Feedback to the Official Plan

Tomorrow, March 12, feedback is due on the draft Official Plan that has been circulating since November. 

It is a giant document and I know residents and stakeholder groups are going to approach it with multiple viewpoints. I've begun to receive some feedback from community associations but thought it might be helpful as residents are preparing their own submissions to know what I've focused on.

It's going to be a long spring and summer of discussion, and I'll be working closely with our community associations to keep them apprised of how the draft appears to be changing as staff hear from councillors and residents. I'm hoping to be in a position in late May or June to host a community meeting once we have a good idea of how the draft might change before a September vote. I expect that some of the language in the draft plan will be clarified and modified as flashpoints become clear and the planning department either persists in some of its directions or adapts those in response to feedback.

The feedback copied below is technical in many places. Official Plans are technical documents and the details matter. For a plainer language version of my larger concerns, please see my post from mid-February here. Not everyone will agree with all my points, and I haven't yet read the submissions on which I've already been copied. But I did feel it was important for residents to know what I'm talking to planners about.

1. “Regeneration” as a replacement term for “intensification” is generating significant mis-trust and resentment in the community. Residents love their neighbourhoods. “Regeneration” is bringing “urban renewal” to mind for many, with its implications for the destruction of communities. “Intensification” may be controversial, but it does not carry the same baggage to the same degree. 
2. Define the 15-minute neighbourhood and use it more clearly to define transects and overlays. Allow for elements of the 15-minute neighbourhood to permit development associated with transforming neighbourhoods regardless of transect. 
3. Clearly define rationale for new minor corridors. I would argue for the exclusion of Sherbourne. New minor corridors should be implemented only after a secondary plan is adopted or amended.
4. Clearly state that in neighbourhoods singles will still be allowed to replace singles. Where the intent is to prohibit that (as in the Westboro Infill rules for Churchill), for example on minor corridors, state that clearly if this is to move forward. 
5. Clarify the distance from non-PMTSA LRT stations within which greater density than low-rise is anticipated to be allowed.
6. Formulate an articulation of the approach that underlies the Westboro Infill Study (a hierarchy of streets, normalizing existing infill patterns, equivalent massing height rules) to serve as an explicit guide to the comprehensive zoning review. 
7. Determine whether the approach to intensifying R1 zones in the inner urban transect and outer urban transect will be accomplished largely through changes to performance standards or by new permitted building typologies (minimum lot sizes versus allowing semis). 
8. Nine storeys on major corridors that have functioned as traditional commercial mainstreets is inappropriate, and I will oppose that. 
9. Section 3.5(12) should contain language that makes clear that major office use will not be permitted as-of-right in neighbourhoods except where a secondary plan exists that would permit it. 
10. Section 4.1.2(9) should be broadened to 5 km cycling distance recognizing that as a commonly-cited distance to encourage multi-modal travel. 
11. Section 4.2.1 must be more clearly explained to provide explicit guidance to the comprehensive zoning review. 
12. Section 4.4.3(f) should more objectively define “not feasible”. 
13. 4.6.3(2) holds out the expectation of the conversion of certain streets to “Living Streets”. By what mechanism will that be accomplished? 
14. 4.6.6(7) raises the question of “compatibility”. How will “appropriate architecture and materials” be determined? 
15. In section 5.2.1(4), it is stated that small, locally-oriented services may be appropriately located within Neighbourhoods. While this is supportable, residents need more clarity on what constraints will be imposed in the course of the comprehensive zoning by-law review that will follow adoption of the Official Plan. 
16.  Section 5.3.4 “provides for three storeys height permission to allow for ground-oriented missing middle development” in the outer urban transect. The new Westboro Infill Rules permit three storeys only with equitable massing rules in place. Should residents expect that three-storey flat-roofed dwellings will be allowed throughout the Outer Urban Transect, or that rules similar to the street-by-street approach adopted in the Westboro case will be implemented? 
17. At 6.2.2(2), it is noted that in minor corridors, commercial development may be allowed. This should be made subject to a secondary plan.  
18. At 6.3.1(2)(b), the draft suggests that three full storeys within the interior of neighbourhoods in the inner urban transect would be permitted. In all transects, this should be made subject to equitable massing provisions such as have been implemented in the Westboro Infill Study 
19. At 6.3.2(2), on-street parking zones are proposed to be permitted in 15-minute neighbourhoods. As a transitional measure I am supportive of this, but there is no objective definition of a 15-minute neighbourhood. 
20. At section 6.3.3, collector streets are identified as potential locations for commercial and other uses. This should be subject to the enactment of a secondary plan, with criteria that are objective with respect to their likelihood of drawing significant traffic (6.3.3(1)(e)) 
21. At 6.6.8 (1)(c), the draft speaks to the evolution of March Road to become a “grand street”. This language is vague and unhelpful, and should be removed. 
22. At section 7.3(d), the draft plan contemplates permitting amenities and small-scale commercial to support “more intensive public use” of urban natural features. This is inappropriate in areas preserved as a conservation initiative. 
23. At section 7.1(4)(ii), the sale of municipally-owned greenspaces is contemplated where there “is no demonstrated public benefit”. This is dangerously vague language. 
24. At section 10.1.7, I would ask for consideration of progressive waste solutions such as up-cycling facilities by exempting those from the definition of waste disposal sites. 
25. At section 11.2(5), if there is a pilot to be undertaken, the Official Plan should identify the geography for that. 
26. Does 11.4(3) reflect current practices? 
27. Section 11.8(1) gives authority to the City to waive the requirement for a formal pre-application consultation meeting. This strikes me as at odds with the pre-consultation meetings that have hitherto invited community groups to the table, and I would seek reassurance that “informal” consultations will not take place in the pre-application phase without similar community protections.