Our response to the Round 3 consultations about the Port Lands Acceleration Initiative
CodeBlueTO has a number of concerns, questions and comments about progress on the Port Lands Acceleration Initiative (PLAI) that we wish to express at this stage.
However, we first want to indicate our gratification that the PLAI review of the Environmental Assessment’s flood protection options has confirmed that the preferred alternative (4WS) continues to be the optimal approach to flood protection of the Port Lands – albeit with suggested realignments. We also recognize the value of the additional phasing and costing analysis, which has identified a potential strategy for staged implementation for flood protection and development. Although few details have been made available, it also appears that there is some optimism that the process will lead to concrete funding or financing strategies that can start to make the first steps of Port Lands revitalization feasible, even in these challenging economic times.
While important progress has been made on the business planning side of the initiative, we are concerned that the analysis is seriously underdeveloped in areas that are critical to the success of the PLAI – both for building broad support for the work in the short run, and for achieving the important city-building goals of the Central Waterfront Plan over the longer term. As a result, we have a number of questions, concerns and comments about the work that has been shared to date, as well as some specific suggestions as to what steps might be taken over the next phase.
1. Naturalization and River Design
… to establish and sustain the form, features, and functions of a natural river mouth within the context of a revitalized City environment while providing flood protection up to the Regulatory Flood.
— Terms of Reference: Goal of the Don Mouth Naturalization Project Environmental Assessment
NATURALIZATION: First, CodeBlueTO wants to stress thatnaturalizing the Don River in the Lower Don Lands is a separate and distinct issue from resolving the issue of flood protection for surrounding areas. Indeed, we know from the work on the West Don Lands Flood Protection Landform that the engineering requirements for flood protection can, in fact, stand in the way of habitat restoration.
No evaluation of naturalization potential for the realigned 4WS (4WSR) proposed by the PLAI has been provided. However, we feel that the proposal’s reduction of the size of the flood plain, combined with a reduction in the overall green space, will limit aquatic habitat value while also drastically reducing the potential terrestrial habitat value – unless the open space devoted to active recreation is severely curtailed, which no one would wish to see. Simply put, a naturalized Don River mouth with virtually no tree canopy would be a serious choke point for migration of neotropical passerine (perching) birds, the very birds that currently pass through. Even as compared to existing conditions in the Port Lands, such a revision could pose a negative effect on bird migration.
Members of CodeBlueTO are also very concerned that construction of a naturalized river mouth will have to wait until phases 4 and 5 of redevelopment, which requires waiting until the agreement with the adjacent landowner over use of the dock wall expires – i.e., until the adjacent landowner moves from its present location. This leaves us wondering whether a naturalized river mouth will be achieved in our lifetimes. Indeed, we wonder what the impact of dock wall uses will be on adjacent aquatic and terrestrial habitat in the interim.
Although an extended and detailed discussion of naturalization choices and strategies for the river mouth was an important part of the public consultation and technical work under the existing Environmental Assessment, there has been no similar discussion as part of the PLAI. It is essential that the specifics of naturalization be addressed as part of the current initiative. Each phase of development of the river and its related ecosystems – whether in three phases or in five – must include a specific commitment to naturalization. In other words, completing part of the overall naturalization plan should be a commitment in each phase of the development, with associated costs identified in the plan.
The recommendations that go forward must address how a naturalized river will be achieved – including technical details as to how a realigned 4WS will be designed and implemented in order to:
- Optimize aquatic and terrestrial habitat;
- Improve linkages between habitats;
- Enhance biodiversity of aquatic and terrestrial species;
- Accommodate future changes in the environment.
— Terms of Reference: Don Mouth Naturalization Project Environmental Assessment
This would require articulating a comprehensive definition of “naturalization” to determine whether or not modifications of existing plans for the Lower Don Lands conform to the EA’s requirements.
We recommend that a series of stakeholder workshops be convened over the next two months to evaluate the capability of a realigned 4WS to meet the naturalization goals set out in the EA Terms of Reference. These workshops should consider:
- The options for terrestrial and aquatic habitat creation along the course of the realigned river mouth, The Don Greenway, and in upland areas;
- The implications of proposed dock wall retention where the river meets the Lake; and,
- Options for implementing naturalization components at each phase of development.
RIVER DESIGN: As was noted repeatedly in the stakeholder and public meetings, there is significant concern that, in optimizing for cost and development potential, the current river design has lost the “magic” and transformative power of the existing design by Michael Van Valkenburgh Associates (MVVA). There has been repeated criticism of the decision to reduce green space along the river course – moving it instead to mid-development blocks. There has been criticism of the river path itself, which appears to reproduce the same unnatural 90° turn as the Keating Channel. There are concerns that bringing the river out in its final stretch saves a few acres of development land at too great an expense to naturalization and place-making.
We believe a better result can and must be achieved from an urban design perspective. We are recommending that a design process be initiated immediately with stakeholder involvement from the outset to enhance the river design and integrate work from the naturalization workshops. We further recommend that the MVVA team be invited back to lead this design process, as they have already worked extensively with all of the parties, including community stakeholders, and have advanced knowledge of aspects of the relevant technical requirements. This process could start with an interactive planning event resembling the Don Greenway charrette, which provided a productive and creative opportunity for education, visioning and consensus building.
We share the concerns of many at the SAC/LUAC and public consultation meetings that planning for transit has not been adequately undertaken.
As the PLAI research has indicated, high quality rapid transit in the Lower Don Lands and Port Lands is essential to attract the kind of private sector investment that is necessary to achieve the City’s aspirations for economic revitalization. Creating quality of place through the provision of viable, rapid, high quality transportation is a critical necessity for creating livable new mixed-use neighbourhoods. In our view, a bus right-of-way – even as a stop-gap measure – does not constitute adequate planning for the area. The negative reaction of investors in East Bayfront to the failed delivery of the promised Queen’s Quay LRT should confirm this point.
As with plans for other infrastructure for the area, we expect that a detailed plan for funding and implementation of high-quality rapid transit – transit that can support the concentration of workers and residents projected for the area – will be included in the next round of public and stakeholder consultations.
3. Business Plan
A great deal of work has been accomplished on the business plan side of the PLAI. Many consultants have been retained to analyze infrastructure implementation and phasing costs, potential development pace, potential revenues, potential financing and funding mechanisms. The SAC/LUAC and public have been given a very high-level report on the results of this work, but the information received to date has tended to raise more questions than it has answered.
- When comparing the PLAI realigned 4WS with the EA’s preferred course for the river, has there been an evaluation of whether the revised version improves or diminishes potential land value? Is there a loss of economic value to having development on only one side of Don Roadway and Commissioners Street?
- Is a “main” street with retail at grade best served from an urban planning viewpoint by single loading it? Commissioners and the Don Roadway may not be envisioned as this kind of street but, if this is the case, what are the “main” streets?
- Is there any reason why the EA preferred course could not have been phased in a way that is similar to the phasing being proposed for the realigned version?
- Has naturalization along the river course and within the Don Greenway been included in the infrastructure costing? If so, what has that costing been based on?
- How would the costs and phasing strategy change if some part of river naturalization were included in each development phase?
- What and where is the land that is being reserved for a future “transformational” use?
- Will it be recommended unequivocally that any revenues or development charges from the Port Lands will be reinvested in Port Lands infrastructure costs? How will those arrangements be secured? Will the arrangements include any kind of contribution towards the “River Precincts” and “River Mouth” phases of the flood protection?
- Given fiscal constraints, does it make sense to rule out Tax Increment Financing and other value capture tools completely, when jurisdictions around the world have found ways to use such tools for sine qua non projects like transit-building?
- And, of course, the big unanswered question: Where does the first instalment of funding come from?
Again, we are requesting that one or more technical briefings be conducted on the business plan issues to allow stakeholders to review the analysis in more detail and to explore questions about the analysis. We recommend that one briefing be held relatively soon to deal with questions coming out of the SAC/LUAC and public meeting, and that a second briefing be held toward the end of the summer to allow a more in depth discussion of the specific funding or financing recommendations.
4. Comprehensive Planning for the Port Lands
At the beginning of this process, it was understood that the PLAI was intended to look at the Port Lands as a whole – a goal that has had broad support from a public that did not want to see one-off developments approved without an overall road map in place.
To date, some very preliminary steps have been taken in the form of identifying possible planning precincts and articulating certain values – such as the Central Waterfront Plan “core principles” – that are intended to guide planning. But it seems fair to say that, so far, what has been shared with the public has been very rudimentary.
We are aware that implementing comprehensive planning for the whole Port Lands is a daunting task – particularly given that for much of the Port Lands, the development horizon is a long way off. At the same time, there is a need to move quickly to a greater level of specificity in areas that might be ripe for development. An example can be found in the film precinct, where private land owners / leasees have begun to put together precinct planning proposals on their own. There is a need to integrate that process with initiatives in other areas, such as South Riverdale, in order to seize every opportunity to create better connections between the Port Lands and the rest of Toronto.
We note that developments in the concrete campus area are in varying stages of approval. Vacancies on the Hearn site, the Lever site and Cascades site present large-scale immediate opportunities for public open space and transportation infrastructure. These projects need to have a bigger planning framework to establish promontories, pedestrian and cycling networks, and view corridors and to connect in with the longer-term plans for development and open space centred on Cherry Street. As well, a framework is required to formalize needed connection improvements at Cherry Street, Carlaw and Leslie. Such a framework will provide some certainty for employment uses that will continue to exist in order to secure well paying jobs in the Port Lands. They need buffers and safe passageways through to ensure compatibility with existing and future uses.
By the end of the PLAI, we expect to see a program for advancing high-level framework planning for the full Port Lands, with a specific time table for initiating precinct planning in key precincts. And, as with all waterfront planning and development processes, we expect confirmation that Waterfront Toronto will continue to be the planning, development, and implementation lead for the Port Lands.
CodeBlueTO would like to thank you for the opportunity to comment on this phase of the PLAI initiative.
Friday June 8 is the deadline to submit responses to Round 3 of the Port Lands Acceleration Initiative. This is a chance to outline visions for the waterfront’s Port Lands district, and what our priorities should be there.
To find out how to send comments, please go to http://www.portlandsconsultation.ca/.
In August, there will be a final public meeting about the PLAI before a report is submitted to City Council. Details to come.
Key background material:
- Explore Projects: The Port Lands, Waterfront Toronto (web page)
- Planning the Lower Don Lands, Waterfront Toronto (web page)
- Making Waves: principles for building Toronto’s waterfront(summary), City of Toronto (PDF)
- Port Lands Consultation, “your portal for learning about and participating in the Port Lands Acceleration Initiative”(PLAI website)
- Environmental Assessment Executive Summary, Don Mouth Naturalization and Port Lands Flood Protection Project, (PDF)
See option 4 of Table E-2. “Alternative Discharge Points and Descriptions” on Pg 13 (ES11), later named 4WS. This table offers comparisons with the other original options that were considered for the naturalized river mouth.