(Updated 26-Apr-2020 with background info at top) CityHallWatch has obtained a copy of this letter from the Character House Network addressed to Vancouver Mayor and Council, April 24, 2020, regarding proposed changes to the Vancouver Building By-law (VBBL), to be review by Council on April 29.
The VBBL amendments are intended to apply to new construction. But an unconsidered consequence is that it also affects existing buildings for renovations, additions and infill. This makes retention options for heritage and character buildings in particular less viable since new construction requirements apply to new work on existing buildings that is much harder to comply with.
From an environmental perspective, reducing GHGs needs to be looked at holistically. New construction has an enormous environmental footprint from the demolition, new materials, resource extraction, loss of ecosystems, forests logged, rivers mined, manufacturing and transportation over land and seas. To mitigate this it is essential that new construction operationally is very energy efficient and preferably zero emissions. But even with operational zero emissions, new construction takes decades to offset the ecological impacts of demolition and new construction production, often being demolished again before the operational efficiencies offset the production impacts.
The foundation of sustainability is reduce, reuse and recycle. Adaptive reuse of existing buildings is essential. By reusing existing buildings, it retains the embodied energy and reduces the impacts of new materials, manufacturing and construction. Heritage and character buildings are built from old growth forests so to demolish them and put this in the chipper is incredibly wasteful (e.g. the mountain of stockpiled woodchips down on Kent Avenue). Retention and extending the lifespan of these buildings has a lower ecological footprint to effectively zero emissions. This more than offsets operational inefficiencies that can be improved over time. So how the VBBL is applied to existing buildings should not be the same as new construction.
Therefore the proposed amendments to the VBBL should not be mandatory for existing heritage and character houses. It is much more important to retain these buildings and avoid demolition. Improving operational efficiencies of existing buildings should be balanced with the existing conditions rather than applying new construction standards dogmatically.
Text of letter from Vancouver Character House Network to Vancouver City Council.
April 24, 2020
City of Vancouver
Mayor Stewart and Council
Dear Mayor Stewart and Councillors:
Re: Climate Emergency Requirements for New Housing 3-Storeys and Under
Agenda April 29, 2020: https://council.vancouver.ca/20200429/pspc20200429ag.htm
The Character House Network is in principle supportive of new housing being built to more energy efficient building standards. However, we have concerns that the impacts this would have on renovations of existing buildings have not been considered, and most specifically how it undermines heritage and character house incentives for retention. Therefore, please register us as being opposed to the proposed changes unless the following amendments are added.
We have a petition on Change.org that calls for, among other things, “…to take immediate action to remove from zoning and building code bylaws any biases favouring demolition and new construction over retention…” is now over 8600 plus paper signers at the time of writing.
And the Vancouver Vanishes Facebook has 13,450 likes, also as a form of support for retention.
Clearly the public wants to see policies that encourage heritage and character house retention, and the city has programs to encourage this through heritage and character house incentives. And reducing demolition and increasing adaptive reuse of existing buildings helps to address the climate emergency.
This also affects heritage homes since being listed on the Heritage Register still allows demolition until they are registered on title at the discretion of the owner. So heritage buildings are still vulnerable. And heritage and character homes are particularly vulnerable in RS zones since there are no disincentives to demolish like there is in RT zones.
However, the proposed Building By-law amendments would apply to renovations on an escalating scale as a certain amount of work relative to the value of the building, and unconditionally for all building additions or related infill, would trigger meeting the requirements of new construction under the Building By-law. This may not be practical or affordable for retention of heritage and character homes, which undermines the City’s policies to incentivise retention options.
VBBL 18.104.22.168.2) The alternative compliance measures provided in Table 22.214.171.124. apply to existing conditions only and do not apply to new work which must conform to the requirements for new construction in other Parts of this By-law.
To address this, the Alternative Compliance Measures for heritage and character buildings in Section 11 of the Vancouver Building By-law must also be amended to ensure these provisions for new construction would not apply for renovation, additions and related infill in a retention project.
The proposed changes to the Building By-law are generally as follows:
1. heating and hot water to be zero emission; and
2. requires all parking spaces to provide electric charging.
While these are appropriate for new construction, they are much more difficult to provide in retention options and in many times impractical and too expensive. This would create an additional bias toward demolition. New building technology may not be compatible with retaining heritage and character buildings, and the increased electrical load may require significant upgrading that may not be economical for adaptive reuse of existing buildings.
The new provisions should therefore not be mandatory for heritage and character home renovations, additions and related infill, and be instead covered by the Alternative Compliance Measures under Section 11 of the Vancouver Building By-law.
Please amend as follows in red:
Recommendation A –
FURTHER THAT Council instruct the Director of Legal Services to prepare and bring forward for enactment the by-law necessary to implement these amendments, generally as outlined in Appendix A, except for heritage and character building renovations, additions and related infill, that are to be instead exempted through Alternative Compliance Measures under Section 11 of the Vancouver Building By-law.
Recommendation B –
FURTHER THAT Council instruct the Director of Legal Services to prepare and bring forward for enactment the by-laws necessary to implement these amendments, generally as outlined in Appendix E, except for heritage and character building renovations, additions and related infill that are to be instead exempted for these amendments under by-laws that apply to new construction.
While we are pleased to see more energy efficient new construction being accommodated, we request the suggested amendments above be made in order to ensure that this doesn’t override other City initiatives for heritage and character house incentives that help to provide more housing choice for both ownership and rentals, and more sustainability through adaptive reuse of existing buildings.
Signatories for Vancouver Character House Network