Infill Housing Scorecard

Townhomes and small apartment buildings are legal on paper in Greater Victoria— but is it possible to build?
BC faces a housing crisis. Our province hasn't built enough housing for decades, and the housing we've built is often inadequate for raising families or aging in place. British Columbians need more options, morre small apartment buildings and townhomes,

In response to this need, the Province of BC told municipalities to allow small apartments and townhomes on nearly every urban property. As part of this, they published guidelines on legalizing this housing.  


Municipalities were required to update their zoning by June 2024 to legalize between 3 and 6 homes on nearly every residential property that previously only allowed one or two homes. These updates are all unique, and all allow different amounts of housing.

We've graded each major core municipality in the CRD on how well they've legalized starter homes, family homes, small apartments, and townhomes.

Methodology

Small apartment buildings and townhomes are often called the "missing middle" between big apartment buildings and single family homes. They are "missing" because municipalities use a variety of tools to block new homes. The main barriers municipalities use are parking requirements, building shape and size requirements, form restrictions, and procedural barriers. We used these four "subjects" to grade Greater Victoria municipalities against provincial  guidelines.

Parking requirements are an effective way to block housing as parking is quite expensive and space-inefficient.  Each parking stall can add as much as $200,000 to the cost of a home. Despite this cost, as many as 30-40% of private parking stalls sit unused, and many municipalities require multiple parking spaces per unit. This is particularly prohibitive for homes built on smaller lots or homes built on rock, which demands excessive blasting. Because of the oversupply of parking and the costs parking force on homes, the province recommends municipalities remove parking requirements outside of rural areas. Homebuyers can still decide if they want to pay for a home with parking, and homebuilders can still choose to build parking, but cheaper homes without parking will now be avaliable.

Municipalities also use shape and size restrictions to ban housing. The most common tools used by municipalities include "lot coverage," the percentage of a lot occupied by homes; "setbacks," the distance from homes to the lot line; and floor area ratio, the ratio between floor area and lot size; as well as restrictions such as maximum height and particular landscaping rules. The Province has set minimum expectaions for each of these, including that municipalities stop using a number of tools to block housing.

Form restrictions are much easier to follow. Municipalities often directly ban particular types of housing, such as forbidding towhomes, small apartments, or having multiple buildings on one lot. They also set rules such as telling homebuilders how to position entrance doors, and set limits on the number of homes that can be built on a lot. The province has recommended against all of these, and set minumum expectations for the number of homes that should be allowed.

Procedural obsticles are harder to track. The Province doesn't want to see municipalities blocking housing by drowning homes in reporting and permitting requirements, such as aesthetic-based permits and reviews and multiple permit steps, such as separate development permits and building permits.

We graded these four "subjects based on bylaws as of December 2025. Each municipal planning department was then given a chance to review our collected data grades and and to make corrections.

Subject
Explanation
Provincial Standard
Parking
Apartment parking stalls can cost upwards of $200,000 per parking space. Despite this, municipalities often set quite high requirements for the number of parking spaces required before homebuilders are permitted to create a home.

These requirements often have no scientific basis. (see: Donald Shoup, The High Cost of Free Parking)
The province recommends removing parking requirements outside of rural areas. This lets homebuilders choose the number of parking spaces they think is appropriate, and it means that homebuyers can choose if they want to pay for that parking or not.

The province also recommends a cap on the number of parking spaces homebuilders are allowed to build in urban areas. This prevents the possibilty of developers building public parking garages under the guise of providing parking to residents.
Building Shape and Size Restrictions
Municipalities set rules for the size, shape, and location of buildings. Often these rules can prevent buildings from existing at all. These rules include:
• Lot Coverage - the maximum percentage of a property that can be occupied by buildings
• Setbacks - the distance between the edge of a property and a building
• Height Limits - how tall a building can be
• Floor Area limits - Limits on the amount of finished space in a building
The province sets minimum guidelines for lot coverage, setbacks, and height limits. You can find these here.

The province also recommends that municipalities stop using floor area limits as they are essentially a limit directly on how many homes are allowed.
Form Restrictions
Municipalities also set rules limiting the types of homes allowed, number of units allowed, and how residents can enter their homes.
The province recommends letting homebuilders choose the types of homes they build. The province also recommends that municipalities shouldn't tell homebuilders where home entrances can be, and sets a minimum standard for how many homes should be allowed on different sizes of properties.
Process
Municipalities often use process to limit homebuilding, such as additional permits for particular types of housing, or strict design limitations.
This was the hardest metric to gauge, as it can be difficult to tell what is required for each project. Often these process requirements are project- or location-specific.

We focussed on whether or not municipalities force missing middle housing through a separate development permit process before they can proceed with building permits.
The province recommends that municipalitites shouldn't impose strict design limitations on smaller homes. The province also warns against using process to prevent homebuilding.

We evaluated a series of weighted metrics, broken down into the above categories, based on provincial guidelines. We provided points for any policies that aren't entirely anti-housing, and provided bonus points for elements that go beyond Provincial minumum recommendations such as exempting basements from storey counts.

We also deducted points for policies that are obvious and significant barriers to new homes, such as tight limits on total floor area, extremely low maximum heights, and requiring enormous amounts of parking, and continuing an explict ban on most types of housing.

Grade
Description
A
Most housing can be built under this policy.
B
Some housing can be built under this policy.
C
A few projects are possible under this policy.
F
Policy is actively hostile to housing. Almost no housing can be built under this policy.

We used the provincial guidelines to grade each municipality. To get an "A", a municipality has to meet or exceed these minimum standards set by the province.

Our scorecard

City
Grade
Summary
Reference (Burnaby, 2024)
A
In their original implementation, Burnaby went farther than provincial recommendations, even allowing townhomes and apartments built on separate properties to share a wall.
Reference (Provincial Recommendations)
A
The province established clear guidelines for how to legalize missing middle homes. Our scorecard used these guidelines to grade each municipality.
Saanich
B
Saanich largely follows provincial guidelines. We couldn't give them an 'A' due to their parking requirements and building restrictions, particularly setbacks.
Esquimalt
B
Esquimalt also largely follows provincial guideliens. They lost points in their parking requirements, which are quite high.
Victoria
C
Though recent tweaks have improved the policy, Victoria still tightly limits the amount of space homes can use and still dictates how buildings can look.
While municipal staff report that variances are "not a barrier to development when there is a supportive rationale," we have already seen several homes blocked by the variance process.
View Royal
C-
View Royal effectively bans large apartments by placing tight limits on home size and how buildings can be shaped. They also insist on large amounts of parking.
Langford
C-
Langford bans walk-up apartments across much of the municipality, and requires a lot of parking. They operate on a pay-to-build model for many types of housing, where homebuilders can pay for permission to build more housing.
Oak Bay
F
Oak Bay receives a failing grade for tightly limiting the amount of space homes can take up and how they can be built on a lot, as well as some of the highest parking requirements in the Province.
Colwood
F
Colwood ignored the provincial mandate and has not yet implement changes to legalize missing middle housing.

Grade Details

Saanich

Letter Grade: B

Saanich largely follows provincial guidelines, although they impose fairly high parking requirements and tight building size restrictions that lower the number of homes that can be built and make them more expensive than necessary. Specifically, Saanich demands large spaces around and between buildings (setbacks), and tightly limits the overall space that can be devoted to homes (lot coverage). They also insist on large amounts of parking across much of the District. As a result, many homes require variances to be built, or are restricted to  large lots.

One thing they do well: Saanich has mostly followed provincial guidelines on legalizing housing. While there are still significant areas for improvement, this makes them the best-scored municipality in the Capital Region.

Esquimalt

Letter Grade: B

Esquimalt’s main barrier is their parking requirements. While they updated them fairly recently, they still require a fairly high number of parking spaces per home, which drives up costs for homes significantly.

One thing they did well: Esquimalt has fairly closely followed provincial guidelines, giving them the second-best score in the CRD.

Victoria

Letter Grade: C

We assessed Victoria's General Residential District (GRD-1) zoning. While Victoria's 2025 zoning overhaul is a big improvement over the previous bylaw, GRD-1 still tightly limits the amount of space homes can use, and uses design standards to control how buildings can be shaped, limiting the number and size of possible homes. In particular, the way they control usable home area and setbacks is a barrier to new homes. Victoria also pushes homebuilders towards buying multiple lots and amalgamating them to make larger buildings, which limits the number of three and four bedroom units that get built, as smaller building footprints make it easier to fit more bedrooms efficiently. Victoria's parking requirements also lost them some points, although staff have already begun work on updating these. Victoria's disappointing grade could be very quickly improved through a few small amendments.

One thing they did well: Victoria proposes allowing much taller buildings across the city than provincial minimums, at least on larger lots.

View Royal

Letter Grade: C-

View Royal effectively bans spacious apartments by tightly limiting home size. They insist on large amounts of prohibitively expensive parking that drives up home construction costs.. View Royal also restricts how buildings can be shaped, limiting the number and size of possible homes.

One thing they did well: View Royal dispensed with one obscure measure used to restrict housing. Unfortunately they replaced it with a hard cap on building size.

Langford

Letter Grade: C-

Langford bans walk-up apartments across much of the municipality, and requires a lot of parking. They operate on a pay-to-build model, where homebuilders can pay for permission to build housing. Langford could very easily improve their policy by legalizing more types of housing and letting homebuilders choose how much parking to put in.

One thing they did well: Langford clearly wants more townhomes, especially near transit, and this comes across in their policy.

Oak Bay

Letter Grade: F

Oak Bay receives a failing grade for making it extremely difficult to build new homes. They tightly limit the amount of space homes can take up and how they can be built on a lot. They also insist that buildings must be extremely small and short. Oak Bay also insists on large amounts of parking. The effect of these rules is very clear, as Oak Bay has continuously failed to meet their (extremely low) housing targets set by the province.

One thing they do well: Oak Bay has cut down on the number of permits required to build a home.

Colwood

Letter Grade: F

Colwood does not allow most family and starter homes. They require enormous amounts of parking. They tightly restrict the size of buildings. Colwood is the lowest-scored municipality in the Capital Region because they have not actually abided by the Provincial mandate to legalize missing middle homes. After seeing the Province crack down on several municipalities, Colwood has now started work on a new bylaw.

Grading Scale

Detailed Scorecard Data

If you are interested in viewing all the data used for this project, including detailed grading standards for each item, you can find it all on this Google Sheet.

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