3609-3687 Arbutus St rezoning application

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This application was approved by Council on June 22, 2021, following a Public Hearing on June 17, 2021.



We would like your feedback on a rezoning application at 3609-3687 Arbutus St. The proposal is to allow for the development of a 6-storey residential building. The zoning would change from RS-1 (Residential) to CD-1 (Comprehensive Development) District. This proposal includes:

  • 116 secured market rental units (with 24 units secured as below-market rental housing)
  • Floor space ratio (FSR) of 2.53
  • Floor area of 7,760.6 sq. m (83,534 sq. ft.)
  • A maximum height of 22 m (73 ft.)
  • 74 vehicle parking spaces and 227 bicycle parking spaces

The application is being considered under the Affordable Housing Choices Interim Rezoning Policy.


In response to COVID-19 (Coronavirus), an extended online question and answer (Q&A) period was held in place of an in-person open house for this project.



We would like your feedback on a rezoning application at 3609-3687 Arbutus St. The proposal is to allow for the development of a 6-storey residential building. The zoning would change from RS-1 (Residential) to CD-1 (Comprehensive Development) District. This proposal includes:

  • 116 secured market rental units (with 24 units secured as below-market rental housing)
  • Floor space ratio (FSR) of 2.53
  • Floor area of 7,760.6 sq. m (83,534 sq. ft.)
  • A maximum height of 22 m (73 ft.)
  • 74 vehicle parking spaces and 227 bicycle parking spaces

The application is being considered under the Affordable Housing Choices Interim Rezoning Policy.


In response to COVID-19 (Coronavirus), an extended online question and answer (Q&A) period was held in place of an in-person open house for this project.

This application was approved by Council on June 22, 2021, following a Public Hearing on June 17, 2021.

Q&A is available from September 8 to September 28, 2020.

Q&A replaces in-person open houses, which are on hold due to COVID-19 (Coronavirus).

We post all questions as-is and reply here within two business days. To find out when we reply to your questions, sign in or register.

  • Share I am concerned about the building line issue. The City has a policy to remove un-needed building lines and Arbutus was one of the ones that was supposed to be studied. Can you provide a cross-section of Arbutus to show how this very large right of way is proposed to be used. If it is no longer needed the City, can the remove the building line through a statutory process? This would reduce the impact of the proposed building on the neighbours ( noise, shadows and privacy) by allowing the building to be situated further east. on Facebook Share I am concerned about the building line issue. The City has a policy to remove un-needed building lines and Arbutus was one of the ones that was supposed to be studied. Can you provide a cross-section of Arbutus to show how this very large right of way is proposed to be used. If it is no longer needed the City, can the remove the building line through a statutory process? This would reduce the impact of the proposed building on the neighbours ( noise, shadows and privacy) by allowing the building to be situated further east. on Twitter Share I am concerned about the building line issue. The City has a policy to remove un-needed building lines and Arbutus was one of the ones that was supposed to be studied. Can you provide a cross-section of Arbutus to show how this very large right of way is proposed to be used. If it is no longer needed the City, can the remove the building line through a statutory process? This would reduce the impact of the proposed building on the neighbours ( noise, shadows and privacy) by allowing the building to be situated further east. on Linkedin Email I am concerned about the building line issue. The City has a policy to remove un-needed building lines and Arbutus was one of the ones that was supposed to be studied. Can you provide a cross-section of Arbutus to show how this very large right of way is proposed to be used. If it is no longer needed the City, can the remove the building line through a statutory process? This would reduce the impact of the proposed building on the neighbours ( noise, shadows and privacy) by allowing the building to be situated further east. link

    I am concerned about the building line issue. The City has a policy to remove un-needed building lines and Arbutus was one of the ones that was supposed to be studied. Can you provide a cross-section of Arbutus to show how this very large right of way is proposed to be used. If it is no longer needed the City, can the remove the building line through a statutory process? This would reduce the impact of the proposed building on the neighbours ( noise, shadows and privacy) by allowing the building to be situated further east.

    Cory asked about 4 years ago

    In 1999 Council initiated plans for a Building Line Review. The review was postponed due to issues raised by the public and staff. In 2007 it was decided that the review be postponed indefinitely, or until at least after the development of a new long range transportation plan, noting that the principles of the 1997 Transportation Plan apply, including no increase in arterial network capacity and giving priority to pedestrians, bikes, transit and good movements over private automobiles except in particular cases. To date there has been no subsequent review on retaining or eliminating building lines.  

  • Share Rental over condo on Arbutus seems appropriate. I expect that this project will appeal to faculty members at York House, Prince of Wales and Traflagar, as well as other local employers on the west side (banks, health care providers, etc) Will you be reaching out to local employers to let them know about this project? on Facebook Share Rental over condo on Arbutus seems appropriate. I expect that this project will appeal to faculty members at York House, Prince of Wales and Traflagar, as well as other local employers on the west side (banks, health care providers, etc) Will you be reaching out to local employers to let them know about this project? on Twitter Share Rental over condo on Arbutus seems appropriate. I expect that this project will appeal to faculty members at York House, Prince of Wales and Traflagar, as well as other local employers on the west side (banks, health care providers, etc) Will you be reaching out to local employers to let them know about this project? on Linkedin Email Rental over condo on Arbutus seems appropriate. I expect that this project will appeal to faculty members at York House, Prince of Wales and Traflagar, as well as other local employers on the west side (banks, health care providers, etc) Will you be reaching out to local employers to let them know about this project? link

    Rental over condo on Arbutus seems appropriate. I expect that this project will appeal to faculty members at York House, Prince of Wales and Traflagar, as well as other local employers on the west side (banks, health care providers, etc) Will you be reaching out to local employers to let them know about this project?

    PamT asked about 4 years ago

    If the project is approved by Council and developed, the applicant will be using some of the typical Vancouver rental advertising methods. They will have a combination of site signage, a project website that will take rental inquiries starting about 12-18 months before occupancy, Craigslist and Facebook market place will also be used. There isn't a guarantee that they will be reaching out to local employers directly but are hopeful that their advertising will reach a wide audience.

  • Share Why is this development exceeding the maximum density recommended in the City- wide draft Secured Market Rental Policy for arterial road locations? on Facebook Share Why is this development exceeding the maximum density recommended in the City- wide draft Secured Market Rental Policy for arterial road locations? on Twitter Share Why is this development exceeding the maximum density recommended in the City- wide draft Secured Market Rental Policy for arterial road locations? on Linkedin Email Why is this development exceeding the maximum density recommended in the City- wide draft Secured Market Rental Policy for arterial road locations? link

    Why is this development exceeding the maximum density recommended in the City- wide draft Secured Market Rental Policy for arterial road locations?

    Cory asked about 4 years ago

    The Affordable Housing Choices Interim Rezoning Policy(External link) rezoning policy was introduced to encourage ground-oriented and mid-rise affordable housing types and tenures, including purpose-built rental apartments and townhouses (you can also refer to the city board for an overview of this policy). This policy also demonstrates the “transition zone” concept where ground-oriented affordable housing types provide a transition between higher density arterial streets and single-family areas. This site is identified as 500 m from the local shopping area and fronting an arterial street with Translink's Frequent Transit Network, thus allowing for 6-storeys under the policy. The City’s Housing Vancouver Strategy(External link) also aims to provide for an increased number of affordable housing projects across the City.

  • Share 1. I gave a feedbac before the open house. Will that be counted? Do I need to submit the comment again? Was that comment saved somewhere or was that just used for general reference by the city? 2. Due to Covid, some neighbours are out still out of town and I don't think they know about the project so they will not be able to submit the comment before Sept 28. Can they submit their comments after the Open House and will their comments be treated in the same ways as the comments entered during the open house? 3. Two neighbours wanted me to send in comments for them but they don't have email addresses. Are these comments counted separately instead of counted as one? If counted as one, what is needed for their comments to be counted separately? Thank you. on Facebook Share 1. I gave a feedbac before the open house. Will that be counted? Do I need to submit the comment again? Was that comment saved somewhere or was that just used for general reference by the city? 2. Due to Covid, some neighbours are out still out of town and I don't think they know about the project so they will not be able to submit the comment before Sept 28. Can they submit their comments after the Open House and will their comments be treated in the same ways as the comments entered during the open house? 3. Two neighbours wanted me to send in comments for them but they don't have email addresses. Are these comments counted separately instead of counted as one? If counted as one, what is needed for their comments to be counted separately? Thank you. on Twitter Share 1. I gave a feedbac before the open house. Will that be counted? Do I need to submit the comment again? Was that comment saved somewhere or was that just used for general reference by the city? 2. Due to Covid, some neighbours are out still out of town and I don't think they know about the project so they will not be able to submit the comment before Sept 28. Can they submit their comments after the Open House and will their comments be treated in the same ways as the comments entered during the open house? 3. Two neighbours wanted me to send in comments for them but they don't have email addresses. Are these comments counted separately instead of counted as one? If counted as one, what is needed for their comments to be counted separately? Thank you. on Linkedin Email 1. I gave a feedbac before the open house. Will that be counted? Do I need to submit the comment again? Was that comment saved somewhere or was that just used for general reference by the city? 2. Due to Covid, some neighbours are out still out of town and I don't think they know about the project so they will not be able to submit the comment before Sept 28. Can they submit their comments after the Open House and will their comments be treated in the same ways as the comments entered during the open house? 3. Two neighbours wanted me to send in comments for them but they don't have email addresses. Are these comments counted separately instead of counted as one? If counted as one, what is needed for their comments to be counted separately? Thank you. link

    1. I gave a feedbac before the open house. Will that be counted? Do I need to submit the comment again? Was that comment saved somewhere or was that just used for general reference by the city? 2. Due to Covid, some neighbours are out still out of town and I don't think they know about the project so they will not be able to submit the comment before Sept 28. Can they submit their comments after the Open House and will their comments be treated in the same ways as the comments entered during the open house? 3. Two neighbours wanted me to send in comments for them but they don't have email addresses. Are these comments counted separately instead of counted as one? If counted as one, what is needed for their comments to be counted separately? Thank you.

    Curious How Comments Work asked about 4 years ago

    Comments submitted before and after the Virtual Open House period are received, analyzed, and included in the Council Report for Public Hearing and Council’s consideration. Generally, concerns are grouped into common themes and then discussed in the report. The total number of responses received both before and after the open house are included. Comments can be received  up until the Council Report is finalized and sent for review to senior staff approximately two months before the Public Hearing (date to be determined). Comments submitted under one username they will be counted as one response. Petitions and from letters are usually noted separately if signed by a number of people. For example, the report might say a petition was received signed by x number of respondents.  

  • Share Are you proposing rental as opposed to condos here because of the close proximity to the new Broadway Subway? Hopefully you are able to build less parking to help with overall affordability.  I also see that this building has some pretty great amenities for residents. Will all tenants have access to these? Lastly, will the building be pet friendly? on Facebook Share Are you proposing rental as opposed to condos here because of the close proximity to the new Broadway Subway? Hopefully you are able to build less parking to help with overall affordability.  I also see that this building has some pretty great amenities for residents. Will all tenants have access to these? Lastly, will the building be pet friendly? on Twitter Share Are you proposing rental as opposed to condos here because of the close proximity to the new Broadway Subway? Hopefully you are able to build less parking to help with overall affordability.  I also see that this building has some pretty great amenities for residents. Will all tenants have access to these? Lastly, will the building be pet friendly? on Linkedin Email Are you proposing rental as opposed to condos here because of the close proximity to the new Broadway Subway? Hopefully you are able to build less parking to help with overall affordability.  I also see that this building has some pretty great amenities for residents. Will all tenants have access to these? Lastly, will the building be pet friendly? link

    Are you proposing rental as opposed to condos here because of the close proximity to the new Broadway Subway? Hopefully you are able to build less parking to help with overall affordability.  I also see that this building has some pretty great amenities for residents. Will all tenants have access to these? Lastly, will the building be pet friendly?

    Genevieve D asked about 4 years ago

    The proposal for secured rental units rather than condos (market sales) is submitted in part of the applicant’s decision to deliver more affordable housing under an enabling policy, which in this case it is the Affordable Housing Choices Interim Rezoning Policy. One of the requirements of this policy is location and form of development – this proposal is shown in the dark blue areas of the map  (see page 3 of the Policy or page 7 of City boards for larger map) which allows for sites “fronting an arterial street that is on Translink’s Frequent Transit Network and within close proximity of a local shopping area.”

    The amenities will be open to all residents of both buildings and will also be a pet friendly building.


  • Share As an incentive to developers, does the COV waive the DCL ( development cost levies) to build rentals? Can the COV afford this, especially now during the covid when city coffers are depleting? What other financial incentives offered to developers? on Facebook Share As an incentive to developers, does the COV waive the DCL ( development cost levies) to build rentals? Can the COV afford this, especially now during the covid when city coffers are depleting? What other financial incentives offered to developers? on Twitter Share As an incentive to developers, does the COV waive the DCL ( development cost levies) to build rentals? Can the COV afford this, especially now during the covid when city coffers are depleting? What other financial incentives offered to developers? on Linkedin Email As an incentive to developers, does the COV waive the DCL ( development cost levies) to build rentals? Can the COV afford this, especially now during the covid when city coffers are depleting? What other financial incentives offered to developers? link

    As an incentive to developers, does the COV waive the DCL ( development cost levies) to build rentals? Can the COV afford this, especially now during the covid when city coffers are depleting? What other financial incentives offered to developers?

    chooch asked about 4 years ago

    The Development Cost Levy (DCL) waiver provides an incentive to developers to provide for secured residential rental and social housing projects, which is seen as an overall community benefit. Staff constantly monitor the DCLs collected and what the needs are (which are paid for by DCLs). In fact, as a result of this analysis, on November 26, 2019, City Council approved the removal of the Utilities DCL waiver for secured market rental housing effective September 30, 2020. Projects with submitted applications will be provided in-stream rate protection for another year. The Rental Incentive Programs Bulletin provides  more details on this, rent level criteria for DCL waivers,  and other DCL related matters.

  • Share I am significantly concerned about traffic congestion, parking issues, and lane congestion which will detrimentally affect our lives in this otherwise quiet, peaceful neighbourhood. My question is regarding privacy and the shadowing which will affect much of our backyards. How does the city plan on easing these issues. Also, are letters/emails sent to the city since May 2020, added to the comments that are made on this virtual open house website? What about comments that are made after this virtual open house? Will they also be counted? on Facebook Share I am significantly concerned about traffic congestion, parking issues, and lane congestion which will detrimentally affect our lives in this otherwise quiet, peaceful neighbourhood. My question is regarding privacy and the shadowing which will affect much of our backyards. How does the city plan on easing these issues. Also, are letters/emails sent to the city since May 2020, added to the comments that are made on this virtual open house website? What about comments that are made after this virtual open house? Will they also be counted? on Twitter Share I am significantly concerned about traffic congestion, parking issues, and lane congestion which will detrimentally affect our lives in this otherwise quiet, peaceful neighbourhood. My question is regarding privacy and the shadowing which will affect much of our backyards. How does the city plan on easing these issues. Also, are letters/emails sent to the city since May 2020, added to the comments that are made on this virtual open house website? What about comments that are made after this virtual open house? Will they also be counted? on Linkedin Email I am significantly concerned about traffic congestion, parking issues, and lane congestion which will detrimentally affect our lives in this otherwise quiet, peaceful neighbourhood. My question is regarding privacy and the shadowing which will affect much of our backyards. How does the city plan on easing these issues. Also, are letters/emails sent to the city since May 2020, added to the comments that are made on this virtual open house website? What about comments that are made after this virtual open house? Will they also be counted? link

    I am significantly concerned about traffic congestion, parking issues, and lane congestion which will detrimentally affect our lives in this otherwise quiet, peaceful neighbourhood. My question is regarding privacy and the shadowing which will affect much of our backyards. How does the city plan on easing these issues. Also, are letters/emails sent to the city since May 2020, added to the comments that are made on this virtual open house website? What about comments that are made after this virtual open house? Will they also be counted?

    Concerned neighbour on 20th Avenue asked about 4 years ago

    Shadow analysis and conditions related to mitigation of shadowing impacts, where possible, are usually included as conditions of an approval of a project if the proposal is supportable in principle. Sometimes projects are required to be redesigned at the rezoning stage if sufficient improvements are warranted. In other cases, the design development would occur during the subsequent development permit review stage, at which time there would be further neighbourhood notification. It should be noted that for the project at 3609 – 3687 Arbutus Street, shadowing impacts would only occur in the morning for properties located on the west side of the north-south lane behind the project.

    Regarding public feedback, comments, letters, emails, and phone calls that were submitted since May 2020 will be included and analyzed as part of this rezoning application. A summary of the feedback will be part of the Council Report that goes to Public Hearing (date to be determined).

  • Share In this low density, quiet neighbourhood, WHY would the city consider a development that is so dramatically out of character for this area? This will have a significant depression of the value of the surrounding homes. The increased traffic and parking issues will seriously impact our daily lives due to noise, traffic congestion and insufficient street parking. on Facebook Share In this low density, quiet neighbourhood, WHY would the city consider a development that is so dramatically out of character for this area? This will have a significant depression of the value of the surrounding homes. The increased traffic and parking issues will seriously impact our daily lives due to noise, traffic congestion and insufficient street parking. on Twitter Share In this low density, quiet neighbourhood, WHY would the city consider a development that is so dramatically out of character for this area? This will have a significant depression of the value of the surrounding homes. The increased traffic and parking issues will seriously impact our daily lives due to noise, traffic congestion and insufficient street parking. on Linkedin Email In this low density, quiet neighbourhood, WHY would the city consider a development that is so dramatically out of character for this area? This will have a significant depression of the value of the surrounding homes. The increased traffic and parking issues will seriously impact our daily lives due to noise, traffic congestion and insufficient street parking. link

    In this low density, quiet neighbourhood, WHY would the city consider a development that is so dramatically out of character for this area? This will have a significant depression of the value of the surrounding homes. The increased traffic and parking issues will seriously impact our daily lives due to noise, traffic congestion and insufficient street parking.

    Concerned neighbour on 20th Avenue asked about 4 years ago

    The Affordable Housing Choices Interim Rezoning Policy rezoning policy was introduced to encourage ground-oriented and mid-rise affordable housing types and tenures, including purpose-built rental apartments and townhouses (you can also refer to the city board for an overview of this policy). This policy also demonstrates the “transition zone” concept where ground-oriented affordable housing types provide a transition between higher density arterial streets and single-family areas. This site is identified as 500 m from the local shopping area and fronting an arterial street with Translink's Frequent Transit Network, thus allowing for 6-storeys under the policy. The City’s Housing Vancouver Strategy also aims to provide for an increased number of affordable housing projects across the City. 

    Staff are continuing to review the application throughout the rezoning process, including whether a Traffic Management Plan is required from the applicant. The review also includes considering public feedback and whether traffic issues can be dealt with as part of the subsequent Development Permit application or as further documentation required as part of the rezoning review.


  • Share Really great to see more housing for moderate income earners. Is it too late in the process to increase the overall building height/design so even more homes can fit on this property? on Facebook Share Really great to see more housing for moderate income earners. Is it too late in the process to increase the overall building height/design so even more homes can fit on this property? on Twitter Share Really great to see more housing for moderate income earners. Is it too late in the process to increase the overall building height/design so even more homes can fit on this property? on Linkedin Email Really great to see more housing for moderate income earners. Is it too late in the process to increase the overall building height/design so even more homes can fit on this property? link

    Really great to see more housing for moderate income earners. Is it too late in the process to increase the overall building height/design so even more homes can fit on this property?

    A.G. asked about 4 years ago

    The Affordable Housing Choices Interim Rezoning Policy allows for at most 6-storeys in this location. It is not possible to go higher at this time

  • Share I understand from the city that there is no cap on the market rental so the applicant can charge what is necessary to help cover the overall building/operational expenses in order to make the project viable. 20% of the units are below market rent so the future landlord can and will charge the the rest (80%) of the units higher rents to cover the shortfalls from the 20%. The rest of the 80% are more than likely going to be moderate income earners as well. I am a moderate income earner and I never have any luck so I probably would end up in one of those 80% that helps to pay for the lucky 20% . Please explain how that would be fair to the 80% who are in the same boat as the lucky 20% except the luck to have subsidized rent. on Facebook Share I understand from the city that there is no cap on the market rental so the applicant can charge what is necessary to help cover the overall building/operational expenses in order to make the project viable. 20% of the units are below market rent so the future landlord can and will charge the the rest (80%) of the units higher rents to cover the shortfalls from the 20%. The rest of the 80% are more than likely going to be moderate income earners as well. I am a moderate income earner and I never have any luck so I probably would end up in one of those 80% that helps to pay for the lucky 20% . Please explain how that would be fair to the 80% who are in the same boat as the lucky 20% except the luck to have subsidized rent. on Twitter Share I understand from the city that there is no cap on the market rental so the applicant can charge what is necessary to help cover the overall building/operational expenses in order to make the project viable. 20% of the units are below market rent so the future landlord can and will charge the the rest (80%) of the units higher rents to cover the shortfalls from the 20%. The rest of the 80% are more than likely going to be moderate income earners as well. I am a moderate income earner and I never have any luck so I probably would end up in one of those 80% that helps to pay for the lucky 20% . Please explain how that would be fair to the 80% who are in the same boat as the lucky 20% except the luck to have subsidized rent. on Linkedin Email I understand from the city that there is no cap on the market rental so the applicant can charge what is necessary to help cover the overall building/operational expenses in order to make the project viable. 20% of the units are below market rent so the future landlord can and will charge the the rest (80%) of the units higher rents to cover the shortfalls from the 20%. The rest of the 80% are more than likely going to be moderate income earners as well. I am a moderate income earner and I never have any luck so I probably would end up in one of those 80% that helps to pay for the lucky 20% . Please explain how that would be fair to the 80% who are in the same boat as the lucky 20% except the luck to have subsidized rent. link

    I understand from the city that there is no cap on the market rental so the applicant can charge what is necessary to help cover the overall building/operational expenses in order to make the project viable. 20% of the units are below market rent so the future landlord can and will charge the the rest (80%) of the units higher rents to cover the shortfalls from the 20%. The rest of the 80% are more than likely going to be moderate income earners as well. I am a moderate income earner and I never have any luck so I probably would end up in one of those 80% that helps to pay for the lucky 20% . Please explain how that would be fair to the 80% who are in the same boat as the lucky 20% except the luck to have subsidized rent.

    Jenny asked about 4 years ago

    You’re correct that there is no City requirement for the starting rents for market rate units to be capped. As with other market rental, the rents will likely be similar to other newer rental units in the neighbourhood. Ultimately, the property manager will want the units to be tenanted, and rents will reflect what market will bear. All market rental is subject to the Provincial Residential Tenancy Act which does set limits on the amount rents can be increased during a tenancy.

    Market rents for new rental apartments in Vancouver are of course very high, and are generally not affordable to households with moderate incomes. In part this is because of limited supply and high and increasing demand. The upward pressure on rents has increased significantly in recent years at the same time as the costs of homeownership have become out of reach for many households.

    We also know that market rents are lower in older buildings, and adding new rental housing supply is important to ensuring that more affordable rental units are available in Vancouver in the future. Over the last decade, the City’s rental incentive programs have been helping address the long gap of time when no new secured rental housing was being built in Vancouver (see graph below).


    Programs that support the delivery of new rental buildings with a below-market component are one of the ways the City is seeking to address the City’s rental housing crisis. You are correct that many households with moderate incomes are spending significant proportions of their incomes on rent in order to be able to live in Vancouver, and that there will be a much greater need for the below-market rental units than any single project can deliver, but projects of this type do get approved and built one at a time. Much more of this type of housing, as well as other affordable housing such as social housing, is needed. 

    To help ensure fairness, and that the below-market units are made available to those in need, there are specific eligibility criteria that apply. The below-market units are enabled by incentives provided by the City that allow more market rate units than could otherwise be built. Renters who choose to live in the market rate units make the project work overall, but the market rents for those units aren’t different than they would be in a building with no below-market units.

    If this project is approved (or in another project nearby) I really do hope that you are able to access one of the units available for moderate incomes. The City isn’t involved in selecting tenants, but I do encourage you to review the eligibility criteria that will apply (https://bylaws.vancouver.ca/zoning/policy-rezoning-mirhpp.pdf ) and reach out to the developer to see if there is a waiting list you can go on – recognizing that even when a project is approved it will take a couple of years to be ready for occupancy. 

    There is a little trick you can use to see all of the projects in the city that are in the moderate income rental housing pilot program (MIRHPP). Go to this webpage: https://vancouver.ca/home-property-development/rezoning-applications.aspx and scroll down to the map. You then click on ‘application approved’ and deselect everything except ‘Moderate Income Rental. You can do the same for the tabs ‘Application in Review’ and ‘Upcoming Public Consultation’. This way you can see MIRHPP projects that are in application and approved. Not all of the projects with below-market units will be in this list (including 3609 Arbutus) because it comes in under a different policy, but the map will represent most of the projects under application that have below-market units.