The board of the Westboro Community Association (WCA) would like to take this opportunity to provide our initial comments on the draft Official Plan to meet the March 12 deadline. Our input reflects the views of board members and some of the comments provided by residents through an online consultation.
EXTENSION OF TIMELINES FOR COMPLETION OF THE PLAN
We believe there needs to be an extension of the timelines for the completion of the new draft Official Plan (OP). Our rationale for this delay is that the OP document is extremely complex, difficult to digest and in its present form has profound implications for our community. We believe that most members of the community continue to be unaware of the changes proposed. Many people are distracted by more immediate issues related to the upheavals from the COVID 19 pandemic. In addition, the long-term implications of the pandemic on issues such as work and transportation patterns are still unclear at this point. Many community members argue that the impact of the pandemic means that we need to revisit policies that promote greater intensification. While the long-term impact of COVID 19 may in fact be less than some anticipate, we strongly believe that it is simply too early to determine these impacts and their implications for city planning.
At the same time, the need to address climate change by promoting more sustainable forms of transportation is perhaps the most important policy driver of change proposed in the draft OP. Ultimately, addressing climate change will have even more profound impacts on how we live than the highly disruptive COVID-19 pandemic. However, while we sense that most residents would have a basic understanding of climate change, based on some of the comments we received and internal discussions, we believe there is a tendency to underestimate the extent to which the way we live will need to change if we are to have a sustainable future. For example, several people have expressed strong doubts about the practicality of reducing our reliance on private cars to the degree set out in the plan’s objectives. The official plan should reflect a shared vision of both planners and citizens. Therefore, unless the City intends to impose a technocratic plan on citizens, much more work needs to be done by municipal politicians and civic leaders to educate the public on climate change challenges and how they can be best addressed through city planning in order to build consensus on the policy directions in the new plan.
Thus, in the spirit of ensuring that the new Official Plan is completed through a democratic and transparent process, we urge city politicians and planners extend the timelines for completion of the plan so that they can more effectively engage with the public and build a vision that is understood and truly shared by citizens.
KEY CHALLENGES FACING WESTBORO
The overwhelming issue faced by the WCA as expressed by its members and Westboro residents in general is the impact of intensification. Westboro in particular has been experiencing the change and disruptions created by intensification for many years. There are high levels of frustration throughout the community on how intensification has been implemented to date and how difficult it is to get city planners to respond to concerns. People already feel disempowered and worn down. Therefore, for the few in the community that are even aware of the intention under the new plan to ramp up intensification, there is alarm and discouragement. Most of the issues we will raise in the following section are related to intensification goals and targets set out in the plan for our community.
COMMENTS ON POLICY DIRECTIONS
We broadly support the strategic directions as articulated under the Big 5 Policy Moves. However, we have a number of comments.
Big Policy Move 1 Growth by Regeneration
We generally support efforts to accommodate intensification within existing urban boundaries in order to reduce urban sprawl and build more sustainable communities. However, we are uncomfortable with the term regeneration and prefer the term intensification, which is better understood by the community. Regeneration also has the connotation of complete transformation (read: destruction of the existing housing stock). In a recent Planning Primer presentation, one of our board members heard a city planner say that much of the housing stock is coming to the end of its life in inner urban areas. We strongly object to this view and hope that the City recognizes that much of the housing stock in Westboro has many more decades of life and that the carbon imprint of demolition is significant.
A key aspect of regeneration is the promotion of 15-minute neighbourhoods. However, we believe that the concept of 15-minute neighbourhoods needs to be more clearly defined. It would appear that most of Westboro could already be considered as a 15-minute neighbourhood, which is perhaps the feature that makes the area so attractive and popular. The attractiveness of Westboro’s traditional main street is already one of the key drivers of intensification in our neighbourhood. Our concern is that the policy direction of the plan will markedly increase intensification to an unsustainable level, thus undermining the qualities that make our community liveable.
In view of our long experience with intensification in Westboro, we are very sceptical that the city can achieve the proposed intensification objectives for an inner urban area such as ours, while at the same time meet other policy objectives such as ensuring that there is the social infrastructure in place to accommodate increased density, as well as achieving a goal of 40% tree canopy. For example, in the case of Westboro, which has been experiencing rapid intensification for the last 10-15 years, we have yet to see any concomitant increase in social infrastructure such as parks and recreation centres (we still only have two small parks and Dovercourt Community Centre which is already overcrowded). Given the challenges the city already has in keeping pace with the demands for additional social infrastructure for the current levels of intensification in Westboro, what assurances are there that even higher levels of proposed intensification will not overwhelm our social infrastructure?
Big Policy Move 2: Sustainable Transport
While the goal of over 50% of movement through sustainable transport is laudable, we wonder if it is realistic and achievable at this time. Incentives for private car ownership still remain powerful. In addition, we see the City undermining this policy objective through its own planning decisions and approvals. The case of Scott Street and what we are calling the “not so Great Wall of Scott street” illustrates this problem. In this case, the City has either already approved or is likely to approve a series of towers well in excess of the six stories maximum set out in the Secondary Plan. These towers could result in an estimated 160 stories of development within a small five block stretch and could potentially have 1,200 parking places. The rationale for approving increased height far in excess of the six stories foreseen in the Secondary Plan was the proximity of towers to LRT (which did not exist at the time the Secondary Plan was approved). And yet, almost every unit will have a parking place, something which seems to undermine the developer’s rationale (and the City’s acceptance) for increased height and density. If the City was seeking to encourage the use of LRT, one would have expected that a lower ratio of parking places to units would have been negotiated for towers that are mere steps away from an LRT station.
Given that Westboro is designated under the plan as a transforming inner urban neighbourhood, what assurances do we have that we will not continue to see this kind of inappropriate intense density under the new plan?
Big Policy Move 3: Urban and Community Design
We welcome the intention to improve urban and community design. At the same time, we believe the transect/overlay model is conceptually difficult to understand for residents. We wonder why there is a need for both transforming and evolving overlays. This distinction would seem to push intensification into communities such as Westboro which are already experiencing high levels of intensification. We believe there is also scope for more intensification in areas outside of Westboro, including in the outer urban transect. There are enormous burdens and disruptions placed on communities such as Westboro by intensification. Efforts should be made to made to target other areas of the city with potential, rather than increasing intensification in communities that are already intensifying.
Big Policy Move 4: Environment
We support efforts under this policy to promote a healthy natural and built environment. However, based on our own lived experience in Westboro over the last 10-15 years of intensification, we are certain that the acceleration of intensification proposed in the plan for areas designated as transforming inner urban will further undermine our already deteriorating urban environment. For example, we do not find the plan’s goal to achieve an urban canopy of 40% achievable if intensification accelerates. Even with the current level of intensification, the canopy is constantly reduced each year.
We have seen intense destruction of our tree canopy in Westboro largely from infill. The typical footprint of infill severely limits space for tree planting both in front, side and rear yards. Developers and the City tend to favour small tree species such as service berries, ornamental crab trees and Japanese lilacs for infill projects. Large trees (that have often grown wild) in rear and side yards are systematically destroyed through infill construction. Large centenary shade trees are replaced (if at all) by small tree species or shrubs that will never be able to create a proper urban tree canopy. Even if larger tree species were preferred by residents and the City, there is often insufficient room in the postage- size front and back yards of new infills. The end result is that our canopy is disappearing. The goal of reaching a 40% tree canopy cannot only be aspirational. It must be achievable and the built form of “regeneration” must be able to accommodate large trees if we are to have an attractive, resilient and livable city.
Big Policy Move 5: Economy
The promotion of economic development is a key policy goal. We would only add here that we believe that the long-term impact of the COVID-19 pandemic on our local economy, in particular work-related transportation patterns, is unknown at this time. Therefore, we believe that the timelines for the completion of the plan should be extended so that we can factor in the degree to which these changes will be permanent or represent a long-term trend.
COMMENTS ON INNER URBAN TRANSECT/TRANSFORMING OVERLAY
We believe that the designation of areas as transforming inner urban transects risks undermining the individual character of neighbourhoods and will tend to promote dense homogenous built environments with inadequate social infrastructure and green space.
We also have serious concerns for the inner urban intensification targets of 80 units per hectare. We estimate that Westboro’s current density is 20 units per hectare. So, achieving the target would mean quadrupling density. Imagining the kind of disruption this would cause in our community is difficult. Residents are already very challenged by the pace of intensification and this target represents a huge increase. It is also not clear how this density will be calculated. For example, would it be an average of our ward or within the boundaries of our association? In Westboro, would high densities be achieved through tower construction on Scott Street and then be averaged across the community, thus reducing pressure on existing lower density streets? Will all the R1 zoned property be up zoned to reach this goal?
We also believe that the planners need to provide more analysis to support whether in fact such a high target is necessary to achieve the overall urban growth anticipated over the next 25 years. For example, could these targets be more easily achieved by focusing more intensification in areas such as Carling Avenue or places dominated by shopping malls and big box stores with huge parking lots.
In terms of height, we note that the maximum for hubs will be 12 stories. Does this mean that once the plan comes into effect, we will no longer see 20 plus story buildings being approved for locations such as Scott Street?
For main street corridors, we strongly disagree with the maximum height of nine stories. We believe that it is difficult to accommodate buildings in excess of six stories on traditional main streets if we are to preserve the human scale that makes these areas livable. For example, imagine how welcoming the corner of Richmond and Churchill will be if we see a nine-story building on each of its four corners. And will the City continue to make exceptions as it did in the case of the 12 story Mizrahi tower on Island Park and Richmond?
We would also like to express our disappointment in the proposed maximum height for minor corridors of six stories. This in our view is excessive.
COMMENTS ON THE SECONDARY PLAN
We are not clear on the standing of the Secondary Plan for Richmond Road/Westboro. The plan indicates that changes have been made and while we have not had time to examine the revised plan in detail, it is not clear what has been changed nor the rationale for the changes. We note that the map of maximum building heights appears to be the same as the original secondary plan. It is unfathomable to think of a potential traditional main street consisting of a canyon of nine-story buildings on each side of the block between Churchill and Roosevelt which the so-called new version of the secondary plan still calls for. We note also that under both versions of the plan, the maximum height for the northeast corner of Richmond and Churchill is four stories. Yet, a nine-story building has been proposed and, based on past experience, will likely be approved. We are disappointed that the City’s intention is to make the secondary plan process an internal one, thus denying community members a crucial opportunity to input into the planning process at a neighbourhood level. On the other hand, if the City’s intention is to ignore the secondary plan when convenient (e.g., excessively high Scott Street towers and now the proposed nine story building at Churchill and Richmond), we question the purpose of investing resources in secondary plans if they are not going to be honoured.
INPUT FROM RESIDENTS
We have included comments from Westboro residents in a separate document for your review. We will continue to consult with our community as deliberations continue and encourage them to be involved directly with City Officials and Council.
Thank you for providing us the opportunity to provide our input. We look forward to further consultations on this important plan that will affect all of us for years to come.
The Board of Directors
Westboro Community Association