My feedback on draft housing affordability recommendations

Here is what I just submitted to housing@victoria.ca in accordance with the guidance provided on the City website specific to the actions of the Mayor’s task force on Affordable Housing. For context on my item specific responses please note that I have simply created a sequential list of the recommendations identified in this short report from the city explaining the need for and proposed sequencing of each recommendation.

If you’re looking for an easier read of these recommendations, please check out the PDF of the recommendations that I previously compiled. Here also a recent article on the workshop that was held related to these recommendations in May.

General comments from Jaclyn with Victorian Analysis

Lots of good ambition and intention. In absence of clear data however it is hard to recognize and or prioritize importance of any particular initiative. For instance, how many complaints have been received about poor quality dwellings that could potentially be enhanced by efforts to tighten up the property maintenance bylaw? Are there any clear numbers on how many affordable housing units are needed? Is there a clear definition of an “affordable unit”? I must admit I’m still confused about the difference between housing types (e.g., supported, affordable and subsidized). If more information was provided to justify each particular recommendation then I think you would also be more prepared to establish a logical sequence between efforts for the years 2016-18. As is, proposed sequencing is somewhat confusing.

Where I recognize that Mayor Helps is on record as saying “easy wins” are put forward for 2016 I think more time needs to be spent on bundling proposed recommendations into key topic areas within the two themes because then a more logical affordable housing business case could emerge. For instance, all parking related items should be considered and presented together – same goes for zoning related items, fees and charges related items, housing reserve related items, landlord and property maintenance issues, and land and real estate related items.

Once this information is clarified, maybe a professionally conduced telephone polls of residents and businesses may be an appropriate way of fully establishing City wide relevance of any particular issue.

Particular comments

  1. Minimize & prorate fees for affordable housing…
    • This should be considered together with DCC charges – similar to how there are charges for residential and commercial perhaps there could be a category of charges established for affordable housing? A tight affordable housing definition would be needed though.
  2. Allow for higher density and greater heights in exchange for…
    • A clear and supportable definition of affordable housing is needed as well as neighbourhood supported clarification on necessary services/provisions/accommodations associated with effective affordable housing.
  3. Create an inventory of publicly & privately held land…
    • This seems like a reasonable and easy thing to do. It should then be clearly tied into other land related items including the proposal for a real-estate function and the proposed recommendations for real-estate transactions. Only make land available for long term leases. Don’t sell it.
  4. Review the Victoria Housing reserve allocation of …..
    • Again – need clear definition of affordable housing. I thought the reserve was only for supported housing? Please clarify.
  5. Investigate options to expand the capacity of the Victoria Housing reserve….
    • Again – need clear definition of affordable housing. I thought the reserve was only for supported housing? Please clarify.
  6. Expedite conversion of motels and other transient accommodations….
    • Before doing this, I would like to see a report on the efficiency and effectiveness of past city efforts in this area? What has been successful and what hasn’t? Might there be other community partners who are better equipped for facilitating such a process?
  7. Designate a City Housing Officer as a lead City Liaison….
    • I did not know about this RESPOND program. Sounds interesting. Still not convinced though that the City should be the lead proponent? Might there be appropriate fee and penalty provisions within the terms of this program to allow the City to recoup related costs? If so, then I can support this.
  8. Review and strengthen Property maintenance bylaw….
    • Sounds like a good idea. I would like to see data though on the actual priority of this item from a resourcing of bylaw services perspective. Will this data be coming out of the bylaw services audit that I believe is scheduled for 2015? Related to my comments made on item 7 I would also like to see proof of the City’s ability to recoup appropriate enforcement costs from negligent landlords.
  9. Investigate opportunities for the City to support the development of affordable home ownership programs….
    • I remember reading something about a similar program supported by the City of Victoria which seemed like a good idea. Suggestions and recommendations could then be tested in a telephone polls of city residents.
  10. Expedite development approval and permitting process….
    • This is not an appropriate topic for 2016. More research and agreement on what could be feasibly delegated or expedited first is needed. Also, with the city’s new neighbourhoods team I imagine that some time will be needed as everyone gets used to new relationships and responsibilities. 1) I DO NOT support by-passing CALUC pre-meetings. 2) Delegating of approval authority may be appropriate once Zoning amendments specific to Conversions are clarified – clarity needed first. 3) With respect to giving “priority” clarity is needed both on what this means in terms of expediting and as well, clarity is needed on what affordable housing projects are and why they should be expedited. A clear definition is needed.
  11. Waive development cost charges (DCCs) for affordable housing projects….
    • Similar to my response to item #1 I think development cost charges should be considered with other development fees. I don’t think they should be waived but perhaps a lesser fee requirement could be established. If fees are waived completely then the City is indirectly subsidizing affordable housing. Perhaps the issue of development related fees will come up in review of the Housing reserve and City fees could be seen as a secondary and or related way of supporting/facilitating affordable housing?
  12. Remove the minimum unit size requirements for multi-unit zones….
    • I think more research is needed on what this might look like. Parking could become a huge headache very quickly in areas where conversions occur. .
  13. Amend Schedule G-House conversations….
    • Within reason I think this is a good idea because some houses are more appropriate for conversions than others. I would like to see more research on this. Related to this, research will be needed on what appropriate cost categories and requirements will be from a City development and enforcement perspective because of the complexity of such projects.
  14. Reduce parking requirements….
    • These numbers seem arbitrary. Is it possible to provide some numbers on parking levels permitted at recent developments and to also look at what the traffic situation is in the neighbourhoods around these developments first? From a sequencing perspective, it seems more logical to explore item 18 (innovations in parking requirements) prior to reducing parking requirements. Proactive innovation makes more sense!
  15. Remove rezoning requirement within Garden Suite Policy
    • If I were a homeowner I would be really opposed to this item because what if I brought my property because I have young kids and I want them to play in our big backyard and my kids become unable to play in the backyard because my neighbour builds a garden suite that both wrecks the experience of my backyard and also makes it inappropriate for my kids to play in since the new tenants of this garden suite are dodgy? It wouldn’t be unusual for my neighbour to also have a big backyard in this context. Garden suites are a big change and require neighbourhood consultation and approval. Clear yard size minimum requirements and garden suite size restrictions would also need to be retained.
  16. Remove the restriction within garden suites policy that prohibits the development of garden suites on properties with secondary suites….
    • I can support this one so long as clear specifications are established for yard and house size minimums (e.g., your house and yard has to be a certain size). I also have to wonder who would want both a garden suite and secondary suite? Would the owner live upstairs and rent the downstairs and garden? Or would all three suites be rentals? Idea sounds good but also sounds like the requirement could also be easily taken advantage of. Is data available on current existing rentals and city application made but rejected as a well of getting a sense of need for such a setup?
  17. Amend schedule J – Secondary suite regulations by eliminating the minimum size requirements…..
    • Does the city have any data on # of legal and illegal suites? Could this be associated with re-introduction of the secondary suite renovation grant program? If size requirements are removed, I would think some criteria for servicing and amenities would have to be introduced so as to ensure a minimum quality of liveability (for instance bachelor suites with only basic kitchens versus proper suites with full kitchens).
  18. Consider a variety of innovations such as facility sharing, unbundled parking, increased density, and use mix, transit accessibility, car sharing options…..
    • As per my response to # 14 I would like a report on possibilities related to this item to come to Council before the City contemplates reducing parking requirements full stop.
  19. Direct City staff to report to Council with recommendations on implementing inclusionary zoning….
    • I support feasibility reports. I don’t quite understand though how this will be different from previous efforts and or the current situation. Related to this, can some Zone standards be established to move the city away from continuous spot-zoning?
  20. Contribute land at no cost or at reduced market value for the development of affordable housing projects….
    • I don’t support this. Think its a bad idea. As per the advice given by the one fellow at the workshop, land should only be made available on long term leases in accordance with best practices.
  21. Create a real estate function within the City’s administration that can purchase and sell property for the purpose of creating affordable housing.
    • I seem to recall that similar item related to the City Real-estate function will likely be a recommendation from the economic development task force. That said, I don’t support this item because I don’t see the need for it – very cart before the horse. If there is a need, a clear case should be made by the City. Related to this, what would the expectation be for public transparency of this new real-estate office because I know that the majority, if not all of the City’s real-estate related transactions occur incamera meetings. Which is to say, a City real estate arm is only supportable if it is transparent.
  22. Create incentives that support converting under-utilized or unused spaces above commercial properties into residential use.
    • This could be good. Depends on landlord and owner support as well as the potential livability of certain places. What would associated rezoning requirements? If anything, I think this item would actually be an “easier win” that garden suite rezoning because 1) fewer neighbours to worry about and 2) these buildings would likely be closer to necessary services the garden suite dweller in a residential neighbourhood would be. In sum, this item could be an effect 2016 item I think.
  23. Investigate and implement appropriate incentives (e.g., grants, tax credits, loads and or loan guarantees, lowered development fees for adding units to existing rental stock) that can assist landlords in maintaining and or improving affordable market and non market housing.
    • I don’t support this. Seems super dodgy and just an excellent opportunity to facilitate things like renovictions. This is too far out of City jurisdiction that it is just a bad idea.
  24. Develop policies and procedures for establishing affordable housing agreements…
    • I support this.
  25. Review the Zoning regulation bylaw to ensure it accommodates a variety of housing types…..
    • Don’t know what this means – seems like it would come out of the other zoning related items and recommendations? Please make an effort to group recommendations by topic (zoning) so they make more sense. If they make more sense, you could get better public support and also have a better chance that these items would actually be implemented. Lastly, is it not false to say the city is “planning a review” when Council recently rejected a staff motion to fund a zoning bylaw review?
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