Opposition to Rezoning Application — 453-461 E 10ᵗʰ Ave & 2536-2542 Guelph St (RZ-2024-00106)

SECTION A: Why we are dissatisfied with the rezoning application for Guelph & East 10ᵗʰ

The following section describes the areas of concern with the rezoning application proposed for Guelph & East 10ᵗʰ. Where applicable, Broadway Plan Policies and Rationale from the Rezoning Application are cited for support of community concerns. The six issues discussed in detail are as follows:

1. Shadow Impact
2. Tower Separation
3. Construction Period Impacts & Contradictory Use of Laneway
4. Traffic Burden on the 10ᵗʰ Avenue Greenway, A Contradiction of City Priorities
5. Infrastructure Gap, Inadequate Public Benefit and Restricted Access to Outdoor Space
6. Displacement Risks and a Weak Tenant Relocation Plan

A1 Shadow Impact | The applicant’s winter-solstice shadow study (Application Sheet A701) shows near-total noon shade over the rear yards on the south side of 10ᵗʰ Ave from November 21 to February 21. The Broadway Plan Policy requires new buildings to design for sunlight access and minimize shadow impacts (Section 11.1.19-20, p. 292-293).

Community Concerns - Four winter months of lost sunlight. The direct tower overlook additionally erodes livability for neighbouring RT-5 homes.

A2 Tower Separation | The Broadway Plan Policy (Section 11.1.7, p. 290) clearly stipulates a minimum tower separation of 80 ft (24.4 m). However, the current application does not clearly specify the distance between the proposed 18-storey tower and the existing 4-storey mixed-use development at the corner of Guelph St. & East Broadway. Instead, the north side of the proposal is only referenced vaguely, with the assumption that it is “unlikely to be redeveloped in the foreseeable future.” 

Community Concerns - This lack of transparency sidesteps the intent of the Broadway Plan Policy and leaves current residents vulnerable to significant negative impacts. By omitting this critical information, the applicant avoids accountability to conform to tower separation guidelines. This undermines the very planning principles meant to protect neighbourhood resident well-being.

A3 Construction Period Impacts & Contradictory Use of Laneway | The applicant’s plan (Application Sheet A402) indicates that the parkade entrance and a shared Class B loading bay will be accessed directly from the laneway to the north, the same laneway that was effectively disregarded in their rationale for building placement and tower separation. While the north side of the property is described as “unlikely to be redeveloped,” the application clearly relies on this lane as a functional access point, undermining the claim that it is of limited relevance.

Community Concerns - The laneway currently supports a single car’s width of traffic and currently faces blockage from city garbage disposal and recycling services. This contradiction in the application has real implications for residents and businesses; the lane use during and after construction implies frequent occupation by service vehicles, delivery trucks, and queuing for the parkade.

A4 Traffic Burden on the 10ᵗʰ Avenue Greenway – A Contradiction of City Priorities | The Broadway Plan Policy (p. 490–491) identifies many existing bike routes, including the 10ᵗʰ Avenue Greenway, as falling short of All Ages and Abilities (AAA) standards. The upgrading of these greenways is highlighted as a priority action to support active transportation and community wellbeing.

Even the applicant acknowledges that the 10ᵗʰ Ave. bikeway “provides a quieter alternative to the traffic and noise along Broadway” and the need to “reduce the impact of density on the 10ᵗʰ Ave Greenway” (Application Section 2.2 Local Development Context, p. 19). 

Community Concerns - The applicant’s proposal does the opposite: it funnels increased tower traffic, service vehicles, deliveries, and construction trucks directly into the area, putting even greater strain on one of Vancouver’s busiest east-west cycling corridors.

A5 Infrastructure Gap | Inadequate Public Benefit and Restricted Access to Outdoor Space | The applicant proposes two POPs (privately owned public spaces), one being a small pocket park. According to architectural drawings in Section 4 of the proposal, this green space is estimated to measure 7.5 m by 6 m, this equates to just over the space they allocate for 2 regular vehicle parking spots, and is 2.5 m shorter in width compared to the Class B loading bay. Such limited dimensions offer minimal utility as a public gathering space and fall far short of the kind of meaningful green infrastructure that high-density development demands.

The proposal includes a Dog Run amenity, but access will be restricted to residents of the new building only. This stands in contrast to publicly accessible Dog Runs in areas like downtown Vancouver, where open access encourages broader community use and interaction. In this case, the Dog Run reinforces a boundary between residents and the surrounding neighbourhood, further reducing the already-limited value of the pocket park for the public.

Community Concerns - While the applicant proposes two POPs (privately owned public spaces) to fulfill amenity requirements, this does not substitute for meaningful public investment in critical infrastructure such as childcare facilities, expanded school capacity, or proper community parks. A small pocket plaza cannot carry the weight of the long-term infrastructure needs created by a high-density tower. Privately owned public spaces should offer inclusive, welcoming, and usable environments for all — not symbolic gestures that serve primarily the building’s occupants.

A6 Displacement Risks and a Weak Tenant Relocation Plan | The Broadway Plan’s Tenant Stability & Protections (Section 12.1.1–3, p. 354–355) clearly require a robust Tenant Relocation Plan for any redevelopment involving displacement. This includes financial compensation, moving assistance, and a guaranteed right-of-return at 20% below-market rent, essential protections for renters in a high-cost housing market. The current application fails to provide any concrete details on how these protections will be implemented.

There is no information on: 

• Compensation amounts or eligibility criteria,
• Relocation timelines and interim housing supports, or
• How below-market rents will be calculated, managed, or maintained over time.

This lack of transparency leaves renters in a precarious position. Promises without implementation frameworks are not meaningful protections.

SECTION B: A constructive alternative the community would support

• A 4-6-storey building
• Maintains the Plan’s 20 % below-market floor-area requirement.
• Funds a full green-lane upgrade and builds an on-site 25-space childcare room to align with Public Benefits Strategy (PBS) childcare targets.
• Includes a Construction-Support Plan—fixed noise hours, defined truck routes, lane-wayfinding signage, and marketing grants so Guelph St. shops stay open.

SECTION C: What we are asking Council

• Refuse the 18-storey scheme as filed.
• Direct the proponent to return with ≤ 6 storeys, 20 % below-market housing, and a clear CAC package (pocket-park funds, childcare, green-lane build-out).
• Require a new shadow study proving < 50 % noon-winter shade on 10ᵗʰ-Ave rear yards.
• Condition approval on a Construction-Support Plan guaranteeing uninterrupted business access in laneway.

SECTION D: Context to keep in mind

• Council’s 13 Dec 2024 update removed tower-number caps within 400 m of SkyTrain stations, this site is outside that radius.
• The update did not waive solar-access, tower-separation, or public-benefit obligations.
• The application delivers none of the amenities or infrastructure envisioned in the Public Benefits Strategy .

BOTTOM LINE:

We back rental housing—but only when it honours the Broadway Plan’s trade-off: more density for more public benefit, not less. Please steer this proposal toward the balanced, livable 6-storey alternative outlined above.