To Land Use Committee:
Re: Land Use Committee, April 1, 2014 – draft OCP
The draft OCP, as currently written, would dramatically change the character of Port Moody, and proposes changes of a scale never contemplated previously, or at least not in the public realm.
Following are some of the reasons this draft OCP should not be adopted.
This proposed plan is not supported by the majority of residents, who have voiced a range of concerns. The city has no evidence to indicate majority support. I have asked for statistics to confirm the city’s assertion of support for the plan, but have received nothing. My own review of feedback to the city supports the assumption that majority support for the plan does not exist. In addition, during the last civic election council supported the vision of Port Moody’s “small-town character” and vowed to control development; there was no indication that a radically different vision for Port Moody would emerge with the “re-opening” of the Official Community Plan.
The OCP is not just a “vision” – once adopted, all other bylaws including zoning must be updated to align with the Official Community Plan. The OCP has very real legal ramifications. [Local Government Act, section 884: “All bylaws enacted or works undertaken by a council … after the adoption of an official community plan … must be consistent with the relevant plan.”]
If this draft plan is adopted, it will be extremely difficult to change, and the city may be at risk of lawsuits if it tries (e.g., to “down-zone” in the future due to unintended consequences).
The city has never provided a business case – triple bottom line cost/benefit analysis (social, economic, environmental) for this plan.
Faulty premises and assumptions
The Evergreen Skytrain line is cited as a primary reason for updating the OCP to allow for a 300-400 percent population increase (or possibly more) in the city-identified Evergreen Line “sub-areas” – all of which are located within a relatively small area in Port Moody; specifically Moody Centre and Inlet Centre areas.
Densification and transit-oriented-development were never requirements for the two Port Moody Skytrain stations. Port Moody is ahead of its regional growth commitments. The station locations were chosen because one has already densified, and the other is an existing transit hub.
There seems to be an assumption that Skytrain will somehow fix all of Port Moody’s congestion problems. What are the hard numbers to support this? How will Skytrain alleviate road congestion, particularly if more population is added to the city?
Growth and measurement tools
Port Moody and Surrey have been the fastest growing cities in BC , and Port Moody is in the top 20 in Canada overall. Port Moody sets its own population targets, and submits the information to Metro Vancouver.
Without tools to measure growth, such as units per acre, site coverage, floor-space-ratio, the growth predictions are meaningless. Density bonusing adds another layer of uncertainty. This draft OCP lacks any meaningful measurement tools.
Environmentally sensitive and hazardous lands
Much of Moody Centre is rated environmentally sensitive and moderate to high-hazard land. The soil type is similar to that of where most of the damage (and loss of life) occurred during a recent earthquake in Christchurch, New Zealand – at high risk of soil liquefaction in the event of an earthquake. Higher buildings and density pose higher risks. Much of the slopes surrounding the lower land in Port Moody are environmentally sensitive, and there is an increased risk for land slides with development and deforestation. Port Moody has experienced land slides including the Chines slope and the north shore. Many areas of Port Moody are also identified as prone to flooding, and drainage is an important consideration.
Infrastructure, including parkland
The Evergreen line does not compensate for the lack of other infrastructure, and will not ease road congestion. If more residential units are added, road congestion will worsen, even if some residents take public transit most of the time. This has many impacts, including air pollution and emergency movement of vehicles.
There are no clearly identified plans to increase parkland; particularly city “destination” parkland. “Pocket parks” if they do occur are not an adequate substitution. Moody Centre has a deficit of destination parkland. The Chines slopes, identified as green space, is not useable parkland; the area is essentially steep and undevelopable so remains treed but not an area for people to gather.
Moody Centre parkland has not expanded to accommodate recent growth in the city (notably Klahanie and Inlet Centre).
Supporting plans such as parks and recreation and transportation are out of date (and should be completed prior to adoption of an OCP).
Public space should remain public space – not rezoned. This includes the Kyle Centre area, and also the Moody Elementary site that school district 43 has decided is surplus to its needs. Any changes to public land should go to public referendum.
Industrial lands need to be preserved as much as possible. These lands are important economic generators (goods and services and employment), and also balance the land use in a city. Industrial lands are also a priority for Metro Vancouver.
Rail corridors are important to the region and economy, but high density residential in close proximity to rail can also pose risks (e.g., air pollution, transport of hazardous goods).
Alternatives to consider
Prepare a business case to identify costs and benefits.
Place more focus on more development of business growth and job-creation.
Capitalize on Port Moody’s unique geography and heritage (e.g., tourism, employers).
Develop a clear policy regarding how much parkland (all types) is required per 1,000 residents, and how the city would achieve its targets.
Develop and require measurement tools to track how goals are being met (or not).
Complete supporting plans (e.g., transportation, parks and recreation, emergency preparedness, and others) prior to adoption of a new official community plan.
Place less emphasis on high density residential.
Some residential growth could be accommodated in Moody Centre with three to four storey buildings, particularly on the north side of St. John’s Street, as was agreed upon during discussions prior to adoption of the current OCP in January 2011. The buildings could be a mix of business (including retail) and residential. This would be “human scale” and would be more in keeping with the vision of “small town character.”
Infill such as laneway homes can also provide more housing, but without overwhelming a community such as what could occur if the proposed OCP is adopted. The draft OCP accommodates this type of infill development.
Infill secondary suites were approved in Port Moody about 10 years ago, as a way to allow additional population (legally) and to give home-owners the legal ability to provide suites for family members and/or to generate income to offset the cost of housing. This policy has allowed for a significant increase in residential units.
The city has no mandate from the public to proceed with this proposed Official Community Plan.
Alternatives must be considered.