Letter to the Minister of Housing and Municipal Affairs from the CBRA Board

Dear Minister Boyle,

On behalf of the Cadboro Bay Residence Association (CBRA), we wish to express our strong support for the District of Saanich’s letter of September 23, 2025, requesting your government to “launch a review of Bill 44’s impact”. We would further encourage you to take this action as soon as possible.

We fully understand the need for immediate remedies to address the Province’s housing needs, including neighbourhood densification and the growing need for SSMUHs. Bill 44’s ambition to reduce restrictive zoning by-laws, shorten and reduce costly permitting processes, and take a more proactive approach to planning are laudable objectives. However, the CBRA, among other observers in the fields of urban planning and housing, feels that the outcome of Bill 44 has led to unintended consequences that are having significant long-term impacts on neighbourhoods across the Province.

In this regard, we would like to highlight three areas of concern, which our Association urges you to include in a meaningful review of the current legislation governing housing developments in British Columbia. These three factors include: 1) impacts on environmental and heritage objectives; 2) Lack of public input on new housing construction in existing, well- established neighbourhoods; and 3) Financial considerations, such as the long-term impact on property values, housing affordability, necessary transportation and service infrastructure costs, urban green and recreational areas.

With respect to environmental factors, we point to the ever-increasing loss of Saanich’s green canopy with the construction of multiple four-plexes throughout Saanich. This, essentially, necessitates significant tree removal. Replacement on a lot, fully occupied by new housing, usually means planting elsewhere and often outside the neighbourhood. Heritage values can also be adversely impacted in an unfettered densification environment. A review on how these, sometimes competing objectives can be reconciled should be undertaken 

Regarding public input, we note that British Columbia has had a long tradition of public engagement in urban planning in the post-WWII period. That’s well over 75 years of local input in a truly democratic way. While this process has been noted as one that can slow the development of new housing, it has led to the establishment of hundreds, if not thousands, of liveable neighbourhoods in British Columbia with local character, in which people are proud to live. 

In the case of the CBRA, a local area plan (LAP) developed by the people living in the area and the District of Saanich was agreed to by the Saanich Council and adopted into the Official Community Plan. It outlined where densification should be targeted, to take into account transportation hubs and walkability. The LAP is now seemingly meaningless, and densification is happening in areas with no easy connection to transport hubs, necessitating additional cars, in what is often considered a semi-rural area. We note in the descriptions of the new planning process that there is a requirement for Municipalities to hold public hearings on Official Community plans and, thereby, Housing Needs Reports, but the removal of Local Area plans as a tool significantly reduces public input in the process. We strongly suggest that a review focus on how local input effectively comes into play in both HNRs and the OCP within the new proactive approach. 

Thirdly, we feel a financial assessment needs to be included in a review. Affordability was a top priority for this significant change to housing legislation in BC. However, it is our observation that the new multiplex buildings in our area will have no impact on the affordability issue. We do feel that some property values will be affected by this legislation and that there will be winners and losers. This could be homeowners, contractors, the Municipality or the Provincial Government. From a local perspective, this needs to be examined. 

As one final point, we certainly hope that Municipalities, in this case Saanich, are given leeway on housing targets when provincial decisions impact planned housing. This was the case with the delayed University of Victoria housing project, which could have had a significant positive impact on the local rental market. 

While the CBRA understands the need for new legislation to move the needle on housing, we strongly believe that an evaluation of the legislation, with possible changes, is required to address the concerns we are expressing.