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Transcript of Rockland Neighbourhood Association Critique of City's Official Community Plan Public Survey

RNA  - March 2024 Newsletter
Dear Neighbours,

Given the extraordinary importance of the OCP review, and the confusion that surrounds the recent City survey, this issue needs to be front and centre in this month’s newsletter.  The board of the Rockland Neighbourhood Association has recently submitted the following letter to the City:

Dear Mayor and Council,
Subject: Official Community Plan (OCP) Online Survey 
The Rockland Neighbourhood Association (RNA) is writing to express our strong concern with the Official Community Plan (OCP) Survey. (https://engage.victoria.ca/ocp/surveys/ocp-survey-draft-211)

The survey was launched this month as part of the OCP consultation process. However, the RNA has identified significant biases in the rollout of the survey questions.
1)    Sampling bias: The OCP survey is only available online. The City has not considered respondents’ age, income and access to the Internet.
2)    Nonresponse bias: Residents who signed up at the City of Victoria website report having received neither a pre-notification email with an access link to the survey, nor a reminder.
3)    Response bias: The survey encourages only two choices for building heights: six storeys across all residential neighbourhoods or just in some residential neighbourhoods, with everywhere else being four storeys.  This is a false choice. Provincial legislation on small-scale multi-unit housing (SSMUH) only requires four to six units per property, and recommends they be built only to a maximum of three storeys.  This legitimate choice is not offered in the survey.
4)    Acquiescence bias: Leading questions and vagueness in content. The survey asserts that policies "will likely" lead to such benefits as more rentals and non-market housing. However, the Council has proven that it can remove a developer's commitment to affordable or non-market housing after issuing the development permit.

Requires Mitigation:
Question 1: Only two options--six-storey buildings in all residential areas, or four- and six-storey buildings in these areas—which exceeds provincial requirements of four to six units per property, with a maximum of three storeys.
Question 5:  Seeks input on features for taller buildings without the option to flag the need for parking.
Question 6:  Family Housing: offers no option to choose parking as a priority except for 3-bedroom homes.
Question 9: Town Centres: offers no comment on preserving architectural heritage.
Question 12: Linear Parkways are not defined in the preamble to the question.
Question 14: Community and Cultural Spaces: assumes all neighbourhoods have such spaces, e.g. community centres.
Question 16: "Old town" features – residential architectural heritage is not addressed.
Question 19: Climate Resilience. There is no mention of the urban forest at a time when the Garry oak ecosystem is under threat.
Question 20: Climate-friendly building construction supports the tearing down of buildings (even if they are being reused), with no option to flag the importance of converting existing buildings into multiplexes.

The RNA encourages discussion and open lines of communication. We believe the shortcomings of this survey will marginalize respondents and deprive a wide selection of Victoria residents of their voice in developing the new Official Community Plan. This is very worrying, as under provincial legislation, the OCP process is one of the very few avenues for residents to have an impact on the direction of Victoria’s housing policy.
The survey process has data collection and methodological problems in its "one-city" approach to consultation. The RNA requests that the City of Victoria rectify these items to improve residents' voices in the OCP process.

We request that the Mayor and Council:
a)     Rescind the current OCP survey.
b)    Hire an external organization to implement a survey free of the biases identified above and extend the deadline for its completion.
c)     Provide city-wide mailouts with hard-copy surveys.
d)    Email participants who signed up for OCP updates via the City of Victoria website.
e)    Set up formal, face-to-face OCP consultations with each of the 12 neighbourhood community associations.

Good governance requires that the City ensure the views of the broad range of Victoria residents are recorded, along with those of the various private sector lobby groups who have already demonstrated significant interest in this process.


Sincerely
Rockland Neighbourhood Association
Rockland Land Use Committee 

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