in our residential neighborhoods. This is an important and timely initiative. Abundant research indicates that residents of compact urban neighborhoods drive less, save on transportation costs, are safer and healthier, produce less pollution, consume less land, and have better economic mobility (chance that a child born in poverty becomes economically successful as an adult) than they would living in automobile-oriented areas. As a result, residential infill helps achieve our community’s economic, social and environmental goals.
Cities for Everyone advocates the “1.5% Solution” which means that residential neighborhood housing supply should increase by approximately 1.5% annually to match regional population growth rates, in order to accommodate growing demand, increase affordability and achieve other community goals. According to analysis of Victoria’s building approvals, most neighborhoods are adding far fewer homes than needed to achieve this target, as shown below.
The proposed Next Generation House Conversion Regulations can help achieve neighborhood growth targets by reducing the costs and impediments to property owners of adding more housing units. We therefore support the proposal and encourage the city to adopt the “sprint” (strongest) option because it would allow:
- Conversions in zones that currently restrict them.
- Garden suites with conversions.
- Additions that create new floor area.
- Delegated authority for parking variations.
Below are some specific comments and suggestions about this proposal.
- We see little justification to limit conversions to houses built before 1985, since some newer houses are suitable for expansion. Many newer houses are large and were designed for easy conversion, using adaptable housing guidelines such as CMHC’s FlexHousing standard, which allows houses to be upgraded, expanded, divided into extra units, and adapted to new uses.
- The proposed maximum heights (7.6 metre and 2.5 stories) are likely to prevent some potential house conversions. We recommend that this be increased, particularly for corner lots and larger lots where there are fewer impacts on neighbors.
- The proposal only marginally reduces off-street parking minimums. For example, it still requires 0.7 spaces for a small 450 square foot unit 1.0 spaces for a 700 sf unit, although 20% of Victoria households are car-free, and the city wants to discourage car use and increase housing affordability. Many jurisdictions are eliminating parking requirements, or requiring unbundling(parking rented separately from apartments) so car-free households are no longer required to pay for parking spaces they don’t need. Note, eliminating parking requirements does not eliminate parking, it simply allows property owners to decide how many off-street parking spaces to provide based on their specific needs. In many situations, off-street parking requirements actually reduce the number of parking spaces available to residents because each driveway displaces one on-street space. Most residential driveways only serve one vehicle and are only occupied part-time. As a result, adding an off-street space reduces the number of parking spaces available to neighbors. Off-street parking significantly increases development costs, increases impervious surface area and stormwater management costs, and driveways create obstacles to pedestrian, particularly wheelchair users. We therefore recommend eliminating parking minimums altogether, or be significantly reduced, and eliminated where a new driveway would serve just one vehicle.
- We would also like to ensure that residential garage spaces can be converted to living space, as many newer houses have ground-level garages that are not used to store motor vehicles and are well suited for suites with wheelchair/ disabled access.
- The proposal emphasizes the importance of preserving heritage buildings. This is desirable but should be balanced with other community goals. As the proud owner of a 1905 designated heritage home I can report from personal experience that such housing is costly to maintain and operate, and can never be as energy efficient as new housing. Not every older house deserves preservation, and to achieve our affordability and environmental goals heritage preservation should be matched with higher allowable densities on other properties. For example, if 20% of houses in an area are preserved for their heritage value, this constraint on infill development should be offset by increasing allowable densities by 20% on other properties, for example, raising maximum building heights from 2.5 to 3.0 stories.
- To reduce development costs and delays, particularly for smaller infill projects, we encourage the City to delegate project approval decisions, such as reduced parking requirements, to qualified staff.
- On a related issue, we note that many areas designated for multi-family housing in Victoria’s Official Community Plan (OCP) have not be upzoned to allow the density and height required for such housing. We therefore ask the city to upzone all areas designated in the OCP for multi-family housing to accommodate those targets.