Waste & Recycling


Critique of Toronto Port Lands plan

I thought I’d share this interesting letter with readers from planners and university planners critcizing Toronto Mayor Rob Ford’s plan for the Toronto Port Lands.
September 15, 2011
Dear Toronto Councillors:
The following letter explains our concerns about how to proceed with planning and
development of the Toronto Port Lands. We urge you to keep Port Lands planning under the
control of Waterfront Toronto and to respect the already agreed upon principles and the basic
framework of the Lower Don Lands Plan. In addition to ourselves, it is signed by 151
researchers, planners, designers, engineers, and others who have dedicated our professional lives to the development and application of urban design and planning best practices, both within
Toronto and worldwide. We are writing to you at this time because we are extremely concerned
that recent proposals to radically alter plans and development control for the Lower Don Lands
are ill-conceived, reckless, and, if adopted, will result in irrevocable harm to the City, as well as
higher costs and further delays.
Sincerely yours,
Eric J. Miller, Ph.D.
Professor, Department of Civil Engineering
Director, Cities Centre
University of Toronto
Paul Bedford
Former Chief Planner, City of Toronto
Adjunct Professor, Urban and Regional Planning
University of Toronto
Ryerson University
Richard Florida, Ph.D.
Professor, Rotman School of Management
Director, Martin Prosperity Institute
University of Toronto
Richard Sommer
Professor of Architecture and Urbanism
Dean, Daniels Faculty of Architecture, Landscape and Design
University of Toronto
Dear Councillor:
This open letter explains the reasons for urging you to reject efforts to remove Port Lands
planning from Waterfront Toronto and to abandon its vision. Our judgement is based on both the
facts of the case and our collective extensive experience with city-building in a wide variety of
contexts and cities, including other waterfront developments.
We have six main points to offer:
1. Flawed Reasoning. The facts concerning Waterfront Toronto’s history, performance and
current plans have been misrepresented in the recent Port Lands proposal endorsed by the
Mayor. The alternative vision is deeply flawed. In particular:
• The Mayor’s main justification for a change of plan is that little progress has been made,
and somebody has to break the logjam. This is simply incorrect, as over the last 10 years
we have seen major progress on the waterfront, including the waterfront promenade, new
piers, wave decks, Canada’s Sugar Beach, Sherbourne Common, Don River Park
floodproofing berm, and Underpass Park. The Corus Entertainment building and George
Brown College were attracted to the waterfront by this extensive public realm
investment. The West Donlands area is now starting construction and the East Bayfront
has attracted a major developer to build the vision outlined in the precinct plan. The
Mayor’s approach on the contrary is likely to slow down progress on the next stages as
development moves towards the Port Lands, because of added uncertainty, replication of
environmental assessment processes, OMB challenges, etc.
• Furthermore, the Mayor’s assertion that his alternative proposal, which includes heavy
reliance on the private sector, can do this faster and better, is not credible. In a
redevelopment of this size it is essential for a body like Waterfront Toronto to create the
public realm first and provide the context within which the private sector can build.
Investing in the public realm first substantially increases the land value and attracts high
quality developments. The public corporation can then sell or lease land with all the
approvals in place and reinvest the funds into achieving the public planning objectives
that are clearly spelled out in the Central Waterfront Plan and precinct plans.
• At the foundation of the Mayor’s criticism of the existing plan, is the suggestion that land
that will be devoted to ecologically remaking the mouth of the Lower Don River
somehow represents a loss of valuable land. This is absolutely false from a real estate,
land development, value creation and ecological perspective. An investment in
transforming the infrastructure and parkland, transportation infrastructure, and other
amenities, including well-designed streets and everyday cultural facilities will make the
rest of the land much more valuable over time, more than compensating for the land
devoted to parks and ecological functions.
2. A Flawed Vision. The proposed plans do not represent a “bold new vision” for our
Waterfront. Rather, they are a tired recycling of 1960’s thinking. The Lower Don Lands are not
Disney World. The current plan is an award-winning design that will create a whole new
community on the waterfront that will be a model for sustainable urban development. The new
proposals represent yet another attempt to bring failed suburban urban design concepts into a
downtown setting. Such ideas are being rejected around the world in cities that Toronto is
attempting to compete with for economic development. For Toronto to take such a step into the
past when its competitors are boldly stepping into the future is a strategic mistake of the first
order. If implemented, not only will these new proposals have dire consequences for the entire
Toronto East End, they will represent a failure to capitalize on the once-in-a-lifetime opportunity
that we have to “get it right”.
3. An Inferior Plan. The elements of the alternative plan so far released to the press quite
simply are shockingly inferior to the current plan. In particular:
• The Lower Don Lands plan already provides for a large amount of retail space, both for
residents and visitors, but with active urban shopping streets rather than a megamall. The
proposed “destination shopping” complex is simply a very bad idea for many reasons.
First, the need does not exist for another major shopping mall in the downtown:
Councillor Ford’s assertion that there isn’t enough retail outside the Eaton Centre will
come as a surprise to the thousands of store owners and tens of thousands of retail
employees in downtown Toronto. Building a megamall would have a major negative
impact on the retail core and especially all the successful retail strips that have devoted
huge efforts at revitalization through BIA’s and hard work. Second, placing a major mall
in this location would generate a transportation nightmare for the Toronto East End
requiring a parking demand of approximately 6,000 spaces based on conventional
standards which is a waste of valuable waterfront land. The overwhelming majority of
shoppers travelling to this mall would come by car and would continue to do so once the
spaces were provided. In addition, the road system in the East End could not reasonably
accommodate this additional burden, leading to significantly increased congestion on our
roads and a significant degradation in the quality of life for all East End residents.
• The proposed monorail is a technically inferior option to the recently cancelled LRT line.
The proposed alternative would not be able to handle the volume or diversity of
anticipated user needs. A transit focused waterfront would be abandoned in the process.
• Malls do not represent a sustainable vision for prime waterfront lands in Toronto. In the
U.S. 20% of the 2,000 malls are failing and a staggering half a billion square feet of retail
space lies empty. Even Wal Mart has abandoned 400 stores across the U.S. The great
irony in our current debate is that in many of these U.S. locations planning efforts are
underway to convert dead malls into mixed use centres with lots of residential
development! Here the proposal is to do the reverse. While the Toronto economy is
certainly stronger than in many parts of the U.S., no logical evidence has been presented
as to why this proposal for constructing massive amounts of new retail space is
warranted, either as an economic development or an urban development strategy.
• Re-naturalizing the mouth of the Don through the three outlets of the existing plan
achieves flood-proofing while the Mayor’s plan does not. It maintains the hard edge
Keating channel and allows for the water to simply flood a north-south park The proposal
will remove a lot of public park land, which is important both environmentally and as an
attractive public space, much as in Chicago’s waterfront.
• The existing plan can be financed from increased land values and resulting tax revenues.
• Given the plethora of giant Ferris wheels already in existence around the world, the
notion of building one here on precious waterfront land is hardly a novel idea or one that
will put Toronto “on the map” as a tourist attraction. In functional terms it is also largely
redundant, given the existence of the CN Tower, a truly iconic symbol for the City and
one that already provides spectacular views of the City and the Lake.
4. Delays. The new proposal would also require a new Environmental Assessment, precinct plan
Official Plan Amendments, zoning and public consultations. This would take years and would
result in a guaranteed major OMB hearing. In the meantime, major developers who are now
ready to invest and build in accordance with the existing Plan would be put on hold and may go
elsewhere. Rather than speeding up the process of developing the Port Lands, it will almost
certainly slow it down. Contrary to assertions that have been made, Waterfront Toronto has been
moving as expeditiously as possible to develop the Lower Don Lands in a professionally
responsible and market responsive manner. The new proposals can only serve to seriously
interrupt and delay the current momentum.
5. Long-Term City Building. Further, despite the Mayor’s claims, the proposed new plan is
not, in fact, an exercise in city building at all. Rather, at its core it seems to be simply a
desperate attempt to sell off extremely valuable city assets at bargain basement prices to
developers to raise a one-time contribution towards reducing the City’s deficit. The “city
building argument” is just window-dressing for a land deal that will benefit the parties involved
but that will leave the City much poorer in the long run. The extreme short-sightedness of this
should be apparent to all. The Waterfront is a legacy that we need to preserve and pass down to
future generations. We don’t sell our house if we fall behind on a credit card payment – we find
other and far better ways of paying off the debt, and we keep the house for our own and our
children’s use long into the future. If we sell this land off to private interests we will never get it
back, and we will do major permanent damage to what should become a vital and exceptional
part of the downtown core.
6. Consultation and Democratic Process. The backroom nature of this proposal, the lack of
open consultation and the absence of City staff input into the process are inexcusable given the
years of extensive consultation associated with the existing plan. This mode of decision-making
represents a very serious step backwards in the governance of the City, and, over and above the
immediate threat it poses for proper development of the Lower Don Lands, it poses a very real
threat to democratic decision-making in the City. Without open and transparent processes,
without consultation of both the publics affected and City staff, and without Council exercising
independent judgement over decisions extremely poor decisions will all too often occur. When
these decisions so clearly benefit a privileged few to the detriment of everyone else, then
government is simply not doing its job. In the case of the recent proposal for the Port Lands, it is
not clear that anyone stands to benefit except a developer or two, while the entire City (and
particularly the residents of its east end) will suffer from increased traffic congestion and, even
more critically, the lost opportunity to build a major new sustainable waterfront community on
the edge of the existing downtown.
• The proposal violates the four core principles embodied in the “Making Waves” Central
Waterfront Plan that was adopted unanimously in 2003 by Council.
• It represents a complete retreat from the position successfully argued by the City at the
OMB hearing that dealt with the November 10, 1999 Home Depot proposal for a 10,000
square metre suburban-style Home Depot store surrounded by surface parking at
Lakeshore and Cherry. The hearing deemed that the construction of major retail facilities
on these lands was an inappropriate use of the land, which should be maintained for
higher and better uses (OMB Decision Order 2059).
• The existing Lower Don Scheme was selected as part of an international design
competition in which some of the most innovative, and internationally recognized and
celebrated architects, landscape architects, urban designers, ecologists, planners, and
economic development consultants participated. The selected team – including Ken
Greenberg and Michael R. Van Valkenburgh – has successfully remade the waterfront of
Brooklyn, among other cities to great effect and acclaim. Because of the Don and other
Waterfront Toronto projects, the transformation of Toronto’s waterfront has become an
object of worldwide interest and study. This alone has added value to the city of Toronto
and continues to increase its standing on the world stage.
• The proposal by CivicArts /Eric Kuhne has not been vetted through such a process of
international competition, and it is uncertain that it would stand up to the scrutiny of a
serious, independent jury or review panel.
It is appropriate for cities to review undertakings from time to time, but current Port Lands
planning needs to be kept under the control of Waterfront Toronto and to respect the already
agreed upon principles and the basic framework of the Lower Don Lands Plan. Radical and
erratic changes of direction send the wrong signals to investors, the public, and to all those who
participated for so many years in the creation of an already approved plan.
For all these reasons we ask that you as Councillors approach this vital question carefully and
with an eye to the future of the City in your charge.
Sincerely yours,
Eric J. Miller, Ph.D.
Professor, Department of Civil Engineering
Director, Cities Centre
University of Toronto
Paul Bedford
Former Chief Planner, City of Toronto
Adjunct Professor, Urban and Regional Planning
University of Toronto and Ryerson University
Richard Florida, Ph.D.
Professor, Rotman School of Management
Director, Martin Prosperity Institute
University of Toronto
Richard Sommer
Professor of Architecture and Urbanism
Dean, Daniels Faculty of Architecture, Landscape and Design
University of Toronto

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