Rong Yu and John Duncan
City Planning Division
Dear Rong and John,
We are providing our comments on the draft proposal that has been the subject of recent public consultations. We are concerned about the proposals that appear to be one-sided and do not reflect an evidence based and careful assessment of the Mid-Rise Guidelines developed by Brooke-McIlroy Planning, dated May 2010.
- Important stakeholders were not represented in the consultation process to develop the revised Mid-Rise Guidelines.
- The process appeared to rely on input/guidance from the development industry to generate a final report and recommendations including draft revised performance standards.
- There was no similar opportunity for input from residents including those living in the immediately abutting lands and other affected areas
- The public is now being asked to comment on what appears to be a “done deal”.
- Lack of assessment of the existing Mid-Rise Guidelines: Limited planning studies appear to have been undertaken to develop the new proposals resulting in many concerns to be addressed.
- A number of Mid-Rise buildings have been developed – why were these not analyzed in terms of their performance, rather than simply receiving objections from a self-interested industry?
- There is no information as to what the issues are with the existing Mid-Rise Guidelines (dated May 2010) that were developed by a well qualified architectural firm. Why would the City not retain the same or a similarly qualified firm to conduct a full assessment of the Guidelines, and their implementation, based on a review of a sample of the 150 or so mid-rise buildings constructed since the guidelines are in place.
- Substantive issues with the Proposals
- The proposals have rear setback/angular planes but increase the base to 6 floors. Why 6 floors when the height for abutting neighbourhoods is 4 floors?
- The sections show floors extending from the street to the rear lot line but this is not a workable development form.
- Why is there now only one building form option for site size given the variety of lot sizes in the City?
- How are typical floor plans for double corridor floors accommodated? How can a residential floor plan be deeper than that limit? Yet the sections show deep boxes extending from the street 6 floors high to 7.5m from the residential lot line.
- Given that the tower is at the street line, what happens in the deep space to the rear? On a very deep lot there could be another residential component with a green space between. Or is this kept as open space above a lower retail/office podium space?
- The 45 degree angular plane limited the rear of the building at a setback of 7. 5m. It appears to permit only 2 or 3 storeys at the lowest floors depending on the use of the floor area. Retail and service areas can have higher floor to ceiling heights. But given that 4 storeys is now through EHON policies the maximum height, why is the permitted height at the setback line adjacent to existing residential areas not 4 storeys?
- Why is there no height limit, given the height of a storey can vary significantly?
- Why are large setbacks above grade not encouraged, as they can accommodate green roofs?
- What are the spring/fall shadow impacts of these different options?
- What are the visual impacts of the different options, such as a 4-storey rear height limit?
- The proposal claims to address issues of affordability, and climate change, and permit use of mass timber in construction.
- Mention was only made that mass timber buildings did not like step backs.
- Amending the angular plane to permit more units does not affect affordability unless the sale prices are adjusted. Price adjustments are possible but unlikely in the case of market housing as prices are set by the housing market, not by construction costs.
- The revised guidelines do nothing for climate change. They do not require tree cover retention (or its increase) and do not require “green roofs”. The step back areas can be effective green roofs.
- The claim that the use of mass timber is not possible under existing guidelines has not been substantiated.
- Need for a buildings data base
- The proposal should include development of a reference list with addresses of completed projects with key planning/construction data – such as main street road width, lot size and shape; lane access or not, use of wood frame etc.
In summary, we believe that a major focus of any revisions to the 2010 Guidelines should take account of the “lived experience” with the products resulting from the current Guidelines application, not from the Industry comments, which is conflicted.
Finally, we recommend that the proposals, before they appear in public again, should be reviewed by the City of Toronto Design Review Panel.
cc: Emilia Floro, Director, Urban Design, City Planning Division
Gregg Lintern, Chief Planner and Executive Director, City Planning Division
Kerri Voumvakis, Director, Strategic Initiatives, City Planning Division