Can BC Housing still support this project?

Because the overdevelopment by OBUC breaches so many of the BC Housing guidelines, we have written to BC Housing to see if BC Housing still supports the project.

Attached is a copy of the letter mailed on September 19, 2018.

If BC Housing do respond we will post their response here.

We got a response nearly 2 months later after following up several times, including with the Minister of Housing

From: Malcolm McNaughton <mmcnaughton@bchousing.org>
Sent: Wednesday, 9 January 2019 11:42 AM

Mr. Bolitho,

Thank you for your letter dated September 18, 2108 regarding “Oak Bay United Church, File Ref #: 94414, Project Ref #:7958”. Apologies for the delay in responding. We have have had a chance to catch up over the Christmas break.

 Your letter identified a table with several BC Housing Design Guidelines and Construction Standards (referred to henceforth as “BCHDGCS”) (2018) and provided comments/ comparisons with the Oak Bay United Church (OBUC) summary plans, that included several questions. These two columns have been reproduced in the attached table with responses to your questions provided in a new column to the right.

 In addition to the table, your letter included several pages referring to the Oak Park Zoning Bylaw Review. The project is currently undergoing rezoning by the District of Oak Bay and BC Housing respects and defers to their planning and permitting processes.

BC Housing Design Guidelines and Construction Standards 2018

Introduction page 2 says “The BC Housing Design Guidelines and Construction Standards are intended to be a reference and baseline from which full project specific specifications are compiled by the Design Team.” {emphasis added}














1.2.1  Unless otherwise specified in this document, the recommendations included in these guidelines are intended to apply to housing developments whose capital and/or operating budgets are funded or financed by BC Housing regardless of project type. 


2.1.2  Zoning and Development Analysis  Each municipality in BC has their own regulations governing development. A careful analysis of the development regulations must be undertaken by the project team to determine allowable density, height, site coverage, parking requirements, bicycle requirements and energy targets.


4.1.1      Common areas for buildings consist of: 
• Indoor amenity spaces for residents use,
4.2.1 Amenity spaces are an important part of developments funded by BC Housing. These spaces provide for meetings and social gatherings and should be designed to offer residents the option for social interaction and to encourage a sense of community within the project.
4.2.4      Basic Amenities for Family and Independent Housing .1  For projects which will provide housing accommodations only, the amenity space shall consist of a multi-purpose room, a kitchenette, an accessible public washroom, and storage room.
.2 The multi-purpose room shall be calculated as a minimum of 1.4 m2 (15 ft2) per unit up to a maximum of 140 m2 (1505 ft2). For projects with less than 25 units, the multi-purpose room shall not be less than 35 m2 (375 ft2). The accessible washroom and amenity kitchenette should be adjacent to the multi-purpose room.
.3 The amenity kitchenette is not intended to be used for commercial cooking purposes.



Comment / Comparison to OBUC Summary Plans

How far below baseline can a project go before it is disqualified from receiving further funding from BC Housing?










If the recommendations are not applied to the OBUC development will that preclude it from receiving capital from BC Housing?






OBUC are proposing a Comprehensive Development Zone that would incorporate the appropriate portions of P-2 & RM-4.  Unfortunately, the Summary Plans do not comply with the majority of the requirements of P-2 & RM-4. (refer “Oak Bay Zoning Bylaw Review” attached).

Does BC Housing support a project that doesn’t comply with Zoning?


The only common area shown on the plans is a Common Lounge on the 1st floor.

That area seems to have only a sink. Comparing the space to the unit to the west it appears to approximately 13 m2, not the 134.4 m2 that a 96 unit complex requires.

From what I can see the following are not provided: 

  • a kitchenette, 

  • an accessible public washroom, and 

  • storage room.

I cannot see ANY public washrooms for the residents on any floors

 The OBUC are proposing to build a “Church Program Space” of several hundred square meters, but this is not a space for “for residents use” nor will it “provide for meetings and social gatherings and should be designed to offer residents the option for social interaction and to encourage a sense of community within the project”

 Can BC Housing support a project with just 10% of the common room requirement?

 Can BC Housing support a common room without washrooms or a kitchen?

BC Housing Response

The section of the BCHDGCS quoted in column 1 of this table (Introduction, p.3) is under the “Alternatives to the BC Housing Design Guidelines and Construction Standards”, which later goes on to state that “BC Housing will support proposals for alternatives to these standards.”

Further, Section 1.1 of this document (p.2) describes the guideline objectives of providing “basic guidance on design and performance which will influence the form, layout and specifications of buildings delivered under the various programs of BC Housing.” 

BC Housing considers multiple factors when considering any project, including design, project type, clientele and budget. Each project has unique considerations and will be considered on its merits.


BC Housing has provided preliminary development funding to assist the non-profit society in initiating designs for new affordable housing. BC Housing will review the designs as the project progresses and provide project-specific recommendations as needed.


The project is currently undergoing rezoning by the District of Oak Bay and BC Housing respects and defers to their planning and permitting processes.



BC Housing will review the designs and provide input as the project progresses through the design development stage.