This could be one of our most important posts ever on CityHallWatch. It may seem rather like “inside baseball” and urban planning jargon, but it is deeply relevant to our housing, the shape and look of our communities and neighbourhoods, and to life itself in Vancouver.
At last, after months and years of requests, the City of Vancouver via its chief planner (Theresa O’Donnell) has dropped a bombshell, admitting that
“… the Planning Department does not have the robust analytics or data storage
of a fully functional GIS (geographical information system)
infrastructure for land use and policy.
I do not believe we have been clear on this fact.”
Effectively, her letter states that
– a crucial piece of evidence presented to City Council (see Fig. 6.1), purportedly showing the City’s zoned and development capacity from 1991 to 2041, is misleading and based on essentially made-up information, and
– the City of Vancouver really has no comprehensive inventory (past, present, or estimated future) of zoned capacity and development capacity.
Why is this all so important? Because proper data is needed to develop proper policy and make proper decisions. The City of Vancouver is always engaged in a significant number of development and rezoning applications, and is currently considering many major planning initiatives — the citywide Vancouver Plan, the Broadway Corridor Plan, Streamlining Rental (to allow up to six stories within one block of all arterial streets), False Creek South, Marine Landing, Regulation Redesign, Metro Vancouver Regional Context Statement, and much, much more (for a sampling, see the Shape Your City website, https://shapeyourcity.ca/).
How can a municipal government push ahead with all of these major initiatives without having sound data for its policies and decisions?
Below, first we look at the importance of this August 20, 2021 letter from Theresa O’Donnell (General Manager, Planning, Urban Design and Sustainability, City of Vancouver) to John Rose (Professor, Kwantlen Polytechnic University). Then, the text of the letter, and finally, some more detailed commentary. For more background, please refer to our posts “Can we have the data now? Prof John Rose writes Vancouver’s new chief planner” (June 5, 2021) and “Show us the data! Planning staff failed to answer Council request for data on ‘Recalibrating the Housing Vancouver Strategy post COVID-19’ – Memo by Clr Hardwick” (18-Sept-2020).
The bigger story goes back a few elections, Councils, and chief planners. In fact, Vancouver is now on its fourth chief planner (after Brent Toderian, Brian Jackson, and Gil Kelley) since CityHallWatch was first launched in 2010, and Vancouver has seen a huge amount of rezoning and development, but this is the first time to get such an admission of the shortcomings of data being used as the basis for all planning in Vancouver.
This breakthrough is largely thanks to persistent efforts by Councillor Colleen Hardwick, who spearheaded a motion, adopted by Council in May 2020, directing City staff to provide planning data upon which the planning department was basing its projections, policies, and development and rezoning recommendations. And thanks to persistent efforts by academics, particularly Prof. John Rose, who accelerated his attempts this past year. Many citizens and community groups also voice their requests for the City to release the data, in writing and in person. It is difficult to understate the amount of effort that went into all the various requests. Previous responses by senior staff were incomplete and unsatisfactory.
With this August 20 letter, the head of the planning department admits that the City’s zoning data is a hodgepodge of overlapping plans and PDF documents, and that the City’s methods of calculating zoned and development capacity are opaque. They are not transparent, even to the city planners.
The planning department’s projections are the basis for information to the public and for staff recommendations to our elected officials on development and rezoning. Underpinning all of this there should be sound and transparent data. But that has been sorely lacking.
This letter is significant. It is not just a matter of getting the City to provide transparent zoning data to better understand the housing issue, but of institutions earning and retaining the fragile trust of the public. City Council is elected by and represents the public, so it is important for this information to be made public.
Finally, the City’s planning department has stepped up and made the admissions in the letter.
The City (elected officials and public servants) need to be accountable, and we hope that this letter, effectively a mea culpa (admission of fault or error) by the planning department, signals a willingness to enhance data transparency on the housing file. Time is of the essence, with so many crucial projects, proposals and policies coming down the line in the coming weeks and months.
TEXT OF LETTER
From Theresa O’Donnell, General Manager, Planning, Urban Design and Sustainability, City of Vancouver
August 20, 2021
Good afternoon Mr. Rose,
Thank you for your patience and for your very clear and specific reply. It has been helpful to me as I try to understand the disconnect between the data that you’ve been requesting and the information we’ve been providing. I now think I’ve come to understand the source of confusion.
Your prior email was the first time I’d seen this chart, Figure 6.1. After speaking to staff, I’ve learned a similar chart was first used in a presentation to the City Council on March 13, 2019 to demonstrate the difference between zoned capacity and development capacity and why development capacity is the City’s standard methodology. As explained to me, the chart was intended to be illustrative only and did not represent a data analysis over time with a projection into the future, as the labeling on the chart indicates. I watched the staff presentation to listen to the additional explanation and even with that context, the design and labeling of the chart below is inaccurate and misleading.
I also understand the chart has been reproduced in subsequent responses and presentations further compounding the confusion. Planning staff will not use this chart going forward.
Nevertheless, I do want to address your specific questions about both zoned and development capacity data and analysis. You have repeatedly asked for “estimated zoned capacity broken down by each zone and by neighborhood, numbers and types of units with estimated total and annual build-out”. I’d like to explain why that data has not been provided to you in the format and breakdown you’ve requested.
Figure 6.1 Zoned Capacity Calculation
As staff have previously explained, an analysis of zoned capacity is extremely labour intensive for all the reasons laid out in past correspondence. Moreover, the Planning Department does not have the robust analytics or data storage of a fully functional GIS infrastructure for land use and policy. I do not believe we have been clear on this fact.
- While zoning districts are available in GIS, zoning sub-area boundaries are not digitized.
- Zoning attribute data for land use and density is not available for data joining with parcel-based zoning GIS layers for analysis. Land use and density attributes currently exist in zoning district schedule PDFs. However there are currently 14 Official Development Plans (ODPs), 97 Zoning Districts, and 750+ CD-1s. Data contained in these documents has not been interpreted nor made digital as a data table or added to a GIS layer for analytical purposes.
- Land use policy attributes for land use and density are not available for data joining with policy GIS layers for analysis. Land use and density attributes currently exist in Plans (64), Policies (51), Guidelines (197), and Bulletins (94) as PDFs or graphical images. Policy documents have not been interpreted for land use and density attributes, made digital as a data table or added to GIS layers, nor verified for analytical use.
These data analytics limitations compound other complicating factors, many of which have been explained before.
- BC Assessment data differs from City definitions for use and floor area. The City does not have a complete inventory of existing land use or floor area.
- City Permit data is incomplete and categorized inconsistently. The current permit tracking software and system was launched in 2016. Data contained in the previous mainframe system cannot be extracted without significant programming effort.
- Not all zoning district schedules have explicit maximum allowable densities for each land use type. For this reason it is not possible to calculate precise or even approximate zoning capacity for population, household or employment as the market determines this on a site-by-site basis.
- Some zoning districts allow different maximum densities for different combinations of land uses or tenure.
- Some zoning districts allow for a choice of use.
Given all the reasons cited above, Staff cannot provide the data or analysis you request. Despite the label on Figure 6.1 that reads: Method 2, Zoned Capacity Calculation to Buildout, there was no data-driven analysis behind this trend line. It was an approximation made by staff for illustrative purposes only. However the base raw zoning data is publicly available on the City website, please see below.
Zoning and land use document library
- Website containing Zoning and Development By-law (including Zoning District Schedules), Official development plan by-laws, Policies, Guidelines, and Bulletins documents including data on land use and density
- https://vancouver.ca/home-property-development/zoning-and-land-use- policies-document-library.aspx
- Download zoning district data
- View zoning district on VanMap
Issued building permits
- Download issued building permits
- Open Data – Issued building permits
Figure 6.1 Development Capacity Model
As you correctly pointed out in your email, the green line on Figure 6.1 is a population projection and not a Development Capacity Model. The City engaged an external consultant, Urban Futures, to provide this information at the municipal level as part of the Regional Context Statement (RCS) review process in 2012. The RCS was subsequently adopted by City Council and Metro Board in 2013. The consultant provided overall population and housing projections by year to 2041 including age cohort projections by gender. This projection utilized a standard demographic analysis that considers aging, fertility rates, mortality rates, migration and immigration trends to existing population and projects out to future years, i.e. 2031, 2041. You can find those numbers here in our published RCS. https://bylaws.vancouver.ca/odp/odp- regional-context-statement.pdf
Development Capacity is an approximation based on development trends observed across the city and reflects actual projects in the development pipeline (pre-zoning inquiry, rezoning applications, development permits and building permit data) in addition to adopted land use policy projections. This approach is informed by zoning and land use policy, but is not dependent on fully defined and digitally available data. Staff uses a combination of Stats Canada, BC Assessment, Building Permits in addition to zoning approvals and land use policies.
This approach also has a number of limitations, many of which are identical to those enumerated in the zoning capacity explanation.
- Longer termed projection relies on past trends, does not respond well to unknown supply and demand factors or scenarios.
- BC Assessment data differs from City definitions for use and floor area, complete inventory of existing land use and floor area is not available.
- City Permit data is incomplete and inconsistently categorized. All building permit data prior to 2016 is captured in a mainframe legacy system with very limited analytical or reporting capability.
- While zoning districts are available in GIS, zoning sub-area boundaries are not digitized.
- Zoning attribute data for land use and density is not available for data joining with zoning GIS layers for analysis. Land use and density attributes currently exist in zoning district schedule PDFs. However there are currently 14 ODPs, 97 Zoning Districts, and 750+ CD-1s. Data contained in these documents has not been interpreted nor made digital as a data table or added to a GIS layer for analytical purposes.
- Land use policy boundaries are not complete nor available in GIS. Policy maps were created in graphics software programs and exist as PDFs or as graphical images. Policy boundaries (64 Plans, 51 Policies, 197 Guidelines, and 94 Bulletins) have not been assessed, digitized, and verified for use in GIS.
- Land use policy attributes for land use and density are not available for data joining with policy GIS layers for analysis. Land use and density attributes currently exist in Plans (64), Policies (51), Guidelines (197), and Bulletins (94). Policy documents have not been interpreted for land use and density attributes, made digital as a data table or added to GIS layers, nor verified for analytical use.
As indicated in my letter dated July 30, 2021, as part of the Regional Growth Strategy (RGS) Update and the Vancouver Plan process and implementation, staff are updating development capacity estimates based on approved policies and community plans and this information will be provided in updates and reports to Council as well as in public engagement materials. As part of this effort to update development capacity estimates, we are working to address the current data limitations outlined above. Following adoption of an updated RGS, the RCS will require updating and approval by Council and the Metro Board. We are happy to continue to update you and share information in this regard as available.
Finally, I would like to apologize for the confusion that this chart and our subsequent responses have created. If you would like to discuss further over the phone or in person, I am happy to schedule a meeting at your convenience.
General Manager, Planning, Urban Design and Sustainability
cc: Mayor & Council
Paul Mochrie, City Manager
Karen Levitt, Deputy City Manager
FURTHER COMMENTARY ON THREE KEY POINTS OF THE LETTER
A) On Figure 6.1 (and the discussion on pp. 1 and 2 of the letter):
Prof. Rose focused his inquiries on this figure because the City planning department and senior planning staff had used it numerous times in recent years to show City Council and the public its assessments of past, present and future zoned and development capacity for the City of Vancouver. Council asked for more detailed zoned capacity data in its May 2020 motion, but this figure was what was provided by staff in its July 31, 2020 response (along with a table describing the differences between zoned and development capacity) (see Fig 6.1 and Fig. 6.2 on p40/59 of “Staff Response to Council Motion Recalibrating the Housing Vancouver Strategy Post-Covid 19, RTS 013971” – Link here). https://vancouver.ca/files/cov/memo-housing-policy-recalibrating-housing-vancouver-targets.pdf
Prof. Rose said in his June 2 letter (see “Can we have the data now?”) that neighbourhood/sub-area data must have been on hand and available at some level for staff to calculate and provide figures for the city as a whole, as shown in Figure 6.1, and asked staff to provide this data. He emphasized that his request was a follow up on what council mandated staff to provide in the motion of May 2020.
The August 20 response from the chief planner makes the stunning confession that the line for zoned capacity in Figure 6.1 is not based on any actual data or analysis. Figure 6.1 is misleading and inaccurate for this reason, and for the fact that the line for development capacity is simply a population line (past/present/projected future). It is not an actual and full representation of development capacity as defined by the City.
The August 20 letter from the chief planner waves this away by claiming that staff simply provided this chart to show Council the conceptual difference between zoned and development capacity, not as an actual representation of those figures for the City of Vancouver from 1991-2041.
There are two crucial problems with that story:
1) This chart doesn’t even work as a conceptual illustration of the difference between zoned and development capacity (since the latter is just portrayed with a population line, which doesn’t even show “development capacity” as defined by planning staff), and
2) The way in which it was constructed and labeled suggests that it is not just conceptual, but an actual depiction of the City’s zoned and development capacity. The July 31, 2020 memo from staff already provided a conceptual table (Fig. 6.2) showing the differences between zoned and development capacity, so there is no need for an additional, “figurative” chart. Moreover, citing sources below a “figurative” chart and populating it with specific data (population for development capacity; made-up numbers for zoned capacity; amounts and dates for both) suggests that what is being shown is a representation of material reality. This is irresponsible and misleading.
B) On the challenges of measuring and providing data on ZONED CAPACITY (p. 2 of August 20 letter):
The letter rightfully shows that even measuring zoned capacity is challenging. It also reveals that the city really has no systematic method of collecting, processing, and displaying data on zoned capacity (via a geographic information system, or GIS). The data they have on hand appears to be a mishmash of different sources, largely in PDF format.
All of the above leads to some questions
- How does the City have any real idea of how many dwelling units can be accommodated (past, present, future) on its land base, even when just considering what zoning regulations deem permissible?
- If the City has no real handle on its zoned capacity, how can any conclusive statements be made about restrictive zoning regulations causing housing price escalation in Vancouver?
- How do we know if the proposed solutions for housing affordability (e.g., widespread up-zoning as we can see being proposed in ShapeYourCity.ca) will actually address the source of the problem (which proponents of ever-increasing supply claim is based on excessively restrictive zoning)?
- Why does the City not have this data in a comprehensive format? Many others do have it. And when asked to provide it, why did the planning department simply direct people to a limited database of linked source documents and expect them to figure things out?
C) On the challenges of measuring and providing data on DEVELOPMENT CAPACITY (p. 2 of the August 20 letter):
- The same points apply here as described for measures of zoned capacity above, but with the additional complexities of trying to incorporate even more additional variables.
This leads us to some questions:
- How does the City actually calculate “development capacity”?
- What is the specific methodology to determine the “development capacity” of a specific site, block, or neighbourhood?
The City’s answer appears to be “We don’t know.” We are just told that this is the City’s “standard approach,” but it is one that “is not dependent on fully defined and digitally available data.”
This letter by chief planner Theresa O’Donnell admitting there is a problem with the City’s planning databases is an important first step by the planning department. Bu now it needs to act, by getting its data house in order, organizing and digitizing its zoning data, and providing this to the public in a transparent, user-friendly, way.
In addition, everyone, including Council and the public, must have a close look at the data and narratives being presented by the planning department to underpin major planning initiatives, such as the citywide Vancouver Plan, the Broadway Corridor Plan, Streamlining Rental (to allow up to six stories within one block of all arterial streets), False Creek South, Marine Landing, Regulation Redesign, Metro Vancouver Regional Context Statement, and much, much more.
PDF of CoV O’Donnell letter to John Rose 20-Aug-2021