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Planning West
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Land use planning and development: comprehensive legal services for local governments throughout British Columbia. Our lawyers, several of whom are certified planners with Master’s degrees, advise on and litigate complex land use planning and development issues on behalf of local governments. Through our services, we help to lay the foundation for growth in large and small communities across the province. VANCOUVER OFFICE KELOWNA OFFICE 1616–808 Nelson Street 201–1456 St. Paul Street Box 12147 – Nelson Square Kelowna, BC V1Y 2E6 Vancouver, BC V6Z 2H2 T: 250.712.1130 T: 604.689.7400 F: 250.712.1880 F: 604.689.3444 Toll Free: 1.800.665.3540 www.younganderson.ca
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by Joan Chess-Woollacott MCIP, RPP
Welcome to the fall… after Vancouver. This year’s event will be held at the Westin Bayshore in
what I hope was a wonder- Vancouver on Saturday, November 10. Be sure to register to attend
ful summer for everyone. this fantastic annual event. Members are encouraged, wherever
Fall is often a season of they live and work, to mark this special day for our profession.
transition and busy activ-
ity for many of us. Speak- Thinking further ahead, we are also excited to be hosting our
ing of transitions, I’d like planning colleagues from across Canada and beyond at next
to take this opportunity year’s joint CIP-PIBC annual conference in Vancouver, July
to welcome Iain Bourhill 6-9, 2013—so mark your calendars. Be sure to check out the
MCIP, RPP as the newest conference website, including the call for proposals—which
member of PIBC Council. is looking for unique, engaging, and substantial sessions—as
Iain is the Deputy Direc- well as the innovative call for digital media—which is looking
tor of Planning at the City IRUSKRWRJUDSKVLPDJHU\íOPDQGYLGHRWRDXJPHQWWKH
of Colwood, near Victoria, conference experience. It promises to be a truly valuable and
DQG MRLQV &RXQFLO WR íOO D memorable conference.
vacancy created with the I hope everyone enjoys the crisp fall season! +
departure of Holly Foxcroft
MCIP, RPP earlier this year.
And the transitions don’t stop there. As many members are aware,
the planning profession in Canada—including PIBC, is in the midst
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standards and new university accreditation standards through Editor’s Note ........................................................ 4
the nationally based Professional Standards Board (PSB). We are
pleased to have former PIBC President Finlay Sinclair MCIP, RPP %D@STQDR
as PIBC’s representative on the PSB. The PSB, CIP, and provincial Helping to Create Places around Transit ........... 5
DQGUHJLRQDO$IíOLDWHVLQFOXGLQJ3,%&DUHZRUNLQJWRJHWKHUWR Velo-City Global 2012 ......................................... 8
get these exciting new processes up and running.
Road Pricing......................................................... 9
From this point forward, individuals interested in professional Planning & PlaceSpeak...................................... 12
PHPEHUVKLSDFURVV&DQDGDZLOOíUVWDSSO\IRUDQDVVHVVPHQWRI “Can’t They Just Tell Us What To Do?” ............ 14
WKHLU TXDOLíFDWLRQV WKURXJK WKH 36% EDVHG RQ WKH QHZ VWDQ- Legal Update ..................................................... 15
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Vancouver Urban Forum ................................... 18
for the formal admission of new members (following PSB as-
sessment), and will continue to be the primary point of contact Educating Planners on Wetland Stewardship . 22
and member-service delivery point for professional members. Michael Rosen MCIP .......................................... 23
The PSB will also be responsible for administering the univer-
sity planning program accreditation process on behalf of the (MRSHSTSDÐ-DVR
profession, again based on the new standards.
PIBC Council Notes ............................................ 25
And speaking of the onset of fall, we are also looking forward to Membership Committee Report....................... 26
another World Town Planning Day event in celebration of our Membership Renewals & Removals ................. 26
profession. PIBC is again hosting a gala dinner and celebration
WRKRQRXUORQJVHUYLQJSURIHVVLRQDOPHPEHUVDQGQHZO\FHUWLíHG Cover Photo: The Urban Systems transportation team, along with
Registered Professional Planners in British Columbia and the Yu- the company cargo bike, attended Velo-City this year. Credit:
kon. We are also pleased to be hosting CIP national council at this Urban Systems Ltd.
year’s event, as they will be holding their November meeting in
%@KKÐÐ 
$CHSNQiRÐ-NSD World Town Planning
by Siobhan Murphy MCIP, RPP Day 2012: Join Us!
T
he fall issue is HUGE, as we have stories that
should have been in the summer issue but Join us on 2@STQC@XÐ-NUDLADQÐ Ðin
couldn’t be squeezed in because of our cover- recognition of World Town Planning Day,
age of the PIBC Conference in late May/early June. for this gala celebration and recognition
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of the planning profession in British
all the new and held-over copy.
Columbia and the Yukon at the Westin
This issue has transportation stories galore, which Bayshore in Vancouver.
I hope you’ll enjoy. We haven’t had enough stories
about transportation, and now we have coverage
of the VeloCity Conference held this summer, and Ð/,Ð Ð/QD #HMMDQÐ1DBDOSHNM
a Road-Pricing lecture from the spring sponsored Ð/,Ð Ð&@K@Ð#HMMDQÐ@MCÐ/QNFQ@L
by the PIBC South Coast Chapter, the Sustainable
Transportation Coalition and the SFU City Pro-
gram. Rounding out the transportation offering is Don’t miss this annual
a piece that showcases TransLink’s resources for celebration of our
municipalities and stakeholders to create places profession.
to support transit, walking and cycling. These re-
sources are part of a coordinated approach to land
use and transportation and support TransLink’s
For more details and
Strategic Plan and MetroVancouver’s Regional to register online visit
Growth Strategy. VVV OHAB AB B@
Other articles include an update on Party Walls by
Bill Bulholzer, and an article about PlaceSpeak, Host Sponsor: Carvello Law Corporation
which is a new online engagement tool that was
developed right here in Vancouver and is having
good uptake in the Lower Mainland and elsewhere.
Other items include a PlanTalk event about how
planners can support First Nations planning and
another on how planners can incorporate Wetland
Planning West
Stewardship into their policies. Finally, there is a
memorial for Michael Rosen, an esteemed planner
Submission Deadlines
who passed away this year and was a valued mem-
ber of our profession; he will be missed. Planning West is published quarterly, every
winter, spring, summer and fall.
Last but not least, I want to remind you about World
Town Planning Day, which we are celebrating here
in Vancouver on Saturday night, November 10, at The following deadlines apply:
the Westin Bayshore Hotel here in Vancouver. Please
6HMSDQÐDecember 15, 2012
come and join us if you can, and welcome our newly
minted planners and honour our esteemed planners 2OQHMFÐMarch 15, 2013
who have been part of the Institute for 25 years. 2TLLDQÐJune 15, 2013
Hope to see you there! + %@KKÐSeptember 15, 2013
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by Lyle Walker MCIP, RPP and Michelle Babiuk, PIBC Candidate Member
TransLink is often asked by municipal staff across Metro Vancouver for the secret to bringing
fast, frequent and reliable transit service to their communities. Recognizing that the “best
transportation plan is a supportive land use plan” and that land use is the domain of
local government, TransLink has developed several resources for municipalities and other
stakeholders seeking to create places that support not just transit, but increased levels
of walking and cycling as well.
T
hese resources are part of a collaborative approach to
coordinating land use and transportation that supports
Metro Vancouver’s Regional Growth Strategy (RGS),
TransLink’s Regional Transportation Strategy (RTS), and mu-
nicipal land use and transportation plans.
Shifting from Transit-Oriented
Development to Transit-Oriented
Communities
As planning professionals, we have often focused on “transit-
oriented development” (TOD) with an emphasis on individual
buildings or development projects adjacent to rapid transit sta-
tions. However, because the design of entire regions, communi-
ties and neighbourhoods affects transportation choice, we pre-
fer to focus the conversation on “transit-oriented communities”
(TOCs) with its broader focus beyond individual development
sites to the design of the entire community at all spatial scales.
Transit-oriented communities are places that, by their design,
allow people to drive less and walk, cycle, and take transit
more. In practice, this means concentrating higher density,
mixed-use, pedestrian friendly development within walking
distance of frequent transit, in combination with measures to
discourage unnecessary driving. As people in these communi- the cost-effectiveness of transit service. When paired with an
ties tend to shift their travel away from driving, they generally improved public realm, they improve livability and are the
consume less fossil fuel energy, use more of their own energy foundation for a sustainable transportation system and region.
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gas emissions. In addition, these types of communities improve (continued next page)
%@KKÐÐ Transit (cont’d) quality transit, and the tenants are willing to pay a premium
for this accessibility.
Coordinating Land Use with Frequent
The “6 Ds” – It’s not just about Density
Transit So how do we go from the theory of transit-oriented communi-
Traditionally, rapid transit has been top of mind as the type ties to actually designing them? There is no single “right way”
of transit that is well suited for higher density development. to create successful TOCs. There are, however, six key attri-
However, this focus ignores the high accessibility and level of butes that contribute to high levels of transit demand—Destina-
service provided by other high-quality transit services. Recog- tions, Distance, Design, Density, Diversity, and Demand Man-
nizing this, both Metro Vancouver’s RGS and TransLink’s RTS agement—what we refer to as the “6 Ds” of transit-oriented
use the Frequent Transit Network (FTN) as the framework for communities. While there is much focus on the role of density,
coordinating land use and transportation. The FTN is a network the literature shows that density alone has a very weak direct
of corridors where transit service is frequent enough that pas- relationship with travel behaviour. Instead, density is a proxy
sengers do not need to refer to a schedule. These corridors con- for the other “Ds”—dense settings commonly have central loca-
nect most urban centres and major activity areas, thereby re- tions, short blocks, mixed uses, good transit, and parking man-
inforcing the region’s centres and corridors concept. Corridors agement in place.
included in the FTN have transit service of every 15 minutes
or better throughout the day and into the evening, 7 days a Ultimately, to be most effective at increasing walking, cycling
ZHHN7KH)71GRHVQRWUHIHUWRVSHFLíFWHFKQRORJLHVRUYHKLFOH and transit and decreasing driving, all “6 Ds” need to be imple-
types—any type of service or vehicles ranging from rapid transit mented in concert at the regional, corridor, neighbourhood and
to bus can provide this level of service within a corridor. site scales. To assist communities with incorporating these at-
tributes in their plans and processes, TransLink, in consultation
with our stakeholders, has developed a set of Transit-Oriented
Shifting Development Focus to Transit Communities Design Guidelines organized around the “6 Ds”.
Just because planners think something is a good idea, doesn’t
necessarily mean that there is a market for those ideas. How-
ever, there has been a recent, remarkable shift in development
Putting the Guidelines into Practice
activity in Metro Vancouver. Bob Rennie, the Condo King, has The TOC Guidelines are available for anyone to help support the
recently proposed that in the 1990s the development mantra SODQQLQJRIERWKQHZFRPPXQLWLHVDQGWKHUHWURíWWLQJRIPRUH
was “location, location, location”, in the 2000s it was “timing, mature neighbourhoods. While we encourage you to borrow
timing, timing” and in this decade and beyond it is “transit, liberally from this document, we also expect that you will need
transit, transit”. The market has responded—the developer now to adapt the guidelines to suit the local context, local input and
UHFRJQL]HVWKHEHQHíWVRIWUDQVLWDQGKDVVHHQDQLQFUHDVHGPDU- unique situation of each community.
ket interest in high density and transit-oriented development.
The TOC Guidelines are intended to provide ideas and best
7KLVVKLIWUHîHFWVSHRSOHªVLQFUHDVLQJZLOOLQJQHVVWRSD\DSUH- practices as input to:
mium to locate in areas that are easily accessible, walkable and
OCPs, neighbourhood, station area and corridor plans
livable without needing to own or rely on a car. As a result,
substantial development activity in Urban Centres, around Implementing community energy and emissions plans
existing rapid transit lines and along the Evergreen Line has Development proposal creation and review
created a transit-oriented renaissance. Market interest in walk- Transportation network design
able, mixed-use, higher density transit-oriented development is Street design standards
likely to continue to grow, especially at locations with a high Transit facility integration
level of transit service and an array of community amenities. Design charrettes
In addition to this longer-observed trend in the residential mar-
NHWDVLPLODUWUHQGLVQRZRFFXUULQJIRURIíFHGHYHORSPHQW$ Resources
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TransLink has also developed other resources, as indicated in
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the table on the next page, to help our stakeholders plan more
around rapid transit have higher lease rates and lower vacan-
livable communities around transit.
cies than elsewhere in the region. Developers are now seeing
the compelling business case for developing in areas with high (continued next page)
Ð /K@MMHMFÐ6DRSTransit (cont’d) and neighbourhood design. Finally, we will continue to col-
laborate with municipalities to improve land use and transpor-
tation coordination at all spatial scales.
Future Activities
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Over the next year, TransLink will be reaching out to share to create more walkable and bikeable places around transit. +
these materials with more stakeholders. We will also be work-
ing with Metro Vancouver to implement related concepts in the Lyle Walker is a Senior Planner at TransLink:
implementation of the Regional Growth Strategy and incorpo- Lyle.Walker@translink.ca
rating elements of transit-oriented communities in our updated
Michelle Babiuk is a Planner at TransLink:
Regional Transportation Strategy. We’ll also be conducting em-
Michelle.Babiuk@translink.ca
pirical research on how the “6 Ds” affect transportation out-
comes to help inform municipal decisions on land use densities
Table: TransLink Resources for Creating Transit-Oriented Communities
TransLink Resources Description Audience
Transit-Oriented Communities: This short Primer introduces the FTN and the lÄ General public
A Primer on Key Concepts “6 Ds” and illustrates the key concepts with lÄ $KDBSDCÄNEÆBH@KR
graphics for a non-technical audience. lÄ Municipal staff (planners, engineers,
architects, etc.)
lÄ Developers
Transit-Oriented Communities These Guidelines outline strategies for designing lÄ Municipal staff (planners, engineers,
Design Guidelines communities around frequent transit to support architects, etc.)
walking, cycling and transit. Case studies, lÄ Developers
checklists and other resources help translate lÄ Consultants
guidelines into implementation.
Transit-Oriented Communities To streamline planning and development lÄ Development planners
Checklists application review, a set of checklists for lÄ Developers
transit-orientation is provided for the corridor,
neighbourhood and site planning scales.
Transit Passenger Facility This document offers guidance to TransLink lÄ TransLink and municipal planning staff
Design Guidelines and its municipal partners in designing transit (planners, engineers, architects, etc.)
passenger facilities (stations, exchanges
and stops) and integrating them with
neighbourhoods.
Managing the Transit Network: This Primer outlines the objectives, principles lÄ Municipal planners
A Primer on Key Concepts and considerations, including land use, that lÄ $KDBSDCÄNEÆBH@KR
TransLink takes into account when designing lÄ General public
new transit services or making changes to
existing services.
Frequent Transit Network Map This map, showing the existing FTN in Metro lÄ Municipal staff (planners, engineers, etc.)
Vancouver, is an essential feature for the walls lÄ Developers
of planning and engineering departments lÄ Realtors
around the region.
lÄ General public
All the above resources and more can be found on TransLink’s website at www.translink.ca/TOCs
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by Kate Berniaz, Urban Systems, and Hailey Steiger, PIBC Candidate Member, Urban Systems
Discussing how to get more people on bicycles in communities around the world was the focus
of the Velo-City Global 2012 conference, hosted this June in Vancouver. The international
conference, organized by the European Cyclists’ Federation, brought together planners, engineers,
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T
he Velo-City conference has been taking place since 1980, are children.i This was yet another demonstration of how high
and now alternates between a European and international quality facilities that are comfortable and safe get more partici-
host city annually. With a variety of plenary sessions, pation by everyone, including more vulnerable groups.
workshops, and technical tours, attendees enjoyed an energiz-
ing week immersed in all things bicycling! Velo-City discussions also focussed on the need for social
marketing and education to encourage people to bicycle,
With the program full of renowned speakers, the line-up kicked once the bicycle infrastructure is in place. Recent research
off with Gil Peñalosa opening the conference. Peñalosa brought compared New York City and Chicago, two cities that have
his hard-hitting talk to the Vancouver stage, speaking of his invested heavily in cycling infrastructure improvements.
time as the City Commissioner of Parks, Sport and Recreation NYC was able to double their mode share and Chicago qua-
in Bogotá, Columbia. He highlighted that during that time, he drupled theirs, credited not only to the infrastructure im-
was able to use limited resources to create over 200 parks, initi- provements, but to the policies, and education and awareness
ate the hugely successful ciclovias (car-free days), and develop initiatives the two cities delivered.ii As well, a conference
a world-class bicycling city. Having accomplished this in a city workshop focussed on marketing and education, emphasiz-
far poorer than many in North America, Peñalosa drove home ing that a generic “biking is good” marketing campaign is
the point that there is no reason that Vancouver, and other cit- not enough in this world of information overload. Instead,
ies, can’t be more aggressive in getting more bicycle infrastruc- targeted marketing needs to customize information and
ture on the ground. And not just any type of bicycle infrastruc- delivery to different groups of people based on their interests
ture is enough, as Peñalosa was clear that bike lanes or shared DQGEHQHíWVRIF\FOLQJ IRUH[DPSOHH[HUFLVHVSHHGFRVW
use lanes will not result in dramatic changes. Instead, Peñalosa environment, ease).
urged cities to be bolder with separated bicycle facilities, such
as cycle tracks, which are much more safe and comfortable, and Coming away from this conference, there was optimism that in
thus more effective in getting people pedalling. the future, bicycling will be a part of all planning and develop-
ment projects, and not just as a second thought or add-on if
This was a common theme among many of the Velo-City speak- there is extra funding. Planners have the opportunity to change
ers and sessions, with many focussing on cycle tracks as the behaviour and put more people on bicycles—connecting land
key to attract bicyclists of all ages and abilities. The confer- use to transportation, focussing on complete streets, and inte-
ence also included much discussion on getting more women grating facilities. The conference demonstrated what exciting
and kids on bicycles, and included the signing of the Charter times we are in to actively plan our cities and make it easier
of Vancouver on Children and Cycling by participating mayors. and more enjoyable to do so. +
Many workshops mentioned ‘safe routes to school’ programs
in North America, that have been successful in getting kids to .DWHLVDSROLF\DQDO\VWLQ8UEDQ6\VWHPVª9LFWRULDRIíFHDQG
walk and bicycle to school. City of Vancouver staff shared sta- rides her orange Townie to work. Hailey is a planner in Urban
tistics recorded after the installation of the Hornby Street and 6\VWHPVª9DQFRXYHURIíFHDQGHQMR\VDFFHVVWRWKHRIíFHªVQHZ
Burrard Bridge cycle tracks. The numbers showed that after the Christiania cargo bike.
cycle tracks were installed, the portion of women bicycling on
Hornby Street increased from 28% to 32%, and that on average,
i
http://former.vancouver.ca/ctyclerk/cclerk/20120613/documents/ptec2.pdf
2.5% of bicyclists on the Burrard Bridge on summer weekends ii
http://policy.rutgers.edu/faculty/pucher/TRA960_01April2011.pdf
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by John Calimente, PIBC Candidate Member
2Q$SULOWK9DQFRXYHUSODQQHUVWUDQVSRUWDWLRQH[SHUWVDQGLQWHUHVWHGFLWL]HQVJDWKHUHGWRKHDUDERXW
6HDWWOHªVURDGWROOLQJH[SHULPHQWDVZHOODVWKHYLHZVRIDORFDOSDQHORQURDGSULFLQJ,QWURGXFHGE\*RUGRQ
Price and moderated by Peter Ladner, the event began with Matthew Kitchen, policy analyst with the Puget
Sound Regional Council, introducing us to the transportation challenges that Seattle has faced, and the so-
lutions they are currently piloting, including a new variable toll on the SR 520 Bridge that connects Seattle
with the suburb of Bellevue.
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Richard Walton – Mayor of the District of North Vancouver and Chair of the TransLink Mayors’ Council
Louise Yako – President and CEO, British Columbia Trucking Association
Vince Lalonde – General Manager, City of Surrey Engineering Department
Lon LaClaire – Manager of Strategic Transportation Planning, City of Vancouver
Tamim Raad – Director, Strategic Planning and Policy, TransLink
Funding Infrastructure and Dealing porary measure, “…a second best alternative to what people
had been pretty accustomed to, which was paying tolls on road
with Congestion LQIUDVWUXFWXUH¨VDLG.LWFKHQ$VZHOOWKHFXUUHQWíQDQFHDS-
While there are many similarities between Vancouver and Se- SURDFKHV ZKLOH HDV\ DQG HIíFLHQW WR DGPLQLVWHU DUH íVFDOO\
attle, size and built form are not among them. At about 3.2 weak, don’t generate the revenues that they once did, and also
million people, the population of the Seattle region is only don’t fundamentally improve the performance of transporta-
50% greater than that of Metro Vancouver, and this popula- tion infrastructure.
tion is geographically much more dispersed. But Washington
State has also worked to reduce unplanned growth through So as major roads in the Seattle region have neared their capac-
the Washington State Growth Management Act, which was ity, the Puget Sound Regional Council decided to look again at
passed in 1990. As Matthew Kitchen explained, this legisla- tolls as a way to reduce congestion and raise revenue for other
tion means that Washington State has “…built in this level transportation improvement projects. Tolling is also part of the
of consistency between what we’re intending to do on the Council’s Transportation 2040 plan, which anticipates an even-
infrastructure side and the expectations of how we would ac- tual need for tolls on most of the highway infrastructure in the
commodate growth.” Seattle region.
Historically, large highways and bridges were built by pri-
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ZDVWKHíUVWVWDWHLQWKH8QLWHG6WDWHVWRLQWURGXFHIXHOWD[HV Experiment
and within 10 years every state had a fuel tax. In Washington In 2006 the Council began a road pricing experiment where
State, road construction is funded mainly through fuel taxes.
But from the beginning, the fuel tax was intended to be a tem- (continued next page)
%@KKÐÐ Road Pricing (cont’d)
residents were recruited to drive with GPS-
based tolling devices in their vehicles. Tolls
were levied on select pieces of infrastructure,
which the participants could see charged on
the meters in their vehicles. The tolls were
based on the time of day and type of road they
were driving on, and were levied against a
unique travel budget provided to each house-
hold that was based on their normal travel
behaviour. Participants were told that they
would be given any remaining account bal-
ance in the travel budget at the end of the
18-month study.
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behaviour in small, subtle ways that they
themselves often didn’t perceive. And impor-
tantly, the researchers realized that even a
small amount of behaviour change could lead
Photo courtesy John Calimente, PIBC Candidate Member
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tion when added up across the whole system.
This could be a profound opportunity to improve the way of a new bridge, which is scheduled to open in 2014. The new
the road system performs. By using network tolling, an esti- bridge will be six lanes, with two general purpose lanes and
mated $36.6 billion in travel time savings could be achieved, one carpool/transit lane in each direction, and can accommo-
an amount equal to fully 3% of the total gross state prod- date light rail in the future.
uct for Washington. It demonstrated that there exists a major
Based on the road tolling experiment, it was estimated that
economic opportunity to be realized that has been left on the
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According to Kitchen, the data also told researchers “…mile by 45%, but since then has rebounded to a 35% reduction.
by mile on the road infrastructure where most of the revenues There has been some diversion to other facilities, and also a
were generated from tolling…” and also exactly how much par- UHGXFWLRQ LQ WULSV PDGH 7UDIíF LV QRZ UXQQLQJ DW IUHH îRZ
ticipants were willing to pay for the use of the roads. This data speeds over the bridge, which according to Kitchen, “no one
can now be used by transportation planners to select projects has seen in years”.
that conform to people’s preferences. While it doesn’t neces-
sarily mean that roads need to be expanded where demand is
highest, it does mean that there is a market on certain roads for
Key Lessons from Seattle’s experience
some improvements. Fuel Taxes are good: While fuel taxes have been a success-
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don’t generate the revenues they once did. They are also a
Tolling Begins poor tool for improving system performance.
The introduction of new variable tolls on the State Route 520 Tolls are better: While tolling is more expensive to install
Floating Bridge at the end of 2011 was a watershed project for and administer than existing sources of transportation rev-
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rate tolls and the SR 167 Hot Lanes is operated on a variable and decreasing congestion on tolled routes at peak times.
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WKURXJKRXWWKHGD\EDVHGRQWKHGHPDQGSURíOHLQWKHFRU- must be used productively.
ridor. Tolls vary from zero in the 11pm to 5am time period to
as high as $3.50 in the morning and late afternoon peak pe-
riods. The tolls were introduced in order to fund construction (continued next page)
Ð /K@MMHMFÐ6DRSRoad Pricing (cont’d) not be adding more road capacity, transit investment will be
needed. As for the City of Surrey, Kitchen’s presentation gave
Vince LaLonde both “hope and angst”. He was impressed with
Driver reactions to tolling are becoming better understood:
Seattle’s long-term commitment to road tolling and Surrey’s
Based on its experiments since 2006, Seattle is beginning to
view is that Metro Vancouver should begin working on such
develop a solid understanding of how drivers react to the
a project. On the other hand, there is concern in Surrey about
implementation of road tolls, where demand in the system
what will happen when the Port Mann Bridge is tolled. While
is greatest, and how much drivers are willing to pay in a
6HDWWOHVDZDRIWUDIíFPRYHWRRWKHUURXWHVWKHSUR-
tolled road system.
vincial Ministry of Transportation and Infrastructure is pre-
GLFWLQJRQO\RIWUDIíFZLOOUHURXWH5LFKDUG:DOWRQRIWKH
Factors in Public Acceptance District of North Vancouver agreed with Matthew Kitchen’s
Kitchen related that whether the public accepts tolling as op- assertion that the value proposition has to be evident to all
SRVHG WR WKH WUDGLWLRQDO íQDQFLQJ V\VWHP ERLOV GRZQ WR IRXU groups. He also added that one of the challenges in Metro
questions: Vancouver is that the people planning for the movement of
goods are usually different from the planners who work on
1. Who pays? the movement of people, so there is a disconnect.
2. :KREHQHíWV"
Louise Yako of BC Trucking stressed that road pricing will not
3. ,VLWDPRUHHIíFLHQWV\VWHP"
affect the behaviour of trucks or trucking companies unless
4. Is the level of privacy acceptable? it affects the behaviour of customers. If road pricing would
5RDGWROOVFDQSURYLGHDVL]DEOHXVHUEHQHíWLQWHUPVRIWUDYHO SURYLGHDEHQHíWLQWHUPVRIWUDYHOWLPHVDYLQJVLWZRXOGEH
time savings, but the researchers calculated that the revenues something that the trucking industry would be willing to con-
JHQHUDWHGE\WROOLQJDUHHYHQODUJHUWKDQWKLVEHQHíW7KHUHIRUH VLGHUDVDPHDQVWRLPSURYHHIíFLHQF\$VZHOOWKHLQGXVWU\
it is essential to do something productive with these revenues is interested in a more direct payment system for the services
that the public values. As Kitchen notes, “A central question in gained by using public road infrastructure, rather than the
public acceptability will be whether there is an opportunity to current road user taxes and fuel taxes. And as well, the objec-
VLJQLíFDQWO\LPSURYHHQRXJKIDFWRUVZKLOHNHHSLQJWKHRWKHUV tive to be achieved needs to be very clear from the beginning.
from getting worse”. 0DWWKHZ.LWFKHQDGGHGWKDWZKLOHZHNQRZWKDWEHQHíWVDUH
accruing to commercial vehicles with road pricing, the reality
RIZKRH[DFWO\LVUHFHLYLQJWKRVHEHQHíWVLVVWLOOXQNQRZQ
Panel Discussion on Metro Vancouver
and Tolling Road Tolling in Metro Vancouver
2XUíYHSDQHOLVWVZHUHWKHQJLYHQWKHRSSRUWXQLW\WRUHîHFWRQ If Metro Vancouver is to see an expansion of road tolling
what the Seattle region has accomplished so far and what we across the region, there needs to be a clear set of objectives
may learn from their experience going forward. Tamim Raad in place about what the region would like to achieve with
of TransLink noted that we have created a well-funded and tolling. We need to be very intentional and deliberate about
well-run transit system in Metro Vancouver. Our region has a what we are setting out to do. A road tolling system for Metro
transit service supply about twice that of Seattle and along with Vancouver will necessarily be quite different from what has
twice the population density, resulting in four times the service been created in Seattle and other cities. To be a success, a
intensity of the Seattle region. While successful in terms of regional perspective will be necessary, whereby tolls could be
ridership, Raad noted that TransLink “hasn’t been as successful introduced not simply on bridges but more generally on ma-
LQKDYLQJDVXIíFLHQWDPRXQWRIIXQGLQJDQGWKHIXQGLQJWRROV MRU URDGV ZLWK KLJK WUDIíF GHPDQG 6LQFH WKLV ZLOO OLNHO\ EH
as a means of providing market signals to shape demand and a long-term project, a road tolling experiment in our region
land use that we are looking for.” He also felt it important for similar to the one set up by Matthew Kitchen and the Puget
the region to think about why we are interested in road pric- 6RXQG5HJLRQDO&RXQFLOZRXOGEHDJRRGíUVWVWHSWRXQGHU-
ing, whether it is a way to shift the tax burden from property stand the key issues and start a productive dialogue. +
taxes, to send market signals to the system, or a means to fund
the system.
In Vancouver, downtown parking charges act as the City’s
tolls, said Lon LaClair. He pointed out that a good reason to
invest in transit is to grow the economy; since Vancouver will
%@KKÐÐ /K@MMHMFÐÐ/K@BD2OD@J
Ð5@MBNTUDQÐ&QNVMÐ/TAKHBÐ"NMRTKS@SHNMÐ/K@SENQL
by Maureen Mendoza, PIBC Student Member
Imagining Online Consultation identity through an authentication process;
When Colleen Hardwick wanted to affect the decision-making 2. %\XVLQJWKHJHRYHULíFDWLRQSURFHVVWRWUDQVIRUPWKHZD\
process around transit development in her Vancouver neigh- people in neighbourhoods interact with “location-based is-
bourhood, she started by imagining a different landscape for sues”; and
public consultation. 3. By advancing the public consultation process through an
online platform that enables, and encourages inclusive,
Recognizing that many traditional methods of current public
informed participation, allowing evidence-based deci-
consultation—mailers, telephone polls, open houses—no longer
sion-making.
gain response rates from citizens as they may have in the past,
Hardwick realized that people are online as the Internet pro- Within the past year, PlaceSpeak has gained momentum in
vides both an invitation and challenge to improve civic par- the Lower Mainland, steadily achieving province-wide support
ticipation. and interest across Canada. Its encouragement for residents to
§&ODLP \RXU 3ODFH 6SHDN \RXU 0LQG¨ UHVRQDWHV DIíUPLQJ WR
Hardwick imagined a series of what-ifs: what if you could be users that local decision makers value their input.
QRWLíHGRIFRQVXOWDWLRQVUHOHYDQWWRZKHUH\RXOLYHZRUNDQG
play? What if people had to verify who and where they were For planners who do stakeholder engagement as part of their
online in order to be legitimately counted in consultation? work but face challenges in getting feedback, bringing the con-
:KDWLIFLWL]HQVFRXOGLQîXHQFHRXWFRPHVEHFDXVHWKHLUYHUL- versation online presents the potential of connecting with citi-
íHGLQSXWHQDEOHGHYLGHQFHEDVHGGHFLVLRQPDNLQJ" zens who have lost trust in the decision-making process, or who
may never participate otherwise. Part of PlaceSpeak’s strategy
Imagining just how different public consultation could be LVWRGHYHORSWKH§JDPLíFDWLRQ¨DVSHFWRIDXVHUIULHQGO\SODW-
IRU SODQQHUV JRYHUQPHQW RIíFLDOV DQG GHFLVLRQ PDNHUV LI form, using non-monetary rewards and an enticing interface to
those what-ifs were realities, Hardwick realized that there encourage participation.
ZDVQRRQOLQHSODWIRUPDWWKHWLPHWKDWVDWLVíHGWKRVHXQLTXH
requirements—she would have to build it. She did and called it 2QFH D FRQVXOWDWLRQ LV FUHDWHG SURSRQHQWV PDS RXW VSHFLíF
PlaceSpeak. consultation boundaries. This geographic control allows for
VSDWLDOO\GHíQHGGDWDFRPSDULVRQ3URSRQHQWVWKHQJDLQLQSXW
and provide user information in a variety of ways, including
PlaceSpeak: How it Works discussion forums, event pages, polls and surveys, media gal-
PlaceSpeak was developed to connect people to consultation leries and notice boards. The platform easily allows for social
WRSLFV EDVHG RQ WKHLU ORFDWLRQ 3ODFH6SHDN YHULíHV D XVHUªV PHGLDLQWHJUDWLRQDQGVKDUHVSOXJLQZLGJHWVVRVSHFLíFSURM-
online identity with their addresses of residence, work, and ects can be featured on websites and linked to its PlaceSpeak
recreation so they can voice their opinions on local issues. consultation page.
7KLV JHRYHULíFDWLRQ LV NH\ GLIIHUHQWLDWLQJ WKH SODWIRUP
from other online engagement tools. Given the increasing A key PlaceSpeak feature allows proponents to deliver mass
need for qualitative and quantitative data in the decision- QRWLíFDWLRQV DERXW SXEOLF RSHQ KRXVHV RU UHSRUW XSGDWHV
making process, PlaceSpeak provides proponents with the 7KLV QRWLíFDWLRQ FDSDELOLW\ LV YLWDO LQ FRPPXQLFDWLQJ RXW-
FRQíGHQFH WKDW WKH\ DUH UHFHLYLQJ IHHGEDFN IURP WKH ULJKW comes of the consultation to residents after it is complet-
places and that users are non-anonymous as they are au- ed. Another key differentiator is that PlaceSpeak serves as
thenticated to participate. D EDQN DV XVHUV FDQ EH QRWLíHG RI VXEVHTXHQW WRSLFV RQFH
they have signed on.
PlaceSpeak enhances community consultation in three dis-
tinct ways:
1. By connecting users’ digital identity to their real world (continued next page)
Ð /K@MMHMFÐ6DRSPlaceSpeak (cont’d) DUHWKHUHWKH\ªUHZKRWKH\VD\WKH\DUH¨%HKODIíUPVWKDWEH-
coming more accountable to citizens and connecting through
public consultation is the key: “They’re the people we work for
PlaceSpeak’s Early Adopters: and we want to hear from them”.
Engaging Citizens, Connecting Issues, PlaceSpeak also continues old surveys with new technology.
(MÇTDMBHMFÄ#DBHRHNMR The Urban Futures Survey began in 1973 and was repeated in
PlaceSpeak continues to grow at its early adopter stage, as 1990. The survey provided the basis for many of the policies
online consultation is still a great leap of faith for many ex- in the Livable Region Strategic Plan adopted in 1996 by the
perimenting in digital engagement. A year young, the plat- Greater Vancouver Regional District (now Metro Vancouver).
form has hosted a variety of consultations in the Lower Main- The new Urban Futures survey is currently being deployed on-
land and across BC. In the past year, PlaceSpeak consultations line (as of October 1, 2012) to get input from residents to plan
have included: for the future of the MetroVancouver region.
City of New Westminster’s Master Transportation Plan, in- Ken Cameron FCIP, who has held senior planning and manage-
cluding Pattullo Bridge replacement options ment positions with the City of New Westminster and Metro
The Greater Vancouver Urban Futures Survey 2012 Vancouver, appreciates taking the old survey and putting it in
this new online format. He said, “Doing the 2012 survey online
City of Vancouver Mayor’s Task Force on Housing
through PlaceSpeak not only provides updated data at a frac-
Affordability
tion of the cost, it also means that future surveys can be done
The Islands Trust Strategic Plan
more frequently and more economically.”
'LVWULFWRI7RíQRªV7VXQDPL6LUHQ7HVW 3LORW6WXG\
Town of Gibsons’ Harbour Area Plan (Pilot Study) This fall, PlaceSpeak will begin to host consultations for
Metro Vancouver and TransLink. The platform continues to
One example of PlaceSpeak’s consultations has been the City of garner interest from planners who not only acknowledge
New Westminster’s consultation regarding their Master Trans- the challenging realities of public consultation but also the
portation Plan that sought input regarding the expansion of the potential opportunities for online innovation. Planners
Pattullo Bridge. should certainly be appreciated for taking a chance on new
At the start of the consultation, each proponent is given a civic technology.
§%HVW2QOLQHDQG2IîLQH3UDFWLFHV¨FKHFNOLVWWRSURPRWHWKHLU Hardwick recently submitted a white paper on Best Practices
topic. New Westminster’s planning and communication team in Online Public Consultation to the City of Vancouver, high-
followed these practices that included a press release and lighting key ways local governments and decision-makers—
municipal website integration. As a result, almost two hun- planners included—can turn to digital technology to enhance
dred residents connected to take the survey—a much higher citizen participation. Hardwick acknowledges that the success
response rate than received from the open houses the city RIDQRQOLQHFRQVXOWDWLRQLVODUJHO\GHWHUPLQHGE\RIîLQHHI-
conducted. Thanks in part to the authenticated results from forts. Among her recommendations is to centralize consultation
the PlaceSpeak consultations, TransLink reversed its deci- through open-data arrangements so that online consultations
sion and has decided to collaborate with Surrey and New become as standard and operationalized as open houses. This
Westminster in reviewing other alternatives for the Pattullo will be aided by PlaceSpeak’s API (application programming
redevelopment. interface) development, enabling third-party collaboration with
Jerry Behl, a Transportation Engineer for the City of New West- other engagement tools in need of the platform’s geo-authen-
minster and key contact for the consultations was impressed tication technology.
with the outreach and was “surprised by the sheer number of Online engagement requires the continuous imagination
people who logged on and took a look; we covered a lot of of what is possible in an age when technology is constant-
bases this way. We gave the people the option of turning up at ly being developed and changing. As planners look for
an open house in the afternoon, in the evening, or coming on new ideas for engagement, PlaceSpeak stands out for its
to PlaceSpeak.” innovative approach.
Behl acknowledges that non-anonymity required on Place- How big is the potential? Ken Cameron puts it this way:
Speak adds legitimacy to information because “ …the fact that “PlaceSpeak can be to spatial networking what Facebook is to
people have to register with PlaceSpeak and give some sort of social networking.” +
LGHQWLíFDWLRQDGGUHVV¦DOWKRXJKWKDWªVFRQíGHQWLDODQGSHRSOH
don’t see that—it gives us a sense of comfort that these people
%@KKÐÐ j"@MiSÐ3GDXÐ)TRSÐ3DKKÐ4RÐ6G@SÐ3NÐ#N k
Professional Planners Working to Bridge the Divide
between Municipal and Aboriginal Planning Initiatives
E\&KULVWLQH&DOOLKRR0&,3533 FRXQWHUîRZ#WHOXVQHW DQG-HVVLH6LQJHU MHVVLHDVLQJHU#JPDLOFRP
3,%&6RXWK&RDVW&KDSWHU3ODQWDONKRVWHGDQHYHQLQJRIGLDORJXHLQWHQGHGWREULGJHWKHSUR-
verbial gap often encountered between municipal and Aboriginal planning.
Entitled “What can WE (Professional Planners) do to support PRUH VSHFLíFDOO\ WKH JXLGDQFH SURYLGHG E\ WKH )LUVW 1DWLRQV
First Nation Planning?” the panel session was held at the SFU members of the panel deserves an audience without the au-
+DUERXU&HQWHURQ0DUFKWKZLWKíYHSDQHOLVWVIURPDGL- WKRUVªíOWHULQJ
versity of planning perspectives. Panel members (listed from
left to right in photo above) included Andrew Bak (Legislator, The following are excerpts from the session that were captured
Tsawwassen First Nation), Luke Thomas (Family Program Coor- by the generous student volunteersi. In providing the follow-
dinator, Tsleil-Waututh Nation), John Ingram (EcoPlan Interna- ing quotes and paraphrases, the reader is able to appreciate the
tional), Cheyenne Hood (Community Services Coordinator for sense of honesty and willingness to share brought to the ses-
the Tsleil-Waututh Nation), and Bruce Robert Muir (Land Use sion by the First Nation panelists.
Manager, West Moberly First Nations).
Luke Thomas, Tsleil-Waututh Nation:
The focus of the panel was to explore where professional plan-
“That is one of the things you will have to learn work-
QHUVíWLQWRSODQQLQJZLWK)LUVW1DWLRQVZKLOHDGGUHVVLQJTXHV-
ing with First Nations, you will have to do things that
tions such as: Are there overlapping interests and responsibili-
make you feel uncomfortable.
ties between reserve and municipal land planning? And what
DUH WKH LPSHGLPHQWV DQG EHQHíWV SURIHVVLRQDO SODQQHUV DQG Slow down the pace to keep it with the pace of the
First Nations face in coordinating planning efforts? people; that’s one thing to think about—that it’s our
land so it’s got to be done right.
The panelists described to an audience of about 60 session par-
ticipants their experiences dealing with the joys, frustrations Don’t come in as a planner; come in as a human be-
and lessons taken from attempting to implement new ways of ing. Treat us like equals.”
collaborating between municipalities and reserves. The discus-
sion touched on some common obstacles encountered when Cheyenne Hood, Tsleil-Waututh Nation:
attempts were made by each of the parties to collaborate. These
obstacles were particularly felt when it was realized that histor- “It is important for people to know where I come from
ical injustices had left one side with reduced capacity to engage because our journey shapes how we see things.
meaningfully with the planning process. I think the thing I wanted people to understand, is that
Advice given to professional planners in attendance focused we have been doing things your way for a long time. I
primarily on the need to emphasize relationship and trust am not mad, but we have been doing things differently
building when entering into long-term strategic planning. A from our ways for 125 years [~age of Vancouver] and
willingness to listen to community needs and, where appropri- where has this gotten us?
ate, redesign planning processes to better suit local desires were We don’t plan for 5 or 10 years, we plan for our chil-
highlighted as essential for any success. dren, our grandchildren, for seven generations. We
In writing this article to share with our fellow professional look at land differently; it’s not ‘what can I build on
planners what was learned at the session, the authors realized LW"ª,WªV©ZKDWDUHWKHEHQHíWV WKHRXWFRPHV"ª+
that the strength in what was shared throughout the session
remained with the speakers; the members of the panel. Perhaps
Ð /K@MMHMFÐ6DRSLegal Update
1DFHRSDQDCÐ/@QSXÐ6@KKÐ
FQDDLDMSRÐ-NVÐ6G@S
by Bill Buholzer FCIP, RPP, Young Anderson Barristers and Solicitors
party wall (noun) – an imaginary wall separating many British Columbia towns and
cities from a type of medium-density housing that constitutes a large proportion of the
long-term affordable housing stock in cities like Montréal, New York and Toronto.
T
KDWLVQRWRIFRXUVHDSURSHUGHíQLWLRQRI§SDUW\ZDOO¨ the owners of units sharing a party wall have no registered
but is meant to suggest the reason that planners ought agreement in place to govern its maintenance and repair cre-
to be interested in some recent minor amendments to ates potential liability for the municipality. Whether or not
the Land Title Act that permit the registration of party wall that is sound advice, the indisputable fact is that extremely
agreements that “run with the land”. A party wall, according few of these units have been constructed in this province.
to a standard legal dictionary, is “a wall erected on a property
boundary as a common support to structures on both sides,
which are under different ownerships”. A party wall could The Solution
separate two dwelling units in a side-by-side duplex, or ad- Division 4.1 of Part 14 of the Land Title Act will now allow
jacent dwelling units in a multiple-unit row house project, or for the registration of party wall agreements.1 Presumably, de-
adjacent units in a commercial building. The key elements are velopers will have their lawyers create standard form party
that the units are under different ownership, and that the wall wall agreements, and register them against title to the units
has a structural function in relation to both units. A wall con- as soon as they are constructed. There are many examples of
structed at, but not on, a property boundary, that performs no such agreements throughout the world and their drafting is
structural function in relation to the building on the adjoining not, to use an overworked metaphor, rocket science. Those
lot, is not a party wall. municipalities that have been preventing this form of devel-
RSPHQWZLOOQRZSUHVXPDEO\EHDGGUHVVLQJWKHVXIíFLHQF\RI
the party wall agreements that are being put in place (as well,
What was the problem? perhaps, as the question of whether that review itself might be
Metro Vancouver has plenty of side-by-side duplex and row a source of future liability if something is missed).
house units that are under different ownership, and many of
these units are separated by walls that perform a structural
function. These are strata lots, and the ownership, repair and Now What?
maintenance obligations pertaining to these walls are dealt For planners, the more challenging question is this: now that
with in strata properties legislation. Developers wishing to this perceived obstacle to this type of housing tenure is out of
construct duplexes and row houses that are not strata titled—a the way, what needs to be done to the rest of the regulatory
type of housing for which, according to some reports, there structure to allow developers to supply it without having to
is a healthy demand in many urban markets in B.C.—have apply for variances? My own experience is that the lack of
been faced with a regulatory obstacle in many municipalities, developer interest in this type of development has relieved
which is said to be based on the fact that party wall agree- many local governments of the task of determining whether
PHQWV FDQQRW EH UHJLVWHUHG LQ WKH /DQG 7LWOH 2IíFH VR DV WR their zoning rules actually permit it.
run with the land and automatically bind future owners of the
units. Legal advisors to these municipalities have apparently
been of the view that allowing a situation to evolve wherein (continued next page)
%@KKÐÐ Legal Update (cont’d) always the same thing as minimum lot frontage, so both
types of regulation should be considered. In a larger sense,
the option for this type of housing could trigger an evalu-
Land Use ation of some of the basic premises for the lot standards
B.C. zoning bylaws that identify duplex, triplex, and row in the bylaw. Some commentators have observed that the
house or townhouse buildings as permitted forms of residen- standard 100-foot to 120-foot depth of residential lots in
tial development will generally be interpreted to permit these B.C. is excessive where housing affordability is an objective
forms of housing whether it is rental housing or, in the case of and the lot widths are being reduced to the 16-foot range to
non-rental housing, whether it is strata titled or convention- DFFRPPRGDWHVXEGLYLGHGURZKRXVHV,QJUHHQíHOGGHYHORS-
ally subdivided. Tenure is generally a matter that is outside ment permitting these types of buildings, departures from
the scope of “land use”, so local zoning bylaws should not be WKHVWDQGDUGVXEGLYLVLRQFRQíJXUDWLRQPD\EHZDUUDQWHGRU
addressing the issue anyway. even necessary.
Density Building Form and Character
Given a particular group of row houses on a given area of Some planners are anxious about the prospect of inappropri-
ODQGWKHGHQVLW\ îRRUDUHDUDWLR DQGVLWHFRYHUDJHFDOFXOD- ate changes to the appearance of multi-unit buildings where
tions may work out differently if each row house is on its own there is no strata corporation and individual owners are free
parcel of land, than if the multi-unit building is on a single to alter the exterior of their unit as they please. Individual
parcel. Municipalities that want to ensure a conventional sub- units might be painted distinctive colours, or windows and
division option for these units should ensure that the density doors might be “updated”. In most cases, these buildings will
regulations will accommodate it. be authorized by development permit, and under the Local
Government Act the development permit is binding on every
Siting owner who acquires a unit in the building. The absence of a
strata corporation to oversee these matters may mean that
6RPH]RQLQJE\ODZVVSHFLíFDOO\SHUPLW§]HURORWOLQH¨PXO-
there will be more occasions where the local government
tiple family residential buildings, though not necessarily on
will itself have to enforce the development permit, including
both sides of the lot. Usually the issue here is the minimum
ordering the removal of alterations that are not consistent
side yard setback. Obviously there is no side yard setback at
with the approved development permit drawings. (There is
all where two units share a party wall at a lot line.
nothing stopping the developer from registering a statutory
building scheme that will provide the other owners in the
Parking building with the ability to control these sorts of changes
Many parking bylaws assume that parking provided on-site themselves.) A walk down the street in a typical Toronto
will be provided to the rear of the building, even when there or Montréal row house neighbourhood would suggest that
is no lane access, with the side yards providing a route to the changes of this type are not always per se undesirable, but
rear parking area. In areas with no lanes, encouraging this that such changes as do occur can provide an interesting
form of development will require municipalities to choose be- narrative on the natural evolution of the street. There are,
tween lessening or eliminating the parking requirement and KRZHYHUOLNHO\WREHVRPHSUREOHPVZLWKFKDQJHVLQíQLVK-
VHHLQJDVLJQLíFDQWSURSRUWLRQRIWKHIURQW\DUGVSDFHRIWKH ing materials and so forth that will challenge the authority
units taken up with parking areas or driveways. of municipalities to enforce their permits, given the “particu-
ODUVRIWKHH[WHULRUíQLVK¨UXOHLQV RIWKHLocal Gov-
Subdivision Standards ernment Act—a rule that the Province may wish to revisit if it
This is the area of the bylaw that likely needs most work. wants local governments to encourage this form of housing.
The obvious topics are minimum parcel area and minimum
parcel width. With no side yard requirement, the minimum Conversion of Rental Buildings
parcel width can be reduced, and the minimum lot area pro- There may be existing buildings that lend themselves to sub-
portionately. Attention should also be paid to the minimum division of this type, depending on their actual structure.
highway frontage (10% of lot perimeter) rule in s. 944 of These would not be strata conversions of previously occupied
the Local Government Act, which can be replaced with a buildings requiring approval of the municipality under s. 242
minimum frontage rule in a local bylaw or the council or of the Strata Property Act, but they could raise similar issues
WKHDSSURYLQJRIíFHU LIWKHSRZHULVGHOHJDWHG PD\JUDQW
exemptions case-by-case. Minimum highway frontage is not
(continued next page)
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