Questionable conclusions

February 12, 2019

To: Mayor and Council, Bruce Anderson, Director of Building and Planning—District of Oak Bay

I am very concerned about the conclusions of the Traffic Study and the Parking Study on the OBUC web site:

OBUC Parking Study: "Based on the analysis of each proposed land use, engineers recommend 112-115 parking stalls to accommodate residents (plus visitors), church and public use. OBUC designs include 115 stalls, meeting the upper range of the recommended number."

OBUC Traffic Study: "The study finds that the project area’s main traffic impacts are the result of vehicles bypassing Oak Bay Ave. The OBUC project is not expected to be a factor in adding traffic to the area due to low vehicle ratios for affordable housing, space for bicycles and proximity of public transportation."

How can a development of 96 units, with I'm guessing at least 150 people, likely more, have no impact on local traffic? The Traffic Study by Watt Consulting Group (May 2018) makes the assumption that "Trip generation rates for affordable housing are generally lower than market rental. Studies have demonstrated that vehicle trips per household increase as income increases."

As it is uncertain how many individuals are being considered low income and how many of higher income, concluding how many trips may be generated is sheer speculation. I live on Mitchell Street and my daily observations since the recent parking restriction on Granite Street are that there has been a noticeable impact on traffic. So, combine this with the potential added traffic from the residents in the proposed development, there will be considerable impact on the use of surrounding roads as well as on street parking. The study's conclusion that there will be little impact on traffic is ludicrous.

Closer examination of The Parking Study by Watt Consulting Group submitted in May 2018, provides details of this proposal. It is based on providing 47 parking stalls for 96 units; 10 stalls for Visitor parking, as well as 15 stalls for Church programming, and 35 stalls to be leased for Municipal use.

However, Oak Bay By-Law 3540 determines the minimum parking supply for Multi-family developments @1.5 per unit. Following that, for 96 units the current requirement would be for 154 parking stalls. The Church parking lot currently has 53 spaces, while Church programming use within P-2 Zone requires 117 parking spaces. Allowing the Church to continue to have only 53 spaces as currently provided in their parking lot, the total number would be 217 parking stalls.  Even requiring only 1 parking stall per unit, the total required would be 159!

The proposed 115 parking stalls allows only 47 stalls for 96 units. This recommendation is based on observations by the consultants at other 'representative Multifamily sites with countable/visible parking spaces', ie buildings with only surface parking. These observations were made on two night time occasions in February 2018 (p9), presumably when all the residents were at home. This is an extremely limited strategy to measure the parking needs of potential residents in the proposed OBUC development.

It concludes that "should there be 'overspill' it could be accommodated on Mitchell St and Brighton St which have no parking restrictions". At a minimum there would be an overspill of 44 cars!  Both streets are now contending with the increased volume of traffic and parking due to the recent 2Hr 9-5 Restriction on Granite Street between Foul Bay Road and Mitchell Street. This is certainly not acceptable as a solution to the under provision of parking for this development.

Providing more parking in the proposed two level underground parking area would require deeper blasting. The Geotechnical Report provided by Ryzuk Geotechnical states that "drilling and blasting will require underpinning and/or shoring" of the Church and adjacent structures for the 7 metre maximum. The Report is based on two levels and a new Report would have to be done for going deeper. This report also indicates that vibrations could cause damage to homes close by.

Add to this the Thrift Shop hours on Friday and Saturday to both parking and traffic. I note that the Traffic Study states that the Thrift Shop will continue to operate at the proposed site, while the near residents were told that it would move off site!

My daily observation and experience seem to me to be more real and valid than the methods used by the consultants. The consultants' conclusions are certainly questionable and I hope Mayor, Councillors and staff will take a close of these studies.

The future of Oak Bay’s now quiet streets?

The future of Oak Bay’s now quiet streets?

Janet Poth
Oak Bay

When is a problem not a problem? Ask the experts.

The Oak Bay United Church (OBUC) Developers have called on many experts to prepare their application to the District of Oak Bay.

Important questions to ask when considering input from experts:

  1. Are their findings reasonable and logically supported?

  2. Have they taken an open-minded approach?

  3. Does funding have a determination on their bias?

  4. Are the chosen experts the most qualified and the most trustworthy?

Let’s look at the Traffic Impact Study

The Watt Consulting Group (WCG) state on their website that they are “regarded for consultative processes that involve the community and build support for implementation.”
Yet we have been unable to identify a single person in our extensive community who was asked anything about traffic and parking by WCG or anyone else.
WCG maintain that “the proposed development will have little or no impact on the traffic operations of the Granite Street/Mitchell Street intersection in the short and long term.”
Think about that: a 96-unit apartment block is proposed for a quiet side street and experts says this additional housing for 150-250 people would have no impact on traffic.
No. Impact.
How was that conclusion reached?
We know it was not arrived at through involvement with the people who have lived in this area for decades. Does that mean WCG only sought the opinion of their client—the OBUC Developers? Most of the Developers don’t live anywhere near Granite Street.
A recent community consultation article notes that developers don’t see residents as experts and that this is a critical and corrosive mistake.
“We should only consult with residents when they are the ones that can best answer the questions at hand. But in those moments they should be treated as they experts they are.” People who live in this neighbourhood have extensive experience of the traffic problems that already exist. The OBUC Developers suggest none of the current traffic problems have anything to do with the church.
From the WCG: “The study finds that the project area’s main traffic impacts are the result of vehicles bypassing Oak Bay Ave. The OBUC project is not expected to be a factor in adding traffic to the area due to low vehicle ratios for affordable housing, space for bicycles and proximity of public transportation.”
That argument is lost, if not on its sheer lack of logic, then on the fact that almost half the new apartments will be at market rates, attracting tenants who will most likely have cars.
To say nothing of the simple reality that that the people who don’t own cars still take taxis and use car-share programs. They will also have friends, family, and professional services who will arrive in cars.
WCG notes that “Specific traffic projections are not presented in the City’s (sic) OCP [Official Community Plan] but a steady and low increase would remain for the vehicle travel mode in the future.”
But aren’t WCG the experts? If the traffic flow isn’t presented in the District’s OCP, because there is no 96-unit building on that site now, isn’t it the responsibility of WCG and the Developers’ proposal to identify what that change would be?

NY Expert2.jpg

Finally let’s not forget that the WCG conclusions assume that the building will be built on time and to budget. If it is not, how many of the planned affordable units will be reallocated to market rates so the OBUC can meet its financial goals?

That’s another worry for another day.

Let’s go back to those first four questions:

  1. Are their findings reasonable and logically supported? No. It is not logical to assume that over a hundred and fifty new residents in a single suburban block will have no impact on traffic.

  2. Have they taken an open-minded approach? Not that has been documented in their report. Not that anyone who lives in the immediate neighbourhood can verify.

  3. Does funding have a determination on their bias? Unknown. The WCG may have working relationships with some of the Developers beyond this project. If so, there may be a vested interest in delivering the conclusion that suits the client.

  4. Are the chosen experts the most qualified and the most trustworthy? Also unknown. However, if they are qualified, how did the most obvious dynamic of all escape their notice? How could they possibly not anticipate the simple and obvious fact that 96 new homes will bring a huge influx of people and traffic to any street, anywhere.

When one of the underlying studies for this project is so wildly off base, does it call into question what the other experts might have missed? Watch this space.