Tall Buildings, Inviting Change in Downtown Toronto, Consultant’s Study

May 1, 2011 · 2 comments

in Current Issues


City Planning Division
Tall Buildings Downtown Project

Dear Sir/Madam:

This correspondence is provided in response to the request for public comments on the “Tall Buildings, Inviting Change in Downtown Toronto” Consultant’s Study, its findings and recommendations, part of the Tall Buildings Downtown Project.

The Federation of North Toronto Residents’ Assns. (FoNTRA) believes that the downtown is a resource and an asset to the whole city, and as such planning policy proposals for this area frequently merits wider input, as in this case. However, in addition, the Project’s study area includes some resident associations which are FoNTRA members.

1. A key problem with the Tall Building Study and the numerous “Regulations” is its fuzzy status within the statutory planning approval process. It contains many completely arbitrary physical prescriptions – the requirement for podiums everywhere, for example – and has little or no relationship to land use and density issues. Planning for downtown requires more than a narrow focus on “buildings” as architecture.

2. The report indicates there are numerous unresolved implementation issues which are crucial to tie the urban design proposals to the hard core planning issues. The call for even more design guidelines and design review panels again reflects a questionable relationship to the existing planning system.

3. An overall concern about the Tall Buildings Study is that it takes as a given that unless specifically exempted the downtown will become uniformly occupied by tall buildings. The proposal provides huge incentives for demolition and wiping out important urban fabric, for example in the Church and Jarvis areas, despite the Regulations referring to protection of heritage resources.

The following recommendations (“Regulations”) pertain to heritage resources and viewsheds:
Regulation #16: Tall buildings will not interrupt the view corridors or appear behind the building silhouettes of the three Landmark Views Downtown: Queens Park, Old City Hall and City Hall. Other landmark views should be considered in the review of tall building proposals.
Regulation #17: Tall buildings will not visually impede the setting of listed/designated heritage buildings. Where heritage buildings are low-scaled, the podium of the tall building will respect and reflect the unique urban grain and scale, visual relationships, topography and materials of the surrounding historic building(s). The tall building will preserve and enhance the character and appearance of the setting of the adjacent listed/designated building(s).

While they represent good statements of principle the proposed Regulations are not worth very much without a sound mechanism for monitoring and enforcement. All development applications need to be analysed by the City of Toronto to determine impact on viewsheds.

The chosen vantage points in the Tall Buildings Downtown policy are too close to Queen’s Park to protect views from further down University Avenue and thereby risk undermining the Bloor Visioning Study1. Other important landmark views, such as to St. James Cathedral, and to the Grange, are not included.

Finally we are aware of work being done by the Architectural Conservancy of Ontario which has determined that the heights proposed by the Tall Buildings Downtown project for Bloor Street do not protect the silhouette of Queen’s Park. Further modelling is needed to test whether the heights in the policy in fact protect important views. We would recommend that additional regulations be included as follows:
Regulation 16a. Modelling data to show the impact on landmark viewsheds will be required to be submitted along with all development applications
Regulation 17a. Similar to Regulation 16a Thank you for the opportunity to comment.

Yours truly,

Geoff KettelPeter Baker
Co-Chair, FoNTRACo-Chair, FoNTRA
129 Hanna Road124 Sherwood Avenue
Toronto, OntarioToronto, Ontario
M4G 3N6M4P2A7

Cc: Mayor Ford and Councillors
Gary Wright

1 The language in the Bloor Visioning Study says that there is to be no impact on the landmark viewshed from University Avenue

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