Dear Mayor & Council:
Re: Development Permit Application for 7592 119A St. and 7551, 7565, 7595 and 7597 120 St.
This development proposal is in direct conflict with policies and goals stated in the North Delta Area Plan and the Cougar Creek Integrated Stormwater Management Plan (ISMP). What’s the point of creating and adopting these plans if we’re not going to follow them?
• Area Plan says six storeys. (35 proposed here)
• Area Plan says encourage tree preservation, urban forest, a percentage canopy cover goal, watershed-based stormwater management, rainwater infiltration. (Proposal fails utterly on all counts.)
• Area Plan encourages public as well as private amenities in new developments, including pocket parks. (There’s hardly room for a skinny columnar street tree in this project. The project model is quite misleading in having wide green borders, which are in fact other properties that too could be developed like this one.)
• ISMP commits Delta to pursuing low-impact development — that is, development that allows for rainwater infiltration. (No such possibility here, as the parking garage for so many residential units must occupy the entire lot. This leaves no space for true infiltration, i.e. rainwater-to-groundwater infiltration that keeps Cougar Creek flowing during dry summer months. The site receives around 7 to 8 million litres of rainfall per year — virtually none of which would be infiltrated to groundwater if the proposed project is built.)
As for qualifying for “a tax exemption program and reduced municipal fees and charges” under the Scott Road Revitalization Bylaw, there is no way that the project as proposed meets the requirement for “low environmental impact” under this bylaw. Its environmental impact is very high indeed, because it causes significant and permanent loss of tree cover and stormwater infiltration capacity, which in turn contributes not only to degradation of environmental quality in North Delta, but also to an increased vulnerability to winter flood and summer drought (with attendant wildfire hazard in natural areas deprived of groundwater recharge).
Are there changes that would make this development acceptable? I’d say no, because going against the Area Plan will open the door to relentless pressure from developers to upzone other properties presently zoned for medium density or even single family. This encourages land speculation and pushes housing prices higher.
Highrise condos don’t even appear to solve the housing supply issue, judging by what’s happened in Vancouver: 25,000 empty units, the majority of them in highrise developments, according to the 2016 census. Highrise condos appear to be a magnet for speculative investment, both local and foreign, whereas six-storey buildings are far more likely to provide homes for people who actually want to live in them and participate in our community.
The only circumstance under which Delta should even remotely consider the Scott Road and 75A Avenue proposal would be if the developer offered very significant environmental mitigation, including a much-reduced underground footprint to allow for at least 15 per cent open space at the low southwest corner of the lot. This area should accommodate large trees and infiltration of rainwater runoff from the development, and also serve to cool the building in summer and de-stress everyone year-round. Why 15 per cent? Lessons from rain gardens, as to what ratio of permeable-to-impervious works well.
The six-storey apartment building at 75A and Scott on the Surrey side has enough open space to accommodate several large trees, including iconic B.C. evergreens. Note how building temperatures (high and low) can be mitigated by these trees, even at the top floor.
By contrast, The Rise at 80th and Scott has narrow deciduous trees crammed into tight little spaces. Several of them have in fact died, despite their tree-gator watering bags. Trees planted in minimal soil will never be able to provide significant energy savings, stormwater interception or other benefits. The proposed tower at Scott Road and 75A Avenue would be similar to The Rise.
Single-family lots are required to retain a minimum of 30 per cent permeable ground, yet when they are replaced by multi-family homes, including highrises, there’s no requirement for any permeable ground whatsoever; landscaping can be atop underground parking, with no linkage to groundwater. How can we have a healthy urban forest and streams, supported by a healthy groundwater supply, if we don’t require set-asides of permeable ground on the multi-family developments that are replacing single-family homes? How can this be sustainable in the long run?
How about we require all multi-family developments to set aside a minimum of 15 per cent totally-permeable land for trees and infiltration? In the short term, this will exert a downward pressure on land values — not necessarily a bad thing. In the long term, it will make North Delta an even more desirable community to live in, as well as a more flood- and drought-resistant one.
Rain gardens coordinator, Cougar Creek Streamkeepers