SUPPORTS ITEM NO. P&E COMMITTEE AGENDA Proposed Text Amendments to the Downtown O.C.P. and Amendme...
NOVEMBER 7, 1996    

                                        POLICY REPORT
                                  PLANNING AND ENVIRONMENT

                                                  Date: October 25, 1996
                                                  Dept. File No.  CP

          TO:       Standing Committee on Planning & Environment

          FROM:     Director of Land Use & Development
                    Director of Central Area Planning

          SUBJECT:  Proposed Text Amendments to the Downtown O.C.P.
                    and Amendments to the Downtown South Design Guidelines


          RECOMMENDATION

               A.   THAT the Director of Land Use & Development be instructed to
                    make application to amend the Downtown Official Development
                    Plan generally in accordance with Appendix A*;

                    FURTHER THAT the Director of Legal Services be instructed to
                    prepare the necessary by-law;

                    AND FURTHER THAT the application and by-law be referred to
                    Public Hearing.

               B.   THAT the existing "Downtown South Guidelines (excluding
                    Granville Street)" be amended by Council to incorporate the
                    changes noted in Appendix B*.

          CONSIDERATION

               C1.  THAT the Downtown South Guidelines (excluding Granville
                    Street) be further amended to incorporate the changes noted in
                    Appendix C*, calling for an average floor-to-floor height in
                    residential developments not exceeding 10 ft.

                                             OR

               C2.  THAT the Downtown South Guidelines (excluding Granville
                    Street) be further amended to incorporate the changes noted in
                    Appendix C*, calling for an average floor-to-floor height in
                    residential developments not exceeding 12 ft.

                                             OR

               C3.  THAT the Downtown South Guidelines NOT be further amended to
                    address a floor-to-floor height in residential developments.

          GENERAL MANAGER'S COMMENTS

               The General Manager of Community Services RECOMMENDS approval of A
               and B, and puts forward C1, C2, and C3 for CONSIDERATION. Technical


                                            - 2 -

               work on the original Downtown South Guidelines assumed standard 9'
               Ò floor-to-floor heights, typical at that time. There was little
               discussion of alternative floor-to-floor heights, but it was
               acknowledged as acceptable that buildings approached 300' overall
               height, provided they were outside view corridors and did not
               shadow key public open spaces. The initial public and Council
               acceptance of the guidelines may have been contingent on the
               implicitly assumed floor-to-floor heights, from which C-1 departs
               least. Current expectations may support more choice in unit types
               for which C-2 and C-3 provides increasing flexibility.

          COUNCIL POLICY

          -    On May 16, 1991, Council adopted the Downtown South Community Plan
               and on July 30, 1991, Council amended the Downtown Official
               Development Plan (DODP) and adopted the Downtown South Guidelines
               (excluding Granville Street) which provide design guidance on all
               aspects of development.

          -    On August 30, 1994, Council amended the  Downtown South Guidelines
               (excluding Granville Street)  to incorporate the Downtown South
               streetscape design.

          -    On January 17, 1994, Council instructed the Planning Department to
               report back on a suitable by-law or guidelines to restrict the bulk
               of buildings in Downtown South.


          SUMMARY 

          This report proposes amendments to the Downtown Official Development
          Plan (DODP) and to the Downtown South Guidelines.  The amendments are
          the result of a review of development applications processed and
          developments built since the community plan was approved.

          The changes to the DODP would:

          1)   permit live/work uses in the low-rise portion of developments;
          2)   give the Development Permit Board discretion to relax the height
               limit of 70 ft. on small sites to accommodate increased density for
               low-cost and social housing; and
          3)   add a section to emphasize the importance of the public realm in
               the downtown.

          The proposed changes to the Downtown South Guidelines include:

          1)   language to emphasize the importance of minimizing shadow impacts
               on public open space and shopping streets (Granville and Davie
               Streets);
          2)   guidelines to strengthen safety and security aspects of projects;
          3)   provision for self-contained live/work units in the low-rise
               portion of a development;
          4)   a guide to tower floor plate size to encourage slim towers;
          5)   reduction of the rear yard setback in low-rise portions of
               development to 10 ft. from 30 ft.; and
          6)   guidelines to upgrade the lane environment by providing more
               landscaping.


                                            - 3 -

          An additional amendment to the guidelines, brought forward for
          consideration, would provide a 10 ft. average floor-to-floor height or a
          12 ft. average floor-to-floor height in determining the maximum height
          of developments.

          BACKGROUND AND DISCUSSION

          The Downtown South Guidelines are used in conjunction with the Downtown
          Official Development Plan to assist applicants and staff in designing
          and evaluating new projects in the emerging residential community of
          Downtown South.  Granville Street is excluded because it has a separate
          set of guidelines.

          In the five years since Council adopted the Downtown South Community
          Plan, zoning and guidelines, more than 35 development applications for
          major projects have been received and 10  developments have been built
          or are under construction. This provides a good basis to assess the
          design guidelines.

          The review was conducted in consultation with the Downtown South
          Redevelopment Impacts Committee, members of the architectural and
          development communities, and the residents of Downtown South.

          Several major issues as well as numerous minor items were identified in
          the design review.  The following is a summary of the key issues and the
          proposed changes which address them.

          AMENDMENTS TO THE DOWNTOWN OFFICIAL DEVELOPMENT PLAN (DODP)

          The proposed amendments to the DODP are described below (refer to
          Appendix A* for detailed wording):

          1)   Live/Work Uses

               Permitted uses in Section 1 - Land Use have been expanded to
               include live/work uses in Downtown South.

          2)   Relaxation of Height Limits for Low-Cost Housing

               The maximum height limit of 70 feet serves well for 3.0 FSR
               developments.  However, for the increased density of 5.0 FSR
               allowed for low-cost and social housing, 70 ft. does not provide
               enough height on smaller sites to achieve adequate livability.  A
               relaxation of the 70 ft. height limit to a maximum discretionary
               height of 120 ft. for these projects is proposed.

          3)   Public Realm

               The design of the public realm is crucial to the development of
               Downtown South as an identifiable neighbourhood.  A reference
               outlining special streetscape areas in the Downtown District is
               proposed to be added to the Application and Intent Section of the
               DODP to emphasize the importance of the public realm for those
               precincts, and to highlight those areas which have specially
               designed streetscape treatments.

          AMENDMENTS TO THE DOWNTOWN SOUTH GUIDELINES


                                            - 4 -

          The proposed amendments to the Downtown South Guidelines are described
          below (refer to Appendix B* for detailed wording):

          Section 2.6:  Shadow Impacts

               Public open space will not be abundant in Downtown South. It is,
               therefore, important that all such open space be as usable and
               sunny as possible.  The proposed guideline amendments contain
               additional language to further emphasize the importance of
               minimizing the amount of shadow a development casts on public open
               space as well as shopping streets.

          Section 2.10:  Safety and Security

               In consultation with the Crime Prevention Through Environmental
               Design (CPTED) staff team, the safety and security aspects of
               development have been audited.  Detailed guidelines are proposed
               that will strengthen security aspects of projects.

          Section 3.0:  Ground Floor Units

               Recognizing the need for a high degree of flexibility at street
               level, self-contained ground-level units with direct access to the
               street could, under the amendments, contain live/work units which
               could also be converted to exclusively commercial (office) or
               residential use, while preserving the design objectives of the
               streetscape.

          Section 4.1.1:  Low Rise Portion at Street Edge

               Low-rise elements have been a component of the Downtown South built
               form from its inception with the present guidelines specifying a
               height of  several storeys .  To clarify the intent for  eyes on
               the street  (safety) and adequate definition of the street
               edge/public realm, the low rise portion of a development is
               proposed to be specified as a minimum 30 ft. in height.

          Section 4.1.3:  Tower Width and Floor Plate Size

               To provide more clarity on tower massing and the need for slim
               towers that minimize shadow and view impacts, staff have  specified
               a maximum tower width of 90 ft. and expanded on the present maximum
               floor plate guideline (6,500 sq. ft.) by including a table that
               specifies tower floor plate size in relation to tower height (i.e.,
               the taller the tower proposed on a given site, the slimmer it
               should be).  The proposed guide to maximum floor plate size is
               intended to define an acceptable building envelope relative to
               tower height without limiting the flexibility needed by the
               developer in regard to market objectives.  As a guideline, staff
               would see flexibility applied to the maximum tower width and floor
               plate size where heritage or view corridors are involved.

               Some members of the development community have commented that
               additional building bulk generated by double height or loft units
               is not a problem and that no further controls are needed in this
               regard.  Staff are concerned that the extent of additional bulk
               that could be added under present controls, in the order of 30-35%,
               would compromise overall livability by imposing greater shadows,


                                            - 5 -

               limiting outlook past neighbouring buildings and diminishing space
               between buildings, and are consequently recommending this
               additional bulk control.  (The issue of double-height or loft units
               is addressed below.)
          Section 4.2.3:  Rear Yard Setback

               Amendments to the rear yard setback guidelines would simplify and
               reduce the required setback from 30 ft. to 10 ft. for portions of
               developments lower than 70 ft. in height.  This would allow for
               more flexible and creative site planning.  Trees and landscaping
               will be encouraged in the rear yard setback and in vehicle entry
               courts to promote a "greening" of the lane.

          Section 5.5.3:  Lanes

               Amendments to the guidelines will ensure that the quality of the
               lane environment will be upgraded to include better finishes and
               more landscaping.

          OTHER AMENDMENTS

               Several additional minor amendments are included to provide more
               clarity and precision.  A summary of the revisions is attached as
               Appendix E*.

          The foregoing guideline amendments constitute the package contained in
          RECOMMENDATION B.  The recommended guideline amendments dealing with
          tower massing which augment existing guidelines go a long way towards
          addressing concerns about excessive building bulk and ensuring that
          Downtown South built form principles are maintained.  Council may wish
          to consider an additional component that is not fully dealt with in the
          recommended guidelines. This concerns developments which propose
          substantially higher ceilings or loft developments which could result in
          towers that, albeit slim by virtue of the recommended floor plate size
          guideline, would likely approach the maximum 300 ft. height.  Without
          any further control this would likely result in considerably more 300
          ft. towers than may have been anticipated.  Consequently, the following
          new Section 4.1.4 is put forward for consideration.

          Section 4.1.4: Tower Floor-to-Floor Height

               This new Section would further address the tower bulk issue
               generated by developments proposing loft or mezzanine units.

               Synopsis of the Issue

               The development industry s typical floor-to-floor height for
               residential buildings is in the range of 8'6" to 9 ft. depending on
               the type of construction.  This yields a ceiling height of 8'0" to
               8'6".

               Double-height ceiling spaces (i.e., 16-17 ft. floor-to-floor)
               increase the bulk and height of towers resulting in a net increase
               of 30% to 35% in tower volume at the same FSR.  Such taller,
               bulkier towers may have negative impacts such as increased
               shadowing on public or semi-private open space and reduction of
               views and sunlight for neighbouring projects.  Double-height
               ceiling spaces also have the potential to be illegally infilled


                                            - 6 -

               with floor area that would exceed permitted density and may not
               comply with Building Code requirements.

               To deal with this tower bulk issue, proposed amendments to the
               Downtown South Guidelines include more specific shadow criteria to
               reduce shadow impacts on public open space and major shopping
               streets (Section 2.6 above) as well as maximum tower floor plate
               sizes to limit building bulk (Section 4.1.3 above).  The
               constraints imposed by Council adopted view corridors would, of
               course, remain.  In addition, staff have explored options for
               further controlling tower bulk as follows:

               a)   Allow for lofts in double-height spaces by calculating floor
                    space ratio within the units at 1.4 times the floor area
                    (i.e., lofts at 40% of the floor area below), based on one of
                    several Building Code parameters by which mezzanines can be
                    permitted (suggested by the developer of a number of loft
                    projects):

                    This option addresses only the circumstances where
                    double-height units may be legally infilled with lofts after
                    occupancy of the unit.  In cases where lofts have been
                    indicated in the development permit submission, the loft area
                    would, of course, be included in the FSR calculations.  (Note: 
                    The Building Code does allow lofts at greater than 40% of the
                    floor area below - see memo from Permits and Licences in
                    Appendix F*.). Staff conclude this option represents the
                    status quo and could introduce other technical FSR problems
                    where lofts greater in area than 40% of the floor below are
                    proposed.

               b)   Count floor-to-floor heights over 12'0" as two times floor
                    space ratio (as done in RS-1 zones):

                    This option is the simplest method of restricting additional
                    bulk generated by loft units and does overcome the problem of
                    future illegal infilling of the double- height space by
                    allocating FSR in advance for this possibility.  However,
                    charging FSR to this double-height volume was also seen to be
                    quite onerous and would likely curtail much, it not all,
                    future loft development which a segment of the marketplace has
                    embraced.

               c)   Specify a maximum tower height based on an average
                    floor-to-floor height multiplied by the proposed number of
                    storeys, thereby allowing flexibility for some extra ceiling
                    height:

                    Two variations of this option are put forward as CONSIDERATION
                    C1 or C2.

                    CONSIDERATION C1 proposes a 10 ft. floor-to-floor averaging
                    throughout the development, thereby permitting floor-to-floor
                    height in excess of the 8'6" to 9'0" standard to be
                    distributed at the discretion of the developer.  For example,
                    some double-height (16 ft.) floors would be permitted if these
                    are balanced by an appropriate number of standard height
                    floors (approximately 5 standard height floors to average out


                                            - 7 -

                    one double-height floor).  Or, the developer may opt to build
                    units with predominantly 10 ft. floor-to-floor heights (9' to
                    9'6" ceiling heights).  Irrespective of a developer s choice
                    on how to achieve the 10 ft. average, the resultant tower
                    height would still be subject to view corridors and shadow
                    assessment on open space and shopping streets. This option
                    would ensure compact, generously spaced  buildings that
                    minimize shadow impacts.  However, while still accommodating
                    approximately 10% more tower volume for some additional
                    ceiling height, this option would constrain the percentage of
                    double height (loft) units that could be accommodated and
                    therefore housing choices in the communtiy. 

                    CONSIDERATION C2 is based on the same principles as  C1,
                    except that the height allowance is derived by averaging
                    floor-to-floor heights at 12 ft. instead of 10 ft.  This
                    option allows for more generous ceiling heights, including a
                    greater percentage of double-height (loft) units, that provide
                    a wider variety of unit types.  However, the additional
                    building volume of this option would generate additional
                    shadow and view impacts since proposals would likely be at
                    maximum tower height and width and would be straining against
                    other massing controls.

               Alternatively, should Council not be concerned about an increase in
               the number of 300 ft. high towers and in response to concerns about
               too many regulations and guidelines being imposed, staff put
               forward the option that would not pursue any floor-to-floor
               control. This option is put forward under CONSIDERATION C3.

               Public and Industry Comment

               The advantages and disadvantages of regulating floor-to-floor
               height have been debated at length.  Due to the controversial
               nature of this topic, staff have consulted the Urban Development
               Institute, the Architectural Institute of B.C., a number of 
               architects and developers active in the Downtown South area at an
               open house, the Urban Design Panel, and the Downtown South
               Redevelopment Impacts Committee.  Detailed comments are included in
               Appendix D*.

               The Downtown South Redevelopment Impacts Committee strongly
               supports regulations to prevent the additional tower bulk generated
               through loft unit development. They were concerned that it has
               taken too long to bring forward regulations that will control what
               they consider a serious problem. 

               The Urban Design Panel felt that additional tower bulk was a
               potential problem that could compromise the advantages of slim
               towers in Downtown South.  The method of regulation should provide
               a degree of flexibility so as not to hamper good design.

               The development industry has mixed opinions on this issue.  Some
               were concerned that the absence of controls for floor-to-floor
               heights may foster abuse of over-height ceiling spaces and result
               in taller, bulkier buildings.  Other members of the development
               industry felt that enough regulations were already in place and
               that more regulations would hinder variety and discourage market


                                            - 8 -

               options.  However, if the City was intent on bringing in new
               controls, the 10 ft. floor-to-floor averaging approach appears to
               be preferable to a 12 ft. FSR double-counting regulation. 
               Participants did not comment on the 12 ft. floor-to-floor averaging
               approach, as it was introduced by staff following community
               discussions to add more flexibility.  Some architects attending an
               open house on the subject felt that the additional tower volume
               generated by double-height units was not a problem.

               After consideration of the issues and comments received from these
               consultations, staff put forward CONSIDERATION C1, C2, or C3.

          ENVIRONMENTAL IMPLICATIONS

          Increased requirements for landscaping and greenery in the lanes will
          improve the air quality and livability of the neighbourhood.

          SOCIAL IMPLICATIONS

          Amendments to the guidelines to address safety and security concerns,
          lessen shadow impacts and minimize impact on private views all
          contribute to a more livable neighbourhood.

          CONCLUSIONS

          The proposed amendments to the DODP and the Downtown South Guidelines
          will address concerns about shadowing, safety and security, tower
          massing and other issues, and will provide future developments in
          Downtown South with more clarity and precision while still allowing
          considerable design and site planning flexibility.

          Staff recommend that the amendments to the DODP be referred to Public
          Hearing.


                                      *   *   *  *   *
                   Proposed Downtown Official Development Plan Amendments

                                     (RECOMMENDATION A)

                            Amendments are in italics, bold type

          APPLICATION AND INTENT

          The intent, in the adoption of this Downtown Official Development Plan
          and the accompanying guidelines is as follows:
          7)  to create a distinctive public realm and a unique and pleasing
              streetscape in the downtown.

          SECTION 1

          Land Use

          In the areas denoted by the letters 'L' and 'N' on Map 1, the following
          uses may be permitted.

          (h) Live/work uses *


                                            - 2 -

          In the area denoted by the letter 'M' on Map 1 the following uses may be
          permitted.

          (h) Live/work uses *

          *   to be further defined during preparation of the draft by-law for
              Public Hearing.

          SECTION 4
          Height of Buildings

          In areas 'L' and 'M' the height of a building on a corner site with a
          frontage less than 175 ft. or an interior site with a frontage less than
          200 ft. shall not exceed 70 ft., except for low cost housing and social
          housing projects where the Development Permit Board may permit an
          increase in height to a maximum of 120 ft. for the purpose of
          accommodating extra density for low cost housing and social housing
          developments, provided that it first considers:

              (a)  the size and location of the site;

              (b)  the intent of this Schedule, all applicable policies and
                   guidelines adopted by Council and the relationship of the
                   development with nearby residential areas;

              (c)  the bulk, location and overall design of the building and its
                   effect on the site, surrounding buildings and streets and
                   existing views;

              (d)  the amount of open space, and the effects of overall design on
                   the general amenity of the area;


              (e)  the provision for pedestrian amenities and public realm
                   requirements;

              (f)  the preservation of the character and general amenity desired
                   for the area; and 

              (g)  the submission of any advisory group, property owner or
                   tenant.

          SECTION 7

          Public Realm Design

          The purpose of this section is to help create distinctive areas and
          neighbourhoods in the downtown through the enhancement of the public
          realm with special treatment of the streetscape.

          The City has developed plans and guidelines for the design of the public
          realm for those areas highlighted on Map 6. 

          In addition to park designs and the normally required street designs,
          special public realm designs shall be provided in the denoted areas.

          Buildings, semi-public open spaces and setback areas should be designed
          and detailed to complement the design of the public realm.  Streetscape


                                            - 3 -

          designs as outlined in Council-adopted guidelines, manuals, and policies
          will form an integral part of development permit applications.

          Aspects to consider include, but are not limited to: setback
          requirements, paving, lighting, planting, driveway crossings, pedestrian
          entrances and walks, seating, display windows, weather protection,
          garbage storage, and loading facilities.


                                                                        APPENDIX C
                                                                       PAGE 1 OF 4

                     CONSIDERATION C1 (10 Ft. Floor-to-Floor Averaging)

                     Further Amendments to the Downtown South Guidelines


                       Further Amendments are in Italics and Bold Type



          4.1.4  Floor-to-Floor Height

                 Generally, the development industry s standard residential
                 floor-to-floor dimension is 8'6" to 9'0" yielding  ceiling
                 heights of 8'0" to 8'6".  This dimension provides a standard of
                 livability within dwelling units that has long been accepted by
                 urban and suburban dwellers.  In some instances higher ceiling
                 heights are desired to accommodate different markets and, to a
                 degree, this can be accommodated subject to the limits imposed by
                 view corridors, shadow criteria, floor plate size, and other
                 guideline parameters. Therefore, within the maximum heights
                 permitted in the Downtown Official Development Plan and subject
                 to the limits imposed by view corridors, and other criteria in
                 these guidelines, floor-to-floor heights may be adjusted through
                 the following 10 ft. floor-to-floor averaging formula.

                 a)  the overall height should be calculated by using a 10'0"
                     floor-to-floor height multiplied by the number of floors
                     proposed in the development.  Note: For the purposes of this
                     calculation, lofts or mezzanines which generate more than
                     10% open to below area are not counted as floors.

                 b)  On those sites where tower massing and height are
                     particularly sensitive (i.e., where shadowing of public open
                     space or Granville or Davie Streets may occur) a standard
                     floor-to-floor height should be used.


                                            - 4 -

          



                                                                      APPENDIX C                                                                     Page 3 of 4


                  CONSIDERATION C2 (12 Ft. Floor-to-Floor Averaging)

                 Further Amendments to the Downtown South Guidelines


                   Further Amendments are in Italics and Bold Type

     4.1.4  Floor-to-Floor Height

            Generally, the development industry s standard residential
            floor-to-floor dimensions is 8'6" to 9'0" yielding  ceiling heights
            of 8'0" to 8'6".  This dimension provides a standard of livability
            within dwelling units that has long been accepted by urban and
            suburban dwellers.  In some instances higher ceiling heights are
            desired to accommodate different markets and, to a degree, this can
            be accommodated subject to the limits imposed by view corridors,
            shadow criteria, floor plate size, and other guideline parameters.
            Therefore, within the maximum heights permitted in the Downtown            Official Development Plan and subject to the limits imposed by view
            corridors, and other criteria in these guidelines, floor-to-floor
            heights may be adjusted through the following 12 ft. floor-to-floor
            averaging formula.

            a)  the overall height should be calculated by using a 12'0"
                floor-to-floor height multiplied by the number of floors
                proposed in the development.  Note: For the purposes of this
                calculation, lofts or mezzanines which generate more than 10%
                open to below area are not counted as floors.
            b)  On those sites where tower massing and height are particularly
                sensitive (i.e., where shadowing of public open space or
                Granville or Davie Streets may occur) a standard floor-to-floor
                height should be used.




                                                                      APPENDIX E
                                                                     Page 1 of 3
                                    DOWNTOWN SOUTH                                                                  DESIGN REVIEW
                                  Proposed Revisions


      ISSUE                    PROPOSED REVISIONS


      2.4  Private views            -   require slim towers            protected                -   spacing of towers - i.e. offset
                                     -   siting of tower


                                                - 5 -


      ISSUE                    PROPOSED REVISIONS

       2.6  Shadowing                -   impacts on a hierarchy of spaces in order of
           - of parks                    importance
           - of open space               - parks
           - of public realm             - public open space
                                         - Davie Street & Granville Street
                                         - semi-private and private open space                                     -   buildings over 35 ft. high require a shadow impact
                                         analysis
                                     -   new developments should not shadow beyond property
                                         line of parks and public open spaces
                                     -   towers opposite or next to park or public open space
                                         cannot cast shadow for more than 1 hour between 10:00
                                         a.m. and 5:00 p.m.
                                     -   new developments on Davie Street
                                         - should not cast shadow beyond curb line on north
                                           side of Davie
                                         - no shadow from towers cast on sidewalk at noon                                     -   towers generate maximum 2 hours of shadow on
                                         semi-private open spaces on neighbouring developments
                                         between 10:00 a.m. and 4:00 p.m.


       2.10  Safety and Security     -   separate parking for residents from visitors and
                                         commercial parking
                                         - secure with gate
                                         - use strong materials in construction of separation                                         - allow for visual surveillance between areas
                                     -   secure visitor parking at night from general public
                                         access
                                         - install phone or buzzer systems at parking entrance
                                         - create separate internal corridor from visitor
                                           parking to outside buzzer system; do not mix
                                           circulation areas
                                     -   paint walls of parking garages and bicycle storage
                                         areas
                                     -   provide special security for units opening onto
                                         semi-private spaces                                     -   secure project open spaces that are at or near grade
                                     -   doors and windows of ground level units should face
                                         the street for visual surveillance
                                     -   reduce opportunities for graffiti and skateboarding


       2.11  Lanes

           - not enough greenery     -   upgrade appearance and servicing of lanes; more             in lanes                    landscaping
           - too much hard surface   -   improve appearance of porte-cocheres with lobbies,
             and blank,                  entrances and landscaped areas adjacent
             unattractive walls


                                                - 6 -


      ISSUE                    PROPOSED REVISIONS

           Street Access

           - curb cuts from          -   all vehicular access from the lane
             streets disrupt         -   allow street access only where there is no lane or
             streetscape                 for extraordinary sites sharing lanes with Granville
                                         Street; subject to conditions                                     -   require continuation of the streetscape, incorporate
                                         landscaping into design


           Porte-Cocheres            -   increase design and landscaping requirements in
                                         general
                                     -   provide landscape buffer between lane and
                                         porte-cocheres to offset hard surfaces

       4.1.1 Height and Length of
             Developments

           - not enough massing in   -   minimum streetwall height of 30 feet
             street wall

           - restricted uses in      -   allow flexibility and combination of uses for units             podium                      with direct access to street
                                     -   allow uses to change within self-contained units

                                     -   clear views from street into landscaped open spaces
           - open space in street    -   high quality detailing and design considerations for
             wall                        building(s), display gardens, facade treatment,
                                         landscaping, etc.


       4.1.2 Tower Height Shadow

           - shadow impact of        -   overall tower height to be evaluated against
             taller buildings on         hierarchial criteria for public objectives
             public open spaces          - ie. shadow, private views, etc.

           - maximum height limits   -   in DODP, relaxation of 70' height limit to 120 ft.
             of 70' for 3.0 FSR          for non-market housing projects
             projects too low to
             accommodate density             for non-market
             housing


       4.1.3 Tower Floorplate Size
           - floorplates too         -   maximum dimension of 90 feet
             large, do not result    -   6500 sq.ft. max. floorplate size
             in slim towers              - open balconies can project beyond limits, enclosed
                                           balconies cannot                                     -   guide to maximum tower floor plate size to encourage
                                         taller, slimmer towers; width of tower decreases as
                                         height increases
                                     -   some minor projections allowed into front yard
                                         setback above 80 feet in height


                                                - 7 -


      ISSUE                    PROPOSED REVISIONS

       ***
       4.1.4 Floor to floor          -   a variety of floor-to-floor heights permitted within
             heights                     limits set by an  averaging formula
           - double height units
             result in taller 
       4.1.2 Front yard setback      -   no change in setback
           - no change               -   emphasized in DODP


       4.1.3 Side Yard setbacks      -   no change

       4.1.4 Rear Yard Setbacks      -   rear yard setback reduced from 30 ft. to 10 ft. to
           - setback rules too           allow for more creative site planning
             complicated             -   corner sites to extend building element to rear
                                         property line at lane edge to continue streetscape to
                                         lane
                                     -   landscaping of rear yard setback is required

       4.3 Parking                      require parking entrances to be architecturally
              - parking entrances        treated and have landscaping incorporated wherever
       are dark                          possible
                 holes with blank
       walls

       4.4  Horizontal Angle of
            Daylight                 -   relaxation of horizontal angle of daylight for
                                         projects with max. 3.0 FSR provided 20 ft. of
           - too restrictive and         unobstructed view is maintained
             may compromise
             massing for smaller
             projects

       5.5  Lower Floors of
            Buildings
                                     -   main floor of residential units should be located
           - residential units at        3'0" above the street to promote privacy but still
             grade experience            allow for surveillance of the street from the unit
             overlook from the
             street
       5.5.3 Lane Edges

           - lanes are bleak and     -   no blank walls facing the lane
             unwelcoming             -   more landscaping and architectural treatment of lane
                                         facades


       7.3  Private Open Space
           - min. balcony size of    -   allow for "French" balconies
             49 sq.ft. was           -   allow for surveillance of public realm from private
             inconsistent with           outdoor spaces
             trend to smaller
             units


                                                - 8 -


      ISSUE                    PROPOSED REVISIONS

       8.1.4 Garden Setback Area

           - display garden area     -   ramps must be provided but not by displacing
             was being displaced         landscaping
             for ramps for
             disabled access

       8.3  Pacific Boulevard

           - sites which front on    -   front yard setback, streetscape and massing on
             Pacific fall between        Pacific Boulevard should respond to False Creek North
             Downtown South and          Official Development Plan; remainder of project
             False Creek North           should respond to Downtown South Guidelines
             Guidelines


                                                                    - 9 -



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