Old Information Prior to STCP Being Adopted

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These comments were submitted to Surrey City Clerk’s office, in time to be sent out to the Mayor and Council as part of their agenda package on the Thursday before the Council Regular Meeting on January 31. The comments were based on the draft final Semiahmoo Town Centre Plan (STCP) that was put on the City’s website in the middle of January. The corporate report accompanying this Plan was not released to the public until the Friday, before the Council meeting; additional comments could have been sent to Council before noon on Monday.

Secondary plans in Surrey do not warrant public hearings before approval, Surrey’s usual procedure is to make the proposed plan available to the public only three days over a weekend before the Council meeting. So we would like to express our appreciation to City staff for putting this 200-page Plan online and informing stakeholders of its existence a week earlier than normal. In the absence of any other notice to the public, we endeavored to inform them it is available.

Tripling residential units and population is excessive growth for a small town centre with no planned access to rapid transit lines except buses. We do not wish to become part of a bland, urban, high-rise cluster.  There are other parts of Surrey more suitable to accommodate Metro Vancouver’s growth requirements with greater chance of becoming complete communities and having less impact on existing residential neighbourhoods, e.g. along the Skytrain line. It is up to the City, not Metro Vancouver, to decide how much of an increase in population should occur in the Semiahmoo Town Centre as compared with other Surrey town centres on or planned for the Skytrain line. 

The City has said local jobs will likely only be in the services sector. So we were surprised to see an increase of 5,000 jobs forecast in the Plan and wonder where this figure came from.

We are pleased to learn that the City is moving towards a zero carbon policy, but urge the proposed target date of 2050 be advanced to 2030. We also strongly object to using bonus densities as an incentive. No incentive should be needed.  We are requesting that the City promote, in particular, mass timber construction which would reduce carbon dioxide emissions from buildings considerably, is cheaper than concrete to construct, and which has lower height limits.

During Stage 1, participants were promised in open houses and in written statements that detailed design studies, would be carried out in Stage 2. It was expected that these would develop a pleasing overall urban form or character that would optimize location of buildings, protect view corridors, and minimize adverse effects on existing residential areas. The studies could affect land use designation areas, densities, and building heights, as well as urban design development permits. These studies have not been done.  When questioned, City staff used the excuse that such studies were not carried out for other town centres in Surrey. However, other town centres may not have Semiahmoo’s high-rise issues or a population interested in such studies. We accepted them not being done in Stage 1 because we were told they would be conducted in Stage 2, and we expect the City to fulfill its promises.  We were also told that it is not necessary to do these studies now because they would be carried out after the Plan is approved, when each site gets rezoned. But in order to create an overall attractive urban form, there has to be an overall design showing how one building relates to and fits in with the others, as was developed for the City Centre. Otherwise, we are back to allowing piecemeal redevelopment, which may be good for a particular site, but not necessarily for its neighbours. 

We are requesting that these detailed design studies be done before this Plan is brought to Council for approval. They should include consideration of optional forms of development to high-rises, which has never been explored with residents for this town centre, despite excessive height being an often-raised concern from the public. It would include 3-D imaging and perspectives, which are notably lacking in this new version of the Plan. It would be very difficult for any citizen to visualize and assess the effects of the Plan without these tools.

This rezoning application along 18thAve./Martin Drive, was the subject of two virtual public meetings held by the developer in February, 2021 and viewed by less than 50 people. The rezoning will be coming to Council for approval in a few months and will be the subject of a public hearing at that time. All rezonings are required to comply with relevant secondary plans before approval.  

While we thank City staff for reducing the maximum heights allowed in that part of the high-rise  area from 24 to 20 storeys, this is not enough.  We feel that 20 storey towers would still severely overlook and overshadow nearby residential areas, as shown in sun-shadow diagrams produced by the developer. Placing about 600 units in three towers on a two acre net site, produces net densities more appropriate to a city centre, and is excessive and unnecessary. It is putting about a quarter of the total new units planned for the Mall redevelopment on one tenth of the whole 20 acre Mall site. 

The perspective opposite was provided by the developers at the virtual meetings and supports our contention that the north end of the proposed redevelopment is overloaded.

Part of the Stage 2 process is preparation of development permit guidelines regarding the form and character of new development. In the case of the STCP, the urban design guidelines included in the Stage 2 report seem to be standard throughout the City, irrespective of different locational circumstances.  This duplication and lack of consideration of specific localities or maximum heights or densities leads to conformity, not distinction. We feel towers should be required to be set further apart here than in the higher-density City Centre. We also question why an exception has been made in the case of the maximum floor plate standard which has been set at 650 sq.m. here compared with the recently confirmed 600 sq.m. standard for all of the rest of Surrey. We will be questioning, at the public hearing allowed for this rezoning, why City staff appear to have already agreed to the proposed standard being increased to 680 sq.m. for this Phase 1 rezoning application.

Since development permit guidelines must be incorporated into the OCP by amendment, we would like to see them, please.

We are concerned that the public’s issues with the amount and distribution of development have not been adequately addressed and may have been “played down”, despite the 3 open houses, and 7 on-line surveys in the public engagement process, and despite several statements by the City acknowledging these issues and promising to address them. Only two of these surveys were conducted during Stage 2, which was in the time of covid, and we feel this was not enough consultation. Our reasons for our concerns are as follows:

a) The success of the public engagement process appears exaggerated.  It is claimed in the Plan that there was huge response to the engagement process, with “over 30,000 residents being involved” in the process. But adding participants in surveys, events, phone calls, etc. produces only about 5,500 participants. Maybe people were counted for each time they responded to a survey and many replied to nearly all of them, or recipients of the mailed cards were counted, whether they answered or not. In any case, the sheer volume of response is no measure of its success, especially if a survey does not provide all pertinent information, if highly relevant questions are not asked, and if published results unfairly favour a predetermined outcome. 

b) Not all relevant questions were asked in the seven on-line public opinion surveys. In the core area, the public was actually never asked what amount of growth or height of buildings they preferred, nor given optional overall building forms to consider other than high-rises. 

c) Some survey questions were not explained or only partly explained. Hence they were liable to be misunderstood, e.g. asking participants in the July 2021 survey to choose between two building height maps, the second having 20 hard-to-identify and completely unexplained changes in it.  A better solution would have been to allow each change to have been assessed individually, or in groups, to build up the best plan.  

d) Some results may have been interpreted to claim greater support for the plan than in fact exists, e.g. the claim in the Stage 1 final report that 55% of survey respondents agreed the Plan would somewhat or greatly address growth and housing challenges, when growth was never mentioned in the question and the 35% who said “somewhat” could have meant anything. In the same report, it was stated that “throughout the process survey results have indicated a majority support for the plan”.  But this question was never asked in any of the seven surveys. 

e) One survey was particularly unhelpful. We feel the last survey in July 2021 that is supposed to have consulted the public about 50% of the final Plan content, is particularly disappointing and unhelpful. Its design was unusual in that responses on policies and initiatives were, with two exceptions, confined to verbatim comments, and these boxes were labelled optional, which did not encourage responses. One exception was the subsection regarding choice of one of two building heights maps without any explanation which is described in section (c) above. We found this section particularly useless and its results are in any case, too close to reveal a majority conclusion (but it has, nevertheless, been used for this purpose).  The other exception, about which no comment at all was allowed, is a Refinements to the Land Use Plan where 6 changes to the land use designations of Stage 1 were introduced, without any opportunity for all affected parties to previously comment on them. These include locating a new bus layover in an unusual part of the Mall. 

Perhaps as a result of the survey design problems, the survey results were published in only a half-page summary as part of the Public Engagement process on the City’s STCP website. We felt the analysis of the verbatim comments was superficial: it found 4 general themes were supported (First Nations Reconciliation, green development measures, public plazas, and road designs and improvements). These are improvements that one would expect to be supported.

There were also 4 outstanding concerns identified (amount of growth Surrey is experiencing, need for more green space and mature trees, traffic and parking in the interim as Surrey shifts to a less car dependent City, need for more radical climate change policy).  So, as we have some members with experience in designing and analysing surveys, we did our own analysis after obtaining a list of the verbatim comments from the City under FOI.  We found a wide variety of comments that were very difficult to group into common themes, which made the results of much of the survey not very valuable. We hope that the City is taking note of some useful suggestions made by individual or small numbers of participants.  

While our analysis confirmed 3 of the 4 supported themes described above, we must question if significant numbers of participants supported road design and improvements, other than internal mall roads. We must also very seriously question why building height issues were not identified as a concern when they constituted over half of the comments in the urban design section and were also prominent in the Ground Floor and Other Feedback boxes. We also disagree with the phrasing of the concern about traffic and parking, in that the addition of “as Surrey shifts to a less car dependent City” was not in the survey and is inappropriate and misleading. In fact, we see little opportunity in this Plan for citizens to become less car-dependent, due to many additional roads being planned and still allowing on-street parking in the Mall area after it is redeveloped.

We also noted that the verbatim comments included in the example page provided on the STCP website all supported the Plan, even though they do not represent anything like the majority of comments.

We would suggest that Council members might like to request a copy of the survey questions from this July 2021 Survey, to assess our claims.

So we have to conclude that the City’s surveys, in both design and result-reporting, are unfair and showing some bias in favour of the City’s and developers’ positions. We are requesting a fair survey. 

SEE RECOMMENDATIONS AT THE START OF THIS DOCUMENT FOR CONCLUSIONS.

 20 July 2021
To Kristen Lassonde Planner, City of Surrey

Re: SRA's comments on Survey of Stage 2 Semiahmoo Town Centre Plan draft policies

The Executive of the Semiahmoo Residents Association is very disappointed in this on-line survey, in its timing, its format, its contents, and its proposed Stage 2 policies.   After our contact with City staff since February, we had hoped for a degree of understanding of our position from staff, but that has not materialized.  In these circumstances we feel we must go public with our concerns, as described below, in order of presentation in the survey:

1. Timing - We feel that the survey is ill-conceived at this time because it should have waited until Sept when an open house for the public could have been held, where much more information could have been provided and questions answered.  A survey could have been conducted after that, as was done throughout Stage 1 public engagement.  Staff's argument that the survey has to be done now because there is insufficient time to wait another 6 weeks, hold a draft plan meeting and allow Council to approve Stage 2 by the end of the year is specious because the world won't change if Council approves it in February instead.  Surely, staff should not be held to deadlines set by Council or senior staff when covid has taken so long to subside.
It is also not clear to us whether the statement that "we will report back one more time before we finalize the plan this fall" actually presents a further opportunity for public comment, or whether it will be a document providing the results of this survey and how you will respond to them.  Please clarify.

2. Survey Introduction - The introduction does not address whether the amount of growth provided for in the plan is necessary or not. This should not be taken as a given, as City staff are claiming.  The Semiahmoo Town Centre is not planned for rapid transit other than buses.  With plans now emerging for extending Skytrain to Langley it is becoming more and more apparent that Surrey's share of Metro growth should be concentrated along this line and not in South Surrey.

3. Amount of Public Engagement - The explanation of the process in the survey does not explain that the workshops, open houses, and 6 of the 7 on-line surveys took place between 2018 and early 2020, before Stage 1 was approved. This is about 95% of the public engagement events.  Stage 2 public consultation has consisted only of the November 2020 on-line survey, plus this new one, and any meetings and walkabouts requested by stakeholders. We feel this is inadequate, even in times of covid.
Incidentally, we would appreciate the results of the November 2020 survey being returned to the STCP part of the Surrey website.  It seems that when the new survey was put on line, there was a clear-out of material, except for the Stage 1 approval report.  

4. Choice of how much to answer - We continue to question the value of allowing (almost encouraging) respondents to select which of six sections they respond to.  As there is a save button on each page, the survey can be completed at leisure.  While the results may give the number responding to each question, will the published results sort each section by its demographics and places of residence? Otherwise cross tabulations will be useless.

5. "Refinements to the Land Use Plan" - We found this plan to be very unsatisfactory. As distinct from the Stage 1 Plan which contained both land use designations and maximum building heights, building heights have been separated out into a later question (see below), which may not be clear to many responders.  In a proper public consultation process, people should not just be told that these six changes have been made since March 2020, they should be allowed a chance to comment on them via a comment box.  For instance, the introduction of a bus layover area in the Mall off 16th Ave. is brand new and deserves some explanation.  People may not understand why its adjoining buildings would have to be residential rather than commercial.
We also want to mention that we find it strange that the White Rock Christian Academy is shown on this plan as a "civic" designation. This may give the wrong impression to some people not familiar with it.

6. Building Heights - We have already received a number of complaints about the two Building Height maps alternatives being too hard to understand to answer. One map is the building heights contained in the Stage 1 approved plan, as amended by the "refinements" to designations introduced at the start of this survey, and the second is described as a proposed Stage 2 building heights map.  In talks with City staff, we had supported the idea of a building height map, but had expected it to have some rational base and be accompanied by an explanation and a comment box so that people could explain their answers.  Every other question in the survey has an explanation/proposed policy and a comment box, but this does not. We believe that at least responders should have been directed to using the final comments box, close to the end of the survey, for comments on this question, and these comments would be referenced back to that question.  Otherwise, the results from this question are likely to be meaningless and useless.

With respect to individual building height changes between the two alternatives, the City is proposing that within the high-rise designations, instead of a maximum of 24 storeys throughout that area, heights would range from 28 storeys along 16th Ave. to 20 storeys at the north end of the Mall at the three towers site.  Although we are pleased that a range is being introduced rather than loading so much height and density onto the north end as per the three towers rezoning application, we oppose 28 storeys and want 24 storeys there and 12 storeys at the north end.  Lost density can be made up by extra towers at the south end, not higher towers.   We also feel that the mid-rise transition zone between the high rises and existing 3-4 storey apartment buildings of up to 12 storeys and in the "medical district", is far too high for a transition/buffer zone.  The City is also proposing reducing heights in some low rise residential areas along Martin Drive and Semiahmoo Cres. E., from 6 to 4, and creating an 8-storey node at 152/24th Ave., and allowing up to 16 storeys on the site immediately west of Amica/Hilltop Medical on 16th Ave.  We have no idea why, and responders should not be faced with making decisions on these without any information.

After our conversations with staff, we had been expecting to see mention in the survey of a policy that height and density have to be earned and that not all buildings will qualify automatically for the maximums. This would require development of appropriate criteria, such as size of lot, and siting with respect to impacts on other buildings. But there is nothing.

7. Ground Floor Uses - We feel that the amount of emphasis placed on "active" or "active plus less active" ground floor uses is surprising.  Surely the City is not intending to have two separate zones for these two groups, as we doubt it can be enforced otherwise.  We suggest that only "active" for the south side of 24th Ave. between 152 and 154 Streets is not appropriate.  There are drug stores, medical clinics and real estate offices here, and few pedestrians, except in the Peninsula Village plaza, opposite.

8. Green and Sustainable Initiatives are very much supported by us.   We urge the City to adopt this as the overall special character/theme for the Semiahmoo Town Centre.  However, we feel that the objectives described in the survey are superficial and commonly used in Surrey, and do not go far enough in achieving something special.  The City's proposed zero carbon policy should be incorporated even if it is not yet an official policy.  Architecture as well as streetscape should be "green".  A comprehensive building by building storm water management system and a district heating system should be introduced for all phases of the Semiahmoo Mall Redevelopment and extended to nearby redevelopment.  The use of cross laminated timber as a construction material instead of concrete should be encouraged.

9. Urban Design Guidelines - We feel that reiterating the same minimum distances between buildings, minimum floorplates (but already exceeded here), etc. as used in the City Centre, is not appropriate for this small suburban town centre.  Our towers should be lower and more dispersed with less overlooking and overshadowing of existing residential buildings.  Little was done on urban design during Stage 1, but proper building massing and 3-D imaging studies were promised for Stage 2, in order to establish the optimum densities and heights for each individual parcel or group of parcels.  However we have now been told these studies will not be done.  In response, we recommended a design charette where a team of experts would work together to develop optional designs for the town centre that take into account overall urban form, view corridors, juxtaposition of other buildings etc.  Again the answer was no.   We feel that South Surrey is being short-changed here, and that much more work should be done in this area, so that there is some basis to develop locational criteria or allocate maximum heights and densities per parcel or group of parcels (see Item 6 above).

10. Streetscapes and road designs details have been included for the first time, and we do not like them.  In the Mall area, the City is allowing parking lanes on all roads except the pedestrian street, with one minor exception.  We thought parking was going to be underground, to maximize open space.  The design also requires 4.0 to 4.5 m wide "commercial setbacks" for commercial buildings from road rights of way, which presumably the developers would have to pave, with bits of landscaping.  The proposed pedestrian street (which is now located south of an area designated for 24 or 28 storey buildings, where it won't get much sun) is the same except no parking or bicycle lanes.  We fear that such wide distances between buildings across streets and so many roads and on-street parking could completely change the anticipated "special character" of the town centre, making vehicles and paved areas dominant, rather than pedestrians and green space.

We also wonder how 17th Ave. east of 152 St, is really suitable to be a 24m wide collector road.
If it can be arranged, we would appreciate an opportunity to talk with the appropriate person in the Engineering Dept. about our concerns with these road designs.

11. Plazas - We feel there should be a plaza at the S.W. corner of 152 St. and 18th Ave. opposite the Library's "living wall", as a significant entry into the commercial core of the Semiahmoo Town Centre.

12. Parking requirements - We have no objections to the proposed parking requirements, which will be underground.

13. Densities are not mentioned in the survey at all.  You have advised us that densities are not going to change from Stage 1, which are in the 2.0 to 2.5 FAR range, plus bonus densities. We feel that allowing densities as high as 2.0 in low rise residential areas is overcrowding some sites and should be lowered, subject to locational criteria.  We also continue to request that the implications of the City's bonus system be pointed out to the public, e.g. possibility of developers buying density, possibilities of maximum heights also being exceeded.  We feel that there should be specific density bonuses for this area, as with other secondary plans, which reflect local amenity needs, and which are developed in consultation with local residents.

14. Amenities are described in the Plazas section as being a performing arts theatre and an art gallery, based on a survey of needs at least 10 years old.  We feel the public should have been asked what they want, rather than asking them if they agree with such expensive items as a performing arts centre and a public art gallery and not much in other options.    
In conclusion we feel we are being short changed in urban design studies and need a full public engagement process not just two online surveys before staff finalize Stage 2 policies.  Because of these and other concerns, and in view of your perceived time constraints, we have no real option other than to go public with our concerns.

Thank you for your attention,

Rosemary Zelinka

Vice-President SRA