Absence of Info for Public & Suppression of Public's Info for Council

Dear Ms. Berry,

We have reviewed your comments justifying why the staff concluded that the “changes made to the current submission are not enough to be sent back to the ADP”. We understand that the Staff and the Council desire to put projects underway, especially in light of the fresh application for a CMHC’s Housing Accelerator Fund (HUF). WestStone would be a “shovel-ready”, large project towards that desire. And the Council accepted your recommendation. Nevertheless, we strongly disagree with your assessment (highlighted in in italics), and wish to comment on it, as follows:


The application and revisions made to the project have been reviewed by staff from several municipal departments. Before presenting the project to the City’s Advisory Design Panel, the original design underwent several rounds of review and revision to ensure it satisfies municipal bylaw standards and the directions provided in the City’s DPA Guidelines. The form and character of the building is consistent with the previous four-storey iteration; therefore, staff are recommending that the revised proposal does not require further review by the Advisory Design Panel.

Firstly, the form and character of the building is NOT consistent with the previous four-storey iteration. Secondly, what you have omitted to mention is that the ADP failed this project 4 times, which is rather unheard of. At a point when when the project was at 4 storeys, not even the current 6 storeys, they did so unanimously. Councillor Manning then stated: “They (ADP) are pro-development. They have approved everything else”. It should be noted that the ADP is a highly professional group consisting of architects, professional engineers, arborists, landscape architects, etc. providing expert advice to the Council. The ADP concluded that should this project ever come back, it would require SUBSTANTIAL changes. Otherwise, they were not prepared to see it again. None of their principle objections were acted upon. It appears illogical to discard the ADP’s assessment and substitute it with an opinion of Staff or Council, neither of whom have any comparable qualifications or experience.

Secondly, while there was a Public Information Meeting, it was held digitally due to Covid. As a result, only handful participated since it was a new, challenging experience. And that was over 3 years ago. Therefore, the first real opportunity the public had to hear the presentation and speak to it, was at the Public Hearing of July 24, 2023. And for over 3 years the Management successfully blocked the Council and the ADP from receiving any information coming from the public. We have argued about it via numerous emails, with your predecesor, Greg Newman, to no avail. As a result, the first and only information from the public that the Council received was at the Public Hearing. Subsequent to that, we and others, submitted numerous reports assessing this development that counter your recommendation.

We understand that the City has a policy that “no further information can be received from the applicant or the public once the Public Hearing is concluded”. Nevertheless, this information shows that the Council were voting on an incorrect information provided to them by you. If this additional information is correct, which we strongly believe it is, it means that this development contravenes the OCP in not one, but several crucial areas.


At the time when this development was at 4-storeys, under this exact heading, it stated: “The four-storey proposal is, in the opinion ouf staff, appropriately scaled to the context of development and will allow for the more intensive use of lands that are readily served by municipal infrastructure. In addition, compatible development, through infill, lessens the need for sprawl into the periphery on lands which may be more appropriately left undeveloped, naturalized spaces” (pg.156 of 541 of the Zoning Bylaw).

We wonder whether the current 6-storrey (but in fact 9-storey) building is now even more appropriately scaled than the 4-storrey building, and whether it is still a compatible development that lessens the sprawl into the periphery onto lands more appropriately left undeveloped. And why it was replaced by the following:

Environmental sustainability is addressed within the development by the provision of bike racks and bike storage, charging stations for electric vehicles, light pollution reduction through dark sky-compliant exterior lighting systems, water-efficient landscaping and plumbing systems, natural ventilation through operable windows and energy-efficient HVAC systems, storage and collection of recyclables, renewable based wood building materials and heat island effect reduction by minimizing surface parking and maximizing density. Rainwater runoff will also be dealt with via a stormwater detention tank located on site.

This entire paragraph is an array of environmentally well intentioned and sounding measures. Unfortunately, none of the these measures, together or on their own, can reverse the cumulative damage that this development would bring about to this neighbourhood, and the ravine/riparian/tree areas and neighbourhoods downstream towards Marine Drive. We have already witnessed recent floods and mudslides in 1999 and 2018. They are well documented in the Canadian Disaster Database. An increase in density in this area can only make the situation worse.

There is no reference anywhere in this your Public Hearing presentation report acknowledging that the development is located within the “Environmental (Ravine Lands and Significant Trees) Development Permit Area” (OCP 23.4). That designation places additional requirements on this development, that were obviously not considered by the City or the developer’s arborist, such as:

1.”retention of mature, healthy trees and native vegetation and ground cover is a priority”.

This section requires the developer to “demonstrate every effort to preserve protected trees”. The exact location is obviously crucial for the viability of this project. Why was not the tree location survey provided as part of the consultant package? Were the tree locations not legally surveyed as yet? Many tree locations are shown incorrectly or as “hand-plotted”. These errors lean towards maximizing the size of the available building envelope. That emphasis should be reversed to maximize the protection of the existing trees instead. The developer’s Arborist Report uses as the basis for the Critical Root Zone “DBH times 6”. The Tree Protection Bylaw states it is either that or “one meter beyond the dripline”, whichever is greater. The bylaw does not allow a choice in the matter, and the “one meter beyond the dripline” is substantially greater. Refer to the Browning Consulting’s Arborist Report recently submitted to you. As a result, this greatly reduces the available footprint for the building. The building simply cannot be built as designed.

For comparison, the parkade “notches” on the Beverley are much more substantial, allowing the trees more preservation space. The same applies to the clearance between the curb and the douglas firs at the Vidal St. 2-lane narrowing. Should similar “clearances” be applied to the WestStone property (20% smaller than Beverley), the available building envelope would be drastically reduced, and more suitable for townhouses – as originally intended.

2.“innovative site designs which are in harmony with existing healthy mature trees and other natural features” -There are no such designs employed here. It is all concrete and asphalt which increases runoff and erosion, giving no chance to water retention. Just recently, North Vancouver announced a 2-year tree replanting program with carbon-reduction benefits to fight climate change. Vancouver does that for over 10 years. White Rock seems to go in the opposite direction. Further away, BC just replanted over billion trees. (

-It does not protect existing healthy, mostly coniferous trees; it does not increase or at least preserve the amount of tree canopy. It does not contribute to the sustainability of the City’s urban forest. On the contrary. There are no green infrastructure policies like bioswales, permeable pavement, rain gardens, soil cells, etc. proposed.

3.”building profiles should follow the natural topography of the site with as little change as possible to accommodate construction”.

– The ADP insisted on breaking the building into 2 or 3 smaller blocks (i.e. townhouses) to better follow the rather steep grade of the road, as opposed to having one long, level, monolithic block (21% longer than Beverley).

The WestStone project forms the upper end of this “Environmental” area. City surveyors/planners at the time, when designing the “city grid” recognized that. To protect the watercourse, mature woodlots, to deal with slope stability and erosion, they limited the development potential of Vidal by laying it out as the only “limited local” street in the entire Uptown Area. Nevertheless, over the last century, development slowly encroached on the ravine and its riparian ecosystems. The ravine now starts undisturbed again at the Sea Park West development at the lane south of Thrift. The City mapping clearly shows it again as a watercourse at Roper. Environmental concerns then were not everyday issues. We certainly know better now, and we can, and should, employ design measures to prevent problems like mudslides just downstream in 2018 near Victoria Avenue, and in 1999 up to Marine Drive. If we do not act with caution, these desasters will repeat, and repeat faster. ( ).

IMPLICATIONS FOR TREE PRESERVATION AND TREE CANOPY ENHANCEMENT The Arborist Report prepared by Van Der Zalm (VDZ) and Associates (Appendix F) has undergone several iterations of review and revision since the application was received in 2019. Staff have been working with the Applicant to ensure the design of the building, specifically the parkade, allows for the most significant level of tree retention. This is particularly important along the western and northern boundaries of the Subject Properties, where several mature trees exist. In response to the City’s comments, the Applicant has created notches in the parkade to avoid the tree protection zones associated with several large off-site (OS) trees. Furthermore, the Applicant has reduced the footprint of the building along its northern façade to provide greater accommodation to several off-site trees falling within the property tied to the Beverley development. Trees for which retention is proposed would require the posting of securities in accordance with the City’s Tree Protection Bylaw. Trees proposed for removal would be subject to replacement requirements. Where replacements are not feasible, cash-in-lieu of such may be considered by the City. In summary, $117,000 in securities (held for tree retention) and 27 replacement trees ($40,500 value) would be required. The most recent Landscape Plan illustrates 24 replacement trees, plus 11 trees proposed for the sixth storey (rooftop amenity areas). If the project were to proceed, staff would work with the Applicant and their Landscape Architect to ensure tree species and required spacing, amongst other matters, were addressed to the satisfaction of the city. If Council gives the first and second readings, the tree locations will be legally surveyed as per our bylaw, and any revision will be made before the third reading.

The “Tree Canopy Enhancement of 11 trees proposed for the sixth storey (rooftop amenity areas)” is no substitute for the mature, mostly coniferous, trees. These trees are no more than “green colour” decorations that can only be seen from the air.

The notches in the parkade created to avoid the tree protection zones associated with several large off-site (OS) trees are inadequate, even using the Landscape Architect’s incorrect interpretation of the “critical root zone”. When the correct interpretation is applied, the building simply cannot be built as designed.

We also understand that property owners along the westerly boundary of the property would not allow an encroachment on their property by shotcrete tie-back anchors, etc. While the excavation face could be secured using other means, without an encroachment, that would likely be a rather costly measure. The parkade is located within a backfilled ravine, and it is now four levels deep. A pro-active administration would request a geotechnical and groundwater report to address the the impact of changed flows on the health of the remainig trees around it, and on the submerged foundation itself. It would also go a long way towards eliminating unexpected groundwater problems like during the construction of the Phantom development nearby.


The Save White Rock Team

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