More on the OCP Update survey

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I recently wrote a short blog post about online, self-selected surveys like the current OCP Update survey – pointing out that they are only one element of a much larger engagement process, and are useful but not central to Council decision-making.  

Since that time, City staff responded to a letter from a Neighbourhood Association, and that response provided a lot more information. 

So I’ve shared the staff response here, I’ve removed the name of the organization, but am happy to insert it if the organization asks me to.

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“As an attachment to the direct email response to the April 2, 2024 letter on behalf of __ concerning the 10-year OCP Update process, below please find responses to the specific concerns and suggestions outlined in the letter. 

Understanding the Engagement Approach 

The letter on behalf of __ suggests there was a “decision to preclude neighbourhood consultation.” Note that this is not the case nor was it ever the intention. All community members, from all neighbourhoods, are welcome and encouraged to participate in this process. There are (and will continue to be more) diverse mediums for people to participate. Pop-ups are planned throughout the city to ensure local communities are reached. Neighbourhood association boards, CALUCs and staff were invited to an early outreach session together with other diverse community groups and organizations prior to the engagement launch. These groups will continue to play a role in helping the City hear from a diversity of voices.

The letter also outlines concerns related to the survey, addressed specifically below. However, it is important to first recognize that engagement for an OCP is complex and nuanced. The survey is only one element of the engagement process. Feedback will also be collected at open houses, pop ups, online sessions, other focused conversations with the community and ultimately, at the public hearing. What is paramount in this process is inclusion and equity of engagement, including through multiple, accessible and diverse platforms, per the City’s Engagement Framework

Council will be provided with a summary of feedback collected from all channels and will consider that together with technical information, professional advice and with the guidance of established policies and legislative requirements. 

Place-based Planning 

As part of the OCP update, the City will consider key directions from current neighbourhood plans to ensure each area of Victoria can grow and maintain its unique identity while still aligning with OCP framework. We recognize that __ is one of the communities that has not recently undertaken a local area planning process and this is the role of place-based planning, which is a key component of the OCP update. You can learn more about this component of the process on the Places and Spaces Engage Page

In short, place-based planning will be an opportunity for people who live, work or spend time in __ to come together and consider unique opportunities, challenges and ideas for the local area in the context of the broader OCP update. It will include a collaborative planning session with community members, planners and urban design professionals to brainstorm the future of building design, public spaces and community connection. It will result in refined directions for villages, urban design, mobility and public space in the context of the emerging OCP directions. It will explore unique opportunities for urban design and amenities near villages, transit and gathering places, better connections for walking and rolling, and ways to enhance and integrate open spaces and greenery in the city. 

Addressing Specific Concerns Outlined in the Letter 

1) The survey is improperly constructed, in several respects:

a. It does not provide a “none-of the-above” or “prefer not to say” options in most cases; only by trial-and-error would respondents learn that they do not have to respond to every question. 

As recognized above, participants can skip questions that they care not to answer. However, this is not the City’s preference. Even, and especially, if a suite of alternatives is difficult for a participant to choose from, the City wants to know the community’s preference. Indeed, weighing difficult trade-offs is an important part of any meaningful engagement.

b. It appears to be available as an on-line survey only, making it difficult or impossible for those without online access to respond. 

The survey is available in print form upon request. City staff are happy to arrange this option with community members if the circumstances are appropriate. 

Inclusion and equity are core to the City’s engagement framework. The City has observed that online surveys are the preferred method by the majority of participants and the online approach reaches the greatest number of residents, including those community members who have historically been hard to reach and are often underrepresented. It is also worth noting that completing the survey online, through the City’s engagement platform, allows for more consistent review and analysis of feedback. 

The online survey is the preferred approach, but paper surveys can be made available in specific circumstances as requested.

c. It contains vague, aspirational statements that cannot be verified a-priori, and thus outcomes will be difficult or impossible to assess. 

The planning horizon for the OCP update is 2050. It is inherently aspirational and contemplating complex topics over which the City has varying degrees of influence. For example, the City plays an important role in housing solutions primarily through its land management policies and regulations. However, the City does not build market or non market housing and much of Canada’s housing is realized by private property owners and developers. There are multiple decisions and actions that result in the provision of housing, housing tenure and housing affordability, and many are outside of municipal control. 

The “aspirational” statements in the survey convey a truthful reflection of the City’s role and the potential impact of that role decades into the future. The trade-offs described in the survey are objective, based on technical analysis and were written to be clear and to the point, so that all community members (regardless of their time and capacity to navigate a complicated policy framework) can provide meaningful feedback.

d. There is no indication of when the survey will close, suggesting the survey is open ended, which it certainly is not. 

Project timelines are on the website. The text on the website also notes specifically “Until September 2024, we will be in your community and online talking with you about housing, community and climate and how you see your city changing and growing into the future.” 

Community members will have until September to complete the survey and several more engagement events are planned between now and then. 

2) The survey from the outset is not aligned with the Provincial Legislation

a. Question 1 refers only to the number of storeys (at least four, and minimum six in some or all areas). The legislation, however, mandates the minimum number of dwelling units required per lot, not the number of storeys as specified in the question. Why is the emphasis on “storeys” and not “dwelling units”? 

The Small Scale Multi-Unit Housing (SSMUH) legislation was one component of the recently enacted Bill 44 Housing Statutes (Residential Development) Amendment Act. Another component, informing the OCP update and Zoning Modernization, is the Bill 44 legislation related to pro-active planning

This new pro-active planning legislation requires municipalities to: 

  • Identify municipal housing needs currently and over the next 20 years
  • Update their OCPs to identify areas for residential development to meet needs for at least 20 years
  • Align zoning bylaws with the OCP, including to permit the use and density to accommodate the total number of housing units needed for at least 20 years

The OCP update is proposing a land use framework that can meet these new requirements in a manner that is aligned with Victoria’s context and values. The resulting policy and regulatory framework would not emphasize a maximum number of units on a lot, but rather the forms and scales of development that would be accommodated, which is why that is the emphasis of the question.

b. The first question also embeds the notion that four storeys and upwards are the only available options. However, guidance to the legislation states: “…local governments should consider allowing at least three storeys and a height of 11m in restricted zones…” Why was the option to allow three storeys omitted from the survey? 

Again, the three-storey guidance is related only to the SSMUH component of the legislation. SSMUH or Missing Middle housing is an important housing form and is already permitted in Victoria’s existing land use framework. However, it alone will not meet the city’s housing needs – neither for the total units needed (34,600 out to 2050) nor the diverse types of housing needed (it is unlikely to yield new rental housing supply). 

The proposed OCP directions were informed by work the City commissioned to identify population growth and housing needs out to 2050 and analysis to determine how to best accommodate these needs while meeting multiple objectives. This analysis is described in a high-level summary in the survey itself and the growth projections and analysis are discussed in greater detail in the February 8th report and presentation to Council for those who want to know more. 

Victoria is a built-out city with high land costs which means there are limited ways in which we can reasonably accommodate current and future housing needs (as we are now required to do per the pro-active planning legislation). The choices provided in this question represent the most viable approach to catching up and keeping up with housing needs. The choices provided are also aligned with existing City policy (developed in part through previous public engagement) and the directions in Council’s 2023-2026 Strategic Plan related to housing, mobility and climate action.

c. There is no mention of heritage preservation or conversion of heritage properties until Question 16 (where “early settlement” is the closest “value element” to heritage). Heritage properties and conservation areas are specifically exempted from the legislative requirements, yet the survey does not mention what options might be available for conversion and rejuvenation of these properties and areas. 

The City’s current policies and regulations already allow for conversion of existing buildings to accommodate more units. Conversion is supported in Missing Middle and House Conversion regulations. The City also supports retrofits of existing homes and multi-unit buildings to be more climate-friendly. The OCP engagement process is not looking to rethink these established directions. 

3) The maps linked in the survey show concepts that appear to have been developed arbitrarily without input from Neighbourhood Associations or residents

a. The “Centre and Village Zones” map linked under “Urban Structure Concept” shows expansion to existing villages and proposals for new village boundaries that appear novel. There is no justification provided for re-designating these areas, nor any indication of who proposed their re-designation. 

In the survey, in the preamble to the questions related to villages and centres, it states: “With a growing population, Victoria needs to accommodate more space for new shops and services throughout the city. Proposed OCP updates include designating three more diverse, walkable and densely populated Town Centres close to transit, at Jubilee, Stadacona (Oak Bay Junction) and Midtown. The addition or expansion of Community Villages and Local Villages is also proposed.” 

For those interested in additional details, the February 8th report and presentation to Council describe the retail assessment that informed the proposed village and centre expansion areas. The engagement currently underway is the opportunity for the community to provide feedback on this, and all proposed concepts. 

b. “Local Villages” are not well-defined in the map nor in the survey, so respondents lack information to make meaningful decisions regarding them. 

The links in the survey provide additional information about all concepts, including local villages, for those who are interested. Links are provided in the survey and on the engage page to The Emerging Policy Framework, the Urban Structure Concept Summary, and the Zoning Modernization Summary

c. The __ in particular was unaware of these proposals, and many residents hold strong opinions as to whether or not their properties should be designated “local village” instead of “traditional residential”. 

The City welcomes this feedback. If there are specific ideas or concerns that could not be communicated in the survey, community members are welcome to share at any of our upcoming events or by email at OCP@victoria.ca

Additionally, villages will be a key area of focus during the upcoming __ place-based planning and an opportunity for diverse community members to discuss the future of these important areas. 

4) It does not reflect nor respect the City’s diverse nature, nor its context in the CRD

a. Although the survey asks respondents to indicate which neighbourhood they are from, it does not differentiate between neighbourhoods nor does it respect the unique needs and attributes of each; rather, it blankets them all into a monolithic whole, which will undermine neighbourhood feel and character. 

The principal tenet of this process is one city, one plan. The OCP update recognizes that Victoria, like cities across North America and beyond, is facing complex challenges related to housing, equity and climate change. This process builds on many recent conversations the City has had with the community related to these challenges to identify and implement Victoria-unique solutions. Doing so requires the community to come together as a whole. 

That said, the City fully recognizes that part of what makes Victoria special are the unique local places and spaces found throughout. This recognition is a key reason that place based planning was included as a component of this citywide process. While the directions developed through recent local area planning processes will need to come into alignment with the final outcomes of the OCP, there are many concepts at the local scale that will be retained or elevated to support local identity, needs and aspirations. Some areas, including ________, have not had the chance to develop those unique local ideas, and that is the role of place-based planning.

b. With fewer parking spaces mandated and fewer lanes on City streets, integrated public and commercial transit will become vital, yet the survey only refers to transportation needs within the City itself; there is no indication of how transit systems and traffic movement will be linked to neighbouring municipalities and mass transit services, which are regional.

Transit operations, services and routes in Victoria are the responsibility of BC Transit. Many of the decisions regarding transit services and funding in the Victoria region are made by the Victoria Regional Transit Commission. The City of Victoria supports transit provision through land use planning, investments in transit-oriented infrastructure, and development that supports transit viability and contributes to facility and service level improvements. 

Go Victoria, the City’s sustainable mobility strategy describes key multi-modal goals and the importance of expanding and improving Victoria’s transit infrastructure. The directions proposed as part of the OCP update were strongly guided by Go Victoria’s goals and objectives, specifically: 

  • Enable land use that supports transit investment, including by focusing new housing and commercial uses along transit routes and around mobility hubs (where multiple mobility options converge). 
  • Support the development of a waterways network and water-based transportation integrated with the broader transit system. 
  • Incrementally repurpose road space for sustainable transportation and a network of linear parks, where new approaches to streetscape management and design will help realize social and environmental objectives.”