Note: Please read the note at bottom of petition before signing.

May 12, 2022 - Victoria, BC - Council has voted to send this forward for a public hearing, so this petition is still important. Your comments are valuable, so please do.

Victoria Mayor, Lisa Helps, wants to push through a vote on an initiative that will seriously impact housing for homeowners and renters in Victoria long into the future. Crucially, it will involve upzoning residential areas of Victoria to allow development of up to 6 units on any city residential lot; it will also remove opportunity for public comment which informs council decisions. Approvals for many new multiplexes will be delegated to City staff.

The Missing Middle Initiative (MMI), as it is currently proposed, is flawed and incomplete, and we ask that you urge Mayor and Council to delay approval with the possibility of making this an election issue.

Key reasons why a decision on the MMI should be delayed:

• Inadequate engagement
• Lack of public understanding of the policy
• Flawed and incomplete
• No affordability component built in
• No protection for existing renters
• Required a clearer vision for the reduced parking requirements for 6-unit buildings (will residents be charged to park on streets?)
• Requires integration with broader municipal and provincial policies for housing, renter protections, transportation and infrastructure
• No speculation mitigation strategy
• Requires more research on the risk of local government delegating away their ability to “level the playing field” when it comes to development
• Requires more research on the impact on property taxes (not just a homeowner issue as these costs are typically passed down to renters)

Inadequate engagement and public understanding

Ø  Victoria’s 2012 Official Community Plan was years in the making and was informed by more than 6,000 residents. The MMI, which, at best, had 800 respondents, came forward for approval and was introduced to the public last week in a 2000-page document.

Ø  The MMI engagement was inadequate and biased. Potential negative impacts were not disclosed to the public. Engagement surveys included leading and limiting questions designed for confirmation. Presentations did not provide an opportunity for two-way engagement, but rather, stated to residents what the City wanted to do and why they should agree. Information about the proposal was incomplete and skewed toward garnering support.

Ø  Staff stated in its report to council that there had been broad support for the MMI; however, this implies that those affected were aware and understood the policy and its implications. If all relevant information was not provided clearly and concisely, and even those writing the report do not understand the implications well enough to produce risk mitigation strategies, it is difficult to accept that respondents had an adequate understanding. 

Ø  Staff has been unable to provide meaningful comments on how issues resulting from a reduction in parking requirements will be addressed. When questioned, there was an ambiguous answer provided where staff suggested there might be a future "parking permitting strategy" for ‘curb management” but admitted, they haven't come up with a plan. When asked about when and how the public had been made aware of this, staff stated that it had been “mentioned” in a presentation back in October.

Ø  During Ask the Planner sessions, concerns were raised about affordability and speculation management; however, there were only vague answers about ideas that “might” capture land value in some way, provide for below-market applications of some type, require some kind of CACs and/or cash contributions from density bonusing - there were no specific answers or risk mitigation strategies.

Flawed and incomplete

Ø  Without the rationale of affordability, the MMI is not justifiable. Given what has been witnessed in other cities (and already in our own without the MMI), we can expect a greater number of demolitions/demovictions and displaced renters from existing affordable suites – the MMI does not include protection for tenants currently living in suites and/or older homes currently being rented and affordable housing stock will be replaced by expensive multiplexes and condos not attainable for current renters.

Ø  More research is required to study the impact of our local government delegating away its responsibility and obligation. Currently, because local government defines the type of development that may be allowed and the requirements for its approval; consequently, it can ensure that working-class people are protected and that the system does not unfairly benefit wealthy investors and/or developers with the goal of “unlocking the value” in land. Of note, the Globe and Mail recently calculated that 22 percent of buyers in Victoria were investors.

Ø  If our elected council, who are accountable to us, are not tasked with ensuring development is appropriate and that there is a public benefit by mandating levels of affordability, there should at least be affordability factored in; without it, the MMI will only streamline increasing the wealth of developers and investors rather than creating housing that makes communities more accessible and affordable.

Ø  There is a lack of research and consultation with BC Assessment concerning how the MMII may impact property taxes within Victoria. Evidence shows that when density is increased, land values go up. Therefore, it can be assumed that land assessments will go up relative to surrounding areas which will result in higher property taxes in Victoria.

Ø  Staff has been unable to provide meaningful comments on how issues resulting from a reduction in parking requirements will be addressed. When questioned, there was an ambiguous answer provided where staff suggested there might be a future "parking permitting strategy" for ‘curb management” but admitted, they haven't come up with a plan. When asked about when and how the public had been made aware of this, staff stated that it had been “mentioned” in a presentation back in October.

Requires integration with other provincial and municipal policies

The Missing Middle Initiative is premature with the prospect of all B.C. residential areas being upzoned by the province after the municipal elections. Were the whole province to be upzoned, rather than just Victoria, land inflation could be better controlled, and policy to curb speculation, protect renters and provide for affordable housing could be implemented simultaneously – such as the legislation on rental assistance expected from the provincial government this fall.

Without bold provincial policies, there will be no affordability in any new development; therefore, the missing middle should be tied to broader policies such as:

Ø  Provincial and federal tax waivers and incentives to encourage affordable housing development

Ø  Providing a mechanism for groups of residents to develop their own multi-unit co-op housing instead of having to purchase new individual units from developers. This would enable a least some of the “unlocked land value” to funnel down to those who intend to occupy the home. Without implementing strong policies, there will be no incentive for developers to do this type of work.

Ø  Using various types of covenants, community land trusts and co-ops to de-commoditize housing.

Without some type of effective land value capture, land values will continue to increase making housing more expensive. Investors will continue to leverage the increased land values, and then pass those costs onto renters in the form of higher rents. In other words, increased interest rates will only deter those on the bottom end of the ladder. This cycle will continue, and it will become even more difficult to build affordable housing because land will be too expensive as nothing will have been done to reduce the overheating of the market.

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