WfA Letter on Portlands Planning

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November 13, 2017
Mayor John Tory and Members of City Council
RE: PG 24.6 Port Lands Planning Framework 
Dear Mayor Tory and members of Council,
“Waterfront for All” represents a broad coalition of stakeholders across Toronto’s 46 km waterfront who support a shared long term vision for the transformation of the Port Lands. We believe that the Port Lands Framework Plan does not capture the vision, principles and policies contained in the Central Waterfront Secondary Plan that was unanimously adopted by city council in 2003. The “Regeneration” Official Plan Designation in that plan fully embraced the future potential of the Port Lands to successfully accommodate a diverse range of employment, mixed-use, institutional, community and industrial uses. The real challenge is one of managing the transformation of the Port Lands over an extended period of time while remaining true to that long term vision to realize the full potential of these valuable lands. 
After studying the city planning report in detail, we support the adoption of the Mixed Use Residential designation for Villiers Island but recommend that the draft Official Plan Amendment for the remaining lands be deferred as it does not represent the best way of achieving that goal. 
Our recommendation is based on the following key points. 


First, there is no need to adopt the proposed Official Plan Amendment land use designations to prevent the premature mixed-use development and protect employment uses. Notwithstanding that Council adopted an “Official Plan Regeneration” designation in the 2003 Central Waterfront Secondary Plan, parts of this plan have been appealed to the Ontario Municipal Board and have remained there over the past 15 years. As a result, it is our understanding that the legal in force OP policies for the majority of the Port Lands are designated General Industrial Areas. Polson Quay is designated General Use Areas. Lands to the north of the ship channel are designated Heavy Industrial Areas. South of the ship channel, the lands are designated Restricted Industrial Areas. The legal in-force zoning is industrial. These designations do not permit residential development. As such, Council retains full planning control over future precinct planning and zoning and can enact appropriate planning policies in a phased approach for each of the various precincts over time. 

 Second, nothing can be developed until the floodproofing strategy to re-naturalize the Don River is completed over the next 5 to 7 years. All three governments recently came together to spend over $1 Billion to embrace this much needed initiative. This landmark action was taken to realize the shared vision for comprehensive transformation of the Port Lands over the next 25+ years to create a place where people could live, work, play and take advantage of its unique potential. It was not done to only facilitate employment uses.
Third, a deferral would give all stakeholders an opportunity to re-consider the Framework Plan for the Port Lands in light of the innovative ideas that will evolve from the Sidewalk Labs participation or other similar initiatives in waterfront planning over the coming years. The results of this work can be integrated into future precinct planning and benefit from new emerging ideas.
In summary, with the exception of the Mixed-Use Designation for Villiers Island, there is no need to adopt the draft Official Plan Amendment at this time. It is counter productive and diminishes the future potential of the Port Lands. Nothing can be developed for several years until floodproofing is completed and until precinct planning policies are adopted. Council already has the full array of Official Plan and zoning controls in place to successfully manage transformational change over time.
A final point, in the case of Villiers Island Precinct Plan, we recommend that Council amend the Precinct Plan to adopt a higher percentage of affordable housing in Section 3.5.4 Affordable Housing Strategy. The stated goal is 20%, but the deliverable percentage on privately owned land is 5% or 10% depending on whether units are transferred to the City or the provided by the developer. It is worth noting that the definition of “affordable rental housing” is housing that is affordable to households with median incomes or below. By definition, an equitable community would have in the vicinity of 50% rents “affordable”. Toronto, Ontario and Canada have a long way to go to provide affordable rents to citizens. Villiers Island can be a new neighbourhood where Council moves the bar higher and sets a precedent for the rest of the Port Lands as those lands are developed.
Yours truly,
Waterfront for All