City of Victoria Response to Missing Middle Questions

Dear reader: please note I do not have a professional editor. There is a high probability you will find typos and grammeros. If you do kindly pop me a note so I can correct them. It is a much nicer approach than making fun of me for not being perfect.

On July 11, 2022 I sent an email to the City of Victoria asking if they might provide more information on the Missing Middle Housing Initiative. Below are the questions I sent along with the city’s response in italics.

1  How many homes in Victoria are currently designated as single-family house and what percent of overall homes in Victoria do they represent?

Our analysis provides an answer about the zoning and designations on a parcel-by-parcel basis; of 13,831 parcels designated Traditional Residential by the Official Community Plan, 11,162 of those are also in one of the four common zones (R1-A, R1-B, R1-G, or R-2), and would thereby be potentially eligible for the proposed missing middle regulations (provided they are not subject to the other caveats as summarized on page 9 of the information boards). Please see the next response to address the second part of this first question.

NOTE: 11,162 single family homes could become multiplexes over time

2. How many of these single-family homes host more than one family? 

The census is the best source to look at for this question since we do not have complete information for the number of ‘single-family’ lots that host more than one family due to some of these living arrangements being informal or unauthorized. Our Victoria Housing Needs Report 2020 (page 17) provides a relevant summary of this census data, stating: “as of 2016, there were 45,765 dwellings in Victoria. Compared to the CRD as a whole, Victoria had a lower proportion of single-detached houses. Fourteen percent (14%) of dwellings were single-detached houses and 10% apartment in a flat or duplex (Figure 15). Apartment or flat in duplex refers to single-detached houses with secondary suites. Usually, half of the units recorded as apartments or flats in a duplex (approximately 2,245) are assumed to be single-detached houses with secondary suites, while the other half are the suites themselves.”

NOTE: The city does not know how many single family homes are multi-family dwellings or how many people live in them. They are looking at moving forward with a policy without understanding who it will impact.

3. How many families currently living in Victoria are looking for a home with more than 2 bedrooms?

As per the most recent Census data for the Region of Victoria there are currently 40% of regional households that have 3 or more persons. Although, it may not be all of these households who need a 3 bedroom home, it is likely that many people are now partly working from home and may be using an extra bedroom as an office in addition to bedrooms needed for children amongst those households with kids at home. Further, the City of Victoria has seen very low levels of Building Permits issued for Missing Middle Units. Only 2% of units issued BPs in 2021 were for Missing Middle Units, most of which would be 2 or 3 bedroom units.

NOTE: The city does not know if there is an need for 3 bedroom units yet they are looking at enacting a policy that a may replace 11,162 homes. This new development would lead to the loss of a significant number of residential trees in our urban forest. 

4. How many families currently living in Victoria who are looking for a home with more than 2 bedrooms can afford a $900,000+ mortgage?

Currently in the CRD there are 52,050 households with a household income of $125,000 or greater, roughly 30 per cent of households in the region. These households are all households that are likely to pursue some form of homeownership (condo apt, missing middle, single-detached etc). It is helpful to look at regional population in this regard as people often look across the region when purchasing housing.

NOTE: Based on the current market, Missing Middle Town Homes will likely cost $900,000+. First time home owners earning $125,000 can afford a $500,000 mortgage. These homes are out of reach for the majority of residents living in Victoria and the CRD.

5  What efforts is the city making to provide affordable housing for those who do not qualify for the $900,000 mortgage?

The Missing Middle Housing Initiative is one piece of the housing puzzle, and one of over 40 actions in theHousing Strategy. All together, these actions are aimed at addressing the wide spectrum of needs throughout the housing continuum. For more on this, I’d recommend reviewing the graphic on the second page of theInformation Boards.

NOTE: Single family lots used for high-end town homes will ultimately lead to less land being available for affordable housing for current residents of Victoria.

6. What protections does MMHI offer people who are displaced through demolitions for new builds?

We are using all available municipal powers (e.g. partial development permit fee refund where tenant assistance is provided, and requirement for new secondary dwelling units), and advocating for more capabilities to help mitigate the potential for tenant displacement to result from redevelopment of existing detached houses with secondary suites. Consideration of this issue highlighted both a gap in municipal zoning powers, and a challenge inherent in the role secondary suites play in our rental housing system. The secondary rental market tends to provide less housing security than units in the “primary rental market” because homeowners can resume use of their homes, including secondary suites, if they give sufficient notice. The primary rental market refers to purpose-built rental buildings which generally have one owner and professional management of all units in the building. These rental units provide greater long-term security for tenants, which underscores the critical role purpose-built rental housing plays in our overall housing system. This is a key reason the City’s Housing Strategy Phase Two includes a strong focus on renters and includes multiple actions to preserve and revitalize existing rental housing as well as actions to incentivize and facilitate new purpose-built rental housing. As mentioned, the City is advocating for legislative changes to enable tenant assistance requirements to apply beyond rezoning applications, which would provide strengthened assistance requirements relative to the fee refund approach currently proposed. Despite the above-noted challenges, the proposed zoning for missing middle housing can help ensure no net loss of potential secondary rental market units through the proposed requirement for at least one accessory dwelling unit (suite) to be included in a corner townhouse or houseplex development. In addition to their potential to contribute to the secondary rental market, accessory dwelling units can also provide flexibility for families who need to accommodate a family member, care giver, or meet other evolving needs of their household and can provide a “mortgage helper.”

Note: I don’t see any concrete protections for people displaced through the Missing Middle Housing Initiative. Do you?

7. How many house-plexes and townhouses do you anticipate will be built in Victoria in the next year? In the next 5 years?

The Victoria Housing Strategy Annual Review 2021 is set to be presented to Council this Thursday, and pages 57 and 58 provide an update on the pace of missing middle housing creation. Over the past decade, the pace of new missing middle home creation has consistently been well below the target rate of 167 units per year, with only 21 net new units approved via building permit in 2021. The financial analysis undertaken as part of the Missing Middle Housing Initiative suggests that even though regulatory changes that eliminate the rezoning process would be a major step in reducing barriers to creating this form of housing, the small scale of these projects make the viability marginal in most cases. Thus, the pace of construction is expected to continue to be relatively modest, even if supporting regulatory changes are adopted.

Note: The City of Victoria does not know what the impact of it’s Missing Middle Housing Initiative policy will be on densification.

8. What is the expected city tax revenue from these new dwellings in the first year? And the 5th year?

It is up to Council to set tax rates. While we have not attempted to anticipate future tax revenues as part of this initiative, the approach of applying new regulations in as broad and even a manner as possible across Traditional Residential areas is recommended, in part, because of its potential to avoid creating disparities in taxation that might result if applying different regulations to a smaller set of parcels relative to the broader class of otherwise similar parcels.

Note: The City of Victoria has not reviewed the impact of it’s Missing Middle Housing Initiative policy on city taxes.

9. How many trees do you anticipate will need to be cut down to make room for missing middle housing in year 1? And by year 5?

As summarized on page 13 of the information boards, the proposed zoning regulations are designed to facilitate tree retention and long term health of large canopy trees, even where the don’t yet exist. This is designed to dovetail with the recently adopted Tree Protection Bylaw, which establishes requirements for tree retention, replacement, and even minimum tree counts per property (even where no trees currently exist on a lot). Together, these regulations will help support the continued growth of our urban forest canopy, even as new housing is created through redevelopment. We do not have specific estimates of future tree removals, replacements, and plantings as each site has unique considerations and tree management and replacement plans need to be worked through with staff for each case.

Note: The Tree Protection Bylaw states that a tree may be removed if the trunk of the tree is located within the building envelope and the removal of the tree is necessary for the purpose of constructing a building and 2) property owners will be required to pay $2,000 cash-in-lieu for each replacement tree or tree seedling that cannot be accommodated on the site. 

The following is an image of a plan for what the developer identified as “Missing Middle Housing. Each red dot represents a tree that was removed. The developer only required a permit to remove 2 trees. There is no protection for the urban forest our tree canopy based on the current proposed policy.

10. In her blog, Lisa Helps suggests the city is proposing missing middle housing to provide housing options for “people we need to attract to and keep in our communities – doctors, nurses, police officers, tradespeople, and others who are essential to our community wellbeing and economy”. What steps if any is the city taking to ensure this housing is available to those she is targeting? How will the city measure this?

I believe those profiles were cited as examples of the kinds of people searching for these housing forms. Aside from when households need to confirm their incomes to qualify for affordable or below-market housing, the City does not control who can buy and rent housing based on their type of profession or other attributes.

11 What steps is the city taking to ensure schools and community organizations are able to manage the increased capacity and workloads in the areas of the new builds?

The City shares land use planning (e.g. Official Community Plan designations) and population projection information with the School District to support their future capacity planning. The MMHI is implementing regulations for the ground-oriented forms of housing that the Official Community Plan has supported and anticipated since its adoption in 2012.

Note: See question 7. The City of Victoria does not know what the impact of it’s Missing Middle Housing Initiative policy will be on densification.

12. Has the city considered the impact on our local transportation network? What plans have been put in place to manage anticipated increased bus use?

Yes, the City continues to consider the impacts of population growth and new housing forms on all elements of our local transportation network. BC Transit service levels, routes, and programs are determined by the Victoria Region Transit Commission. The City will continue to advocate for investments in increased public transit service and programs to support new riders through its participation on the Commission. The City will also continue to support transit through its own infrastructure investments in transit stops and shelters as well as traffic signals and allocation of public right of way on roads.

Note: See question 7. The City of Victoria does not know what the impact of it’s Missing Middle Housing Initiative policy will be on densification.

13. My local grocery store is already overly busy. Does the city have plans to bring new businesses into the areas impacted by densification? How will the city encourage new business and where will they be situated?

The Missing Middle Housing Initiative is one part of the City’s work to support more complete, compact, and connected communities. As more people can stay in the city while their housing needs evolve, local business can grow and thrive with the support of more local customers. The Official Community Plan also includes policies supporting the continued evolution of our Urban Villages, Town Centres, and Core. Through Local Area Planning, we are considering areas where new commercial and retails spaces can evolve, including opportunities for larger format grocery stores in areas where they are needed.

14. Many in Victoria have no family Doctor, clinics have closed and when they are open wait times are long. As you increase densification with MM what steps are being taken to make sure EXISTING AND NEW residents have access to doctors and medical treatment when needed?

The scarcity of family doctors is a matter we need the Province and Federal government to meaningfully address. We understand, however, that the high cost and lacking availability of suitable housing options in Victoria is one of the factors leading doctors and other workers to look for work in other communities.

15. What role has Luke Mari from Aryze played in the development of the Missing Middle Housing Initiative? 

Representatives from Aryze participated in some of the workshops we held with housing builders during the two previous phases of engagement on this project.

16 Based on the current documentation, MMHI approvals will be made by staff in order to “get council and the public out of the way.” Who are the people who will make the decisions, what are their qualifications, and who will they be held accountable? What avenues will members of the public have to express an opinion on a development that affects them?

If Council adopt regulatory changes that eliminate the need for a rezoning process on each missing middle housing proposal, then there will not be public input required on each application that follows the regulations (i.e. where no variances are requested as part of the application). Therefore, we have undertaken multiple rounds of community engagement on these draft regulations, and a public hearing is required before these regulations could be adopted by Council. Council can delegate approval of Development Permits to the Director of Sustainable Planning and Community Development. Through their consideration and potential approval of the Missing Middle Design Guidelines, Council provides qualification of how the delegated approval decisions should be made – i.e. the Director can approve based on confirmation of compliance with the Council approved design guidelines. Delegation of approval authority for some or all types of Development Permits is a common practice in BC and many other municipalities have done so where missing middle housing forms are permitted within zoning. Through the proposed regulatory changes, delegated approval would only be possible where applications do not request any variances relative to the regulations Council adopted and have demonstrated consistency with the design guidelines.

Note: Should the Missing Middle Housing Initiative go through, residents will not long have a say in where multi-plexes go or what they look like in their immediate communities.

17. Has the City of Victoria consulted with our local police and firefighters to discuss and plan for the impact of the increased population. If yes, what were the results of these discussions?

Council regularly considers the City’s budgetary needs to maintain the services our community depends on, and updates tax rates accordingly.  The capacity planning for these services are informed in part by the future envisioned through the City’s Official Community Plan. The Missing Middle Housing Initiative is implementing the support for ground-oriented housing forms that has been a part of the Official Community Plan since its adoption in 2012.

Note: See question 7. The City of Victoria does not know what the impact of it’s Missing Middle Housing Initiative policy will be on densification.

18. Has the City of Victoria reviewed the impact of the increased population on hydro, sewage and water management? If yes, what were the results of each of these reviews?

The City updated our Development Cost Charges in 2020 to ensure that all new buildings contribute to the cost of additional sewer and water infrastructure needs, and BC Hydro determines additional infrastructure needs and coordinates with prospective builders on installation of such infrastructure on a project by project basis.

Note: See question 7. The City of Victoria does not know what the impact of it’s Missing Middle Housing Initiative policy will be on densification.

8 thoughts on “City of Victoria Response to Missing Middle Questions

  1. Dear Susan Simmonds
    Thank you for your excellent questions to council and administration of Victoria. Also for your comments noted at the end of each response.
    The future of Victoria is always on the table but it seems that this radical proposals by the current council Will be profoundly impactful.
    I would be very grateful if you would consider standing in the next election, if only to give your articulate voice to our concerns.
    I do understand that standing for public office is an enormous personal sacrifice. That is why I try not to criticize the personality of any politician, but try to stick to the facts and the issues as part of the dialogue of democracy.
    Again thank you for your work and putting together these questions.
    See you Thursday, August 4, 630!

  2. Thank you Susan! That was thorough and in depth. Thank you for your work of putting this together.
    I also have a few other questions about short term rentals and the use of the Board of Variance for variances in height and setbacks. The BoV is a work around for developers and if we have multi units by right, what’s a couple of feet up or out?

  3. Thank you Susan Simmons. It is obvious to me that this Mayor and Council is not working in the best interest of the people who they were elected to represent. You have my vote should you chose to run.

  4. As I understand it, the decisions of the Board of Variance is the one area that has the power to overrule any decisions around property variances by local councils. I doubt that this power also applies to decisions made by higher levels of government. That could be a big problem if Dave Eby’s threat to legislate removal of any local decisions around land designation away from local municipal bodies ever becomes more than just a threat.

  5. Thanks so much. I see the not-so-fine hand of LM on this, especially leaving out the Council’s right to intervene in extremity and to ignore studies of impacts≥

  6. Clearly, this has not been properly planned. There has not been enough research done and there is certainly no risk mitigation strategy. In fact, it’s embarrassing how bad this is.

    The fact that Luke Mari and Aryze were heavily involved in the process, leads me to believe that there should be a great deal of concern with respect to how valid the “engagement” process was.

  7. Thank you for the time it took for you to put a letter like that together. I ask thou, are you worried more about trees or middle housing initiatives. Your questions about schools etc. is the reason it is difficult for a city or town of any size to make decisions as there is so much to consider. I ask you, can you compose a letter in detail to give answers instead of questions.
    I have had the solution for housing since 2018, but it is something our society does not want to even discuss because most of us already come from a situation like I will now release. The answer is divorce and the demise of relationships over the last 50 years. It is called family. Tell me really what is so wrong with a home filled with generations within the same walls. Over the years divorce rate in Canada has actually fallen which might seem contradictory to my reasoning but we all know that many people don’t get married(live together) anymore, or have close relationships with someone for years and live in 2 different homes. There are so many people that live alone so if 2 people stay together and occupy 1 apt., or house instead of 2, (now do you catch what I am saying). Just so you know I back my words up as I rent my 2 bedroom rental property intentionally out to 4 people and I often rent my second bedroom in the home I live in.

  8. Excellent summary, thank you. I am a MMH provider and view the retrofit of existing housing stock as a context sensitive way to provide more affordable housing. Victoria’s MMHI as proposed does not fit development into context and seems to be another “one size fits all” “fix that fails”. There is important ground work in the effort, imo, as is always required when we pursue options. Some of the importance flows not from answers, but from questions unanswered.

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