If you haven’t heard of it before, you will hear a lot about it in the future. It’s called the Commercial Policy Review (CPR) and it was approved by Guelph City Council in 2005. It is a blue print for four massive retail power centres (big box clusters) in the four corners of the City of Guelph. Although approved in principle, the site plans for each proposal are still to be approved by Guelph City Council.
One of these power centres is called Westminister Market and its to be located at 1750 Gordon Street, in the southern part of our city. City Hall has received many comments on the submitted site plan. Here is a very comprehensive review of the proposal that was forwarded to members of City Council:
I am forwarding a copy of the input I have submitted to the Planning Department regarding the Westminister Market site plan application. I believe that a number of the issues I address in my submission are relevant to all the commercial nodes around the periphery of the City.
Re: Site Plan Approval Application – 1750 Gordon Street – Westminister Market
I do not support the site plan as submitted to the Guelph Planning department.
This site plan:
Is not consistent with the Places to Grow Transportation Demand Management Requirements
Does not deliver the 3-Ds of Density, Diversity and Design
Does not meet the Places to Grow density requirements for minimum 50 jobs and residents combined per hectare of greenfield
Does not meet Provincial Policy Statement (PPS) requirements for compact development
Does not reflect the Guelph Wellington Transportation Study recommendation of intensification of nodes and corridors
Is not a mixed-use development as required by the PPS.
Does not meet the housing requirements of the PPS
Does not make efficient use of existing infrastructure.
Is not walkable and bikeable.
Does not meet PPS requirements for energy efficiency.
Does not deliver business opportunities for small businesses.
Does not comprise good urban design and an attractive public realm.
Will be a net drain on the tax baseSince I will be quoting extensively from the 2005 Provincial Policy Statement, I have included the section on its Legislative Authority.
Part II: LEGISLATIVE AUTHORITY
The Provincial Policy Statement is issued under the authority of Section 3 of the Planning Act and came into effect on March 1, 2005. It applies to all applications, matters or proceedings commenced on or after March 1, 2005.
In respect of the exercise of any authority that affects a planning matter, Section 3 of the Planning Act requires that decisions affecting planning matters “shall be consistent with” policy statements issued under the Act.
1) This site plan is not consistent with the Places to Grow Transportation Demand Management Requirements
Places to Grow states the following:
3.2.2. Transportation – General
5. Municipalities will develop and implement transportation demand management policies in official plans or other planning documents, to reduce trip distance and time, and increase the modal share of alternatives to the automobile.
This is further underlined by the 2005 Provincial Policy Statement.
1.6.5.4 A land use pattern, density and mix of uses should be promoted that minimize the length and number of vehicle trips and support the development of viable choices and plans for public transit and other alternative transportation modes, including commuter rail and bus.
1.6.5.5 Transportation and land use considerations shall be integrated at all stages of the planning process.
Guelph already has a template for local transportation demand management policies in Chapter 4 of the Guelph Wellington Transportation Study.
Here is an excerpt from section 4.2: Land Use and Urban Design Practices
The arrangement of land uses and the urban form of the community are the most important and effective long-term influences (their emphasis) on how people move throughout the community. The way in which land is used generates trips which in turn lead to the need for construction of transportation facilities. These transportation facilities provide accessibility which in turn influences land value and affects the use of land. Land uses directly influence transportation systems, and in turn, transportation systems directly influence land uses adjacent to the transportation facilities.
Many communities are putting greater emphasis on the relationships between land use and urban form and their transportation system, particularly in relation to supporting increased walking, cycling and public transit use. Contemporary community planning promotes mixing of land uses, concentration of activities in nodes and corridors and an emphasis on the “3 Ds” (density, diversity and design) in those areas where public transit is provided. (my emphasis). The objective is to create highly pedestrian- and bicycle-friendly urban environments which also support the provision of public transit. An urban form based on a series of nodes and corridors provides an ideal setting for an efficient transit system and continued investment in transit operations. In this manner, activities are concentrated in certain locations, thereby reducing the need to travel by car given the other choices available (walking, cycling and transit). This urban form also maximizes the number of people living and working in close proximity to transit and provides the support base for higher frequency operations.
The City of Guelph Official Plan contains a series of goals and objectives which promote compact urban form, mixed use development, intensification and increased residential densities, and service by all forms of transportation.
Implementing Transportation Demand Management is not only required by legislation, it is essential to the health and economic well-being of the community. The Guelph-Wellington Transportation Study states that “survey data indicates that travel demands in the study are growing significantly faster than the population, placing accelerated demands on the transportation system…”
As the movement of people and goods through the community slows down, businesses experience a direct impact on their bottom line.
The Ontario College of Family Physicians has also identified a number of adverse impacts generated by low density development and car dependence: air pollution, poor social and mental health, road injuries and fatalities and obesity. Details of their literature review can be found in their “Report on Public Health and Urban Sprawl in Ontario”.
2) The Westminister site plan as proposed does not deliver the 3-Ds of density, diversity and design:
Again, I quote from the Guelph-Wellington Transportation Study
4.2.2 Urban Form
An urban form that is supportive of transportation alternatives to the auto would consist of system of nodes and corridors which provide for concentration of activities and mix of land uses in proximity to each other, thereby minimizing the need to use automobiles for many trips. Nodes are locations for a diverse concentration of activities at higher densities (my emphasis) while corridors are areas between nodes along transit routes where higher densities and a mix of uses are also found. The nodes provide catchment areas for transit service and the intersection of transit corridors.
Development in nodes and corridors should orient activity towards the street to create very walkable environments. (My emphasis)
Current Situation
…The general objectives of the Official Plan support the development and strengthening of the concept of nodes, mix of use and compact form. As well, the Transportation Strategy Update contains a vision statement emphasizing high density multi-use nodes (my emphasis) and medium density mixed-use development along the connecting corridors.
How do we Implement?
….The City should also consider shopping centre policies to accommodate high/medium density residential permissions along with a full range of other appropriate uses. (My emphasis). Medium density mixed-use policies can be prepared for application along the corridors. The nodes and corridors form and uses could be facilitated through proactive zoning changes rather than waiting for individual proposals.
The City’s design guidelines for new development generally support buildings being located closer to the street at transit stops and place parking at the side and rear of buildings to support pedestrian movement along the street. (My emphasis). Policy and zoning in the nodes and corridors could provide incentives for this type of development and minimize regulations. Each node and corridor should have an implementation plan to address density, uses, design and implementation.
Recognizing that a municipality’s Official Plan policies regarding urban form are not always consistent with short-term market pressures for development in specific locations, the City should work with the development industry to facilitate urban form and intensification objectives at the nodes. (My emphasis)
This site plan does not integrate a mix of uses. It does not locate the major building close to the street with parking at the side or rear to support pedestrian movement along the street. In fact, the entranceway to the Superstore is oriented towards the parking lot. The entranceways of the other buildings have not yet been established.
3) This site plan does not meet the Places to Grow requirement for a minimum combined density of 50 residents and jobs per hectare.
At the February 13th, 2006 meeting on the Westminister Market development, the Loblaw representative stated that the new store would provide 300 jobs. When questioned further by Councillor Maggie Laidlaw, he revealed that 75% of those jobs would be part-time. Assuming that each part-time job is a half-time job, one can calculate 75 full-time positions and 225 part-time positions (with the same value as 113 full-time jobs), for a total full-time employment equivalent of 188 jobs. These would be provided by the “RETAIL A” store, currently planned for 11,905 square metres.
There is an additional 2,350.4 sq metres of retail space planned for the site. It seems that the Planning Department does not currently have guidelines available for calculating jobs generated per square metre of retail. Roughly estimating that 1/5th of the floor space of RETAIL A would generate 1/5th of the full-time jobs, another 38 full-time jobs can be anticipated, for a site total of 226.
When the estimated total of 226 jobs is divided by the total site area of 6.35 hectares, it yields a density of 35 jobs per hectare, well below the Provincial target of 50 residents and jobs combined per hectare.
Given the new Places to Grow density requirements, it is important that the Planning Department have a clear understanding of exactly how many full-time jobs will be created.
The density target will be measured over the entire designated greenfield area of Guelph, however the Planning Department will have to be clear as to where development will be more intensive so that the minimum target can be achieved. A built density of 35 jobs per hectare on the Westminister Market site will require a corresponding development of 65 residents and jobs per hectare over another 6.35 hectares elsewhere in the greenfield area.
Given the fact that Clair and Gordon is a major node in the City, density and a mix of uses should be added to the existing site. This can be done without affecting the floor level commercial space currently approved at the site. A higher-than-minimum density in this node would offer flexibility for lot sizes for detached single-family homes by helping to pull up the average density in greenfield areas.
A larger market of customers living on-site will also help to support the businesses in the node.
Again, I quote from the Guelph-Wellington Transportation Study:
4.2.3 Density
By increasing the density of residential and employment land uses, they can be located closer to one another, thereby encouraging walk/cycle trips between them. Increased residential densities provide a larger market, which will help sustain nearby business establishments without relying as much on access by car. Future development and intensification in Guelph/Wellington will create more walking and cycling.
… Higher density provides a larger market to help support nearby businesses in nodes and corridors, thereby minimizing auto trips to access services. Higher density and a mix of uses are also known to significantly increase the number of walk trips. It provides other benefits such as reduced land consumption, energy use and air pollution.
How do we Implement?
In conjunction with the previous discussion on nodes and corridors, the City of Guelph should identify appropriate areas where higher residential densities should be permitted and consider proactive OP and zoning changes to permit higher densities as of right in these areas. Key sites in nodes and corridors should also have minimum densities in addition to maximums in order to achieve desired results. (My emphasis) Guidelines and zoning criteria should be prepared to ensure that medium and high density development next to neighbouring low rise areas is sensitively designed and sited to promote compatibility.
The strategy to promote intensification and re-urbanization needs firm political commitment and public acceptance. Strategies to educate and promote intensification may be necessary.
It is unlikely that a potential density of 35 jobs per hectare is considered “transit supportive”. I believe that 50 residents and jobs per hectare represent the minimum density required to support transit.
Here is the pertinent section from Places to Grow:
Places to Grow
2.2.7. Designated Greenfield Area
1. New development taking lace in designated Greenfield areas will be planned, designated, zoned and designed in a manner that –
a) contributes to creating complete communities
b) creates street configurations, densities and an urban form that support walking, cycling, and the early integration and sustained viability of transit services
c) provides a diverse mix of land uses, including residential and employment uses, to support vibrant neighbourhoods
d) creates high quality public open spaces with site design and urban design standards that support opportunities for transit, walking and cycling.
2. The designated greenfield area of each upper- or single-tier municipality will be planned to achieve a minimum density target that is not less than 50 residents and jobs combined per hectare.
3. This density target will be measured over the entire designated greenfield area of each upper- or single-tier municipality…..
4. This site plan does not meet the PPS requirements for compact development.
1.1.3.7 New development taking place in designated growth areas should occur adjacent to the existing built-up area and shall have a compact form, mix of uses and densities that allow for the efficient use of land, infrastructure and public service facilities.
This site has no compact form, no mix of uses and no mix of densities. It does not allow for the efficient use of land, infrastructure and public service facilities. In fact, with a one floor big box store and parking for 800 cars, if could not be more inefficient and low density.
Places to Grow makes the following statement about Employment Lands:
2.2.6 Employment Lands
10. In planning lands for employment, municipalities will facilitate the development of transit-supportive, compact built form and minimize surface parking.
This development is not transit-supportive and does not have compact built form. With parking for 800 cars, surface parking is maximized, not minimized.
5. This site plan does not meet the GWTS suggestions for nodes and corridors.
Nodes are locations for a diverse concentration of activities at higher densities
I have addressed this in detail already in section 2. This plan envisions only commercial development at a low density.
6. This site plan does not envision mixed-use development as required by the PPS.
1.1.3.7. New development taking place in designated growth areas should occur adjacent to the existing built-up area and shall have a compact form, mix of uses and densities that allow for the efficient use of land, infrastructure and public service facilities.
The Guelph-Wellington Transportation Study also supports a mix of uses (diversity) in major nodes:
4.2.4 Mix of Uses
Locating a mix of residential, commercial, recreational, institutional and employment land uses in close proximity to each other directly connected by footpaths, sidewalks and bicycle routes reduces the need to drive for many trips. Travel distances are reduced, thereby increasing the probability that trips will be made by walking or cycling rather than by auto. Locating residential and commercial developments close to the street with parking in behind also creates a more interesting, pedestrian oriented environment which encourages walking and cycling. (My emphasis) This will reduce the need for auto trips for work, school, shopping, recreation and personal business. An additional benefit is that both daytime and night time activity is created, promoting safer streets and neighbourhoods. (My emphasis).
Mixed use development can be vertically integrated in a building, extended along a corridor, or included in a node. (My emphasis) As Guelph matures, opportunities for vertically mixed buildings should increase.
Practicality/Appropriate for Guelph
Many areas of the city could support a mix of uses, particularly the nodes and corridors and sites along the major roads. Opportunities include intensifying shopping centres by adding residential or office buildings to the site (my emphasis) and providing for a variety of different land uses along transit routes/arterial roads at medium and high densities, depending on the location.
The primary barriers to promoting mixed use development in Guelph include the current policies’ limitations, economic factors and specialization of the development industry, including difficulties in obtaining financing for mixed use projects.
There is a need to influence a change in the prevailing mindset of the development industry and the financial institutions to consider the notion of mixed uses.
How do we Implement?
Firstly, it is necessary to identify appropriate locations for mixed use development, in conjunction with the nodes and corridors review. The Official Plan can be amended to create new mixed use policies and integrate them with nodes and corridors. (My emphasis) This would lead to implementation of new zoning in these areas, including design guidelines to ensure that development supports all modes of transportation and is appropriately scaled to its neighbourhood.
7. This site plan does not meet the housing requirements of the Provincial Policy Statement.
1.4.3 Planning authorities shall provide for an appropriate range of housing types and densities to meet projected requirements of current and future residents of the regional market area by:
a) establishing and implementing minimum targets for the provision of housing which is affordable to low and moderate income households.
Until this site was down zoned by the previous Council, the South Gordon Community Plan envisioned medium and high-rise housing at this major node. This is a particularly critical issue, since this intersection is situated only 1.2 km from the southeast corner of the Hanlon Creek Business Park, one of the major employment areas in the City. This distance represents a mere 12 minute walk for the average pedestrian.
Aside from seniors’ homes, there are no multiple unit dwellings within a 3 km distance of the business park. A bread winner pulling in a good industrial wage of $20 per hour would earn $40,000 a year. In rough figures, enough for a $120,000 mortgage. A scan of the weekend newspaper shows that there is little or nothing available in this price range in the south end.
Thirty-three percent of Guelph households are renters. A variety of housing needs to be made available close to the Hanlon Creek employment lands. This can be achieved at the Westminister Market site without any reduction in the amount of commercial floor space. What is required is the addition of housing space above the retail space.
A zoning change that reflects this will bring our Official Plan into line with Places to Grow and the Provincial Policy Statement.
8. This site plan does not make efficient use of existing infrastructure.
The Provincial Policy Statements says the following:
1.6.2 The use of existing infrastructure and public service facilities should be optimized, wherever feasible, before consideration is given to developing new infrastructure and public service facilities.
Major infrastructure investments have, or will be made, in proximity to the Clair/Gordon node. A new branch library and Bishop MacDonnell high school have already been constructed. A new fire station and recreation centre are also envisioned for this area. A high density, mixed use development at the corner of Clair and Gordon would maximize the value of all these infrastructure investments and make them accessible to a broader range of Guelph citizens.
9. This site will not be walkable and bikeable.
This site plan is completely oriented towards automobile use. With almost 800 surface parking spaces, the prime real estate is going to cars. Buildings and their entrances are not oriented towards the street. There are no attractive public realm areas as part of the design.
Something imaginative and people-oriented could have taken its place. Parking could be stacked to free up public space. On the corner opposite the library, a courtyard with cafes and boutiques could surround a fountain in the summer and a skating area in the winter. Play equipment on some green space could add some outdoor fun for children visiting the library. These kinds of amenities would create a real community meeting place where people could linger over a coffee or ice-cream. The south end needs community gathering places like this.
10. This site does not meet the PPS requirements for energy efficiency.
1.8 ENERGY AND AIR QUALITY
1.8.1 Planning authorities shall support energy efficiency and improved air quality through land use and development patterns which:
a) promote compact form and a structure of nodes and corridors;
b) promote the use of public transit and other alternative transportation modes in and between residential, employment (including commercial, industrial and institutional uses) and other areas where these exist or are to be developed;
c) focus major employment, commercial and other travel-intensive land uses on sites which are well served by public transit where this exists or is to be developed, or designing these to facilitate the establishment of public transit in the future;
d) improve the mix of employment and housing uses to shorten commute journeys and decrease transportation congestion; and
e) promote design and orientation which maximize the use of alternative or renewable energy, such as solar and wind energy, and the mitigating effects of vegetation.
11. This site plan does not deliver business opportunities for small businesses.
The smallest retail building planned for this site is 6,500 square feet or 603.9 square metres. This is likely to be occupied by chain stores or other big box retailers. No opportunity whatsoever is provided for independent, small business owners at this location.
12. This site plan does not comprise good urban design and an attractive public realm.
In February of 2006, the Council of the day sought to respond to considerable citizen concern about this development by requiring that the site plan return to Council for approval. The intent was that some of the concerns would be addressed through improved urban design.
Perhaps the most insulting aspect of the current proposal is that it is almost exactly the same as the preliminary site plan submitted over a year ago. After consulting with the Planning Department, the only differences I can discern are the removal of an anticipated gas station on the south end of the development, some rearranged parking, and the addition of a drive through pharmacy on the side of the Canadian Superstore.
I expect better than this from a major Canadian retailer. A number of examples in the City of Toronto prove this is not the best they have to offer.
13. This site plan will be a net drain on the tax base.
C.N. Watson and Associates generated data based on a case study of Milton comparing the annual costs or benefits of commercial and industrial development. (Property taxes received, versus costs to service the development). Industrial development was a hands down winner, but their research revealed that commercial development is an annual net drain on the tax base.
Based on a 10,000 square foot building, commercial development in Milton incurred an annual operating deficit of ($2,132.39).
The Westminister site is just over 150,000 square feet. Applying the Milton figures, it would generate an annual net loss of ($32,000).
This could be dramatically offset by the addition of apartment units to the site. C.N. Watson identified that apartment and condominium dwellings provide a net benefit to the tax base. In Milton, this figure was $668.77 per unit, per year.
In conclusion, the proposed plans for this site are a tremendous disappointment. The possibility still exists to redeem this development without removing any of the commercial space which has already been allocated.
Thank you for taking the time to review my input.
Sincerely,
SW