November/December 2019 update from David Godley regarding Urban Design Policy Draft Official Plan. Urban design policies being gutted?


UrbanDesign Op 1 Public Realm

urban design op 2 Built Form

Following text is from David Godley:

Greetings from Long Branch

URBAN DESIGN POLICIES BEING GUTTED? If you wish to be involved write to Stephen Dixon, Senior Planner, City of Toronto.

Special Meeting of Planning and Housing  Committee Room 1 at City Hall, 10 December starting at 10am or soon after. The attachments are the up to date documents which may be revised before the Planning and Housing Meeting

Attachment 3 – Incorporated Public Realm Policy Revisions with the In-Force Official Plan
Attachment 4 – Incorporated Built Form Policy Revisions with the In-Force Official Plan


Hello Again, I have had a response from Steve Dixon the Official Plan Review project manager:

Hello David,

Thank you for your emails and comments on the Public Realm and Built Form policies. The July 2019 version of the policies (from PH7.10) is not the final version. It was used as the basis for the final consultation and the statutory public open house which took place on September 16, 2019. There will be refinements made to the policies though I do not anticipate wholesale changes. The urban design review has been a multi-year process that has culminated in the final recommended policies, which will be available to the public online and in hard copy at Metro Hall on November 20, 2019.

The Special Meeting of Council to hear final deputations on the policies is scheduled to coincide with the December 10, 2019 Planning & Housing Committee meeting, which begins at 10:00am. Should Committee support the policy amendments, they will then proceed to the December 17/18 council meeting for adoption.

Regards, Steven

Steven Dixon, MES, MCIP, RPP

Senior Planner, Official Plan

Strategic Initiatives, Policy & Analysis

City Planning Division

City of Toronto


I have also had a response from an informed highly member of the legal community endorsing my view (below). It appears that those impacted are not meaningfully involved in the development of the policies and that it is the development sector is ruling the roost. The most effective policy in Section 3 has been removed in its entirety. I also believe that the draft policies do not fully comprehend the notion of urban design which is why so many anomalies occur. I intend to be at the Dec 10 meeting although will be away until the end of the month. I am hoping someone else will pick up the pieces while I am away.

David they gutted the policies for Neighbourhoods. Previously the protections applied to all built forms, now only tall buildings. The midrise provisions do not deal with adjacent properties and given midrise relates to infill and townhouses this is a significant concern. Similarly with public realm they removed the views from natural areas so that developers can overwhelm the natural areas by massing buildings close to the edge of ravines not under TRCA rules.

If you look closely BILD was instrumental in these discussions. The general public less so.

More importantly we do not know if any comments during the public discussions have been incorporated.

These are the rules of engagement for 10 December Planning and Housing special meeting.

Hi David:

When the item appears on the agenda at the December 10 meeting, you may hit the button to say you would like to speak or submit a communication.  Here is the link to the agenda –

The agenda will be released on December 3 and at that time there will be an agenda item designated for this report.

The time to speak is five minutes unless the Committee decides to change it to possibly three.  We will not know about this until the meeting starts.  I would be prepared for both five and three minutes just in case.

This item will not be heard before 10:00 a.m. but could be heard any time after that.

Sincerely, Christine Chandler

City Clerk’s Office

tel: 416-397-4579


On 11/5/2019 10:47 AM, David Godley wrote to Council Members and key Neighbourhood Associations:


Good Morning Council members,

I am concerned the current version of the OP Review on urban design will cause difficulties at hearings. This is essentially the only place where the OP is tested.

So far my experience is that TLAB are doing a brilliant job of integrating urban design issues into planning. One member even commented not enough urban design was brought to the table.

Urban design is all important to the electorate as it enriches their quality of life and seeks to prevent unwarranted impacts. This duality does not seem to be recognised in the new policies.

I am requesting a deferral of the matter so that a group of people knowledgable about Urban Design, especially its use at hearings, be gathered to go through the document win detail to make it an effective tool for the City to achieve its goals and objectives. The letters below point to some issues. I have also attached a copy of my base evidence for 65 40th Street TLAB hearing which shows the difficulties created by challenge from applicants.

The new policies appear to be a step back from the ones currently in force. The 2006 OP was a sophisticated document and set out comment and policies in a succinct manner easily communicated to a hearing officer. It was a trailblazer for urban design. While improvements need to be made with the hindsight of 20 years (and have been to some extent) the is a critical need to recalibrate the new policies for the future. From my quick review the figurative baby looks to be in danger of being thrown out with the bathwater. As the OP points out good urban design is good business and good social policy.

Yours truly, David Godley (Deisignated Local Planning Expert by TLAB)

401 Lake Promenade

Toornto M8W 1C3


Letter to Steve Dixon, Planning Department 4 November 2019

Hello Steve,

I have looked over PH7.10 Attachment 3. Not sure if this is the final version to be considered by P&H Committee on Dec 10.

If I have jumped to conclusions erroneously please forgive me.

I am mostly concerned about neighbourhood issues.

I agree clarity and addressing evolving issues is key, as you say in you reports.

The Planning Department has abandoned relevant comment on urban design so residents (and Urban Forestry) have taken over the mantle of implementing the OP at TLAB.

The majority members of COA do not use the OP or in fact any planning or legal consideration.

As a 7 TLAB hearing attendee (and each one takes about a week) there are many issues relating to urban design we have experienced. Naturally the builders reps. look for every loophole or alternative interpretation in policy. Even with City adopted Long Branch Character Guidelines we have difficulty defending the OP.

The main items that caught my eye are:

1) CIP recognise aesthetics are central to planning but many planners think they are equivalent to cake decoration. Some sort of definition is needed that urban design is the third dimension of planning, it is what you see from the public realm and usually how a development is judged. Nearly all our severances/variances are strongly urban design oriented with little land use planning involved. There needs to be cross reference to Section 4.1.5 eg massing,scale and respecting and reinforcing character

2) The Public Realm needs to include not just publicly accessible land but what you can see from it such as trees on private property and skylines.

3) Guidelines are the most effective means of achieving excellence in urban design but I do not see them mentioned. Many municipalities do these. Any evaluation required should be part of a complete application and guidelines should form the basis of a design.

4) As well as skyviews, light and sunlight, a consideration of overpowering walls, privacy, views in general, micro climates etc should be mentioned but perhaps that comes in Built Form impact.

5) Trees are of stupendous importance with climate change and have numerous benefits (see attached). Severances and variances that damage or destroy trees should be turned down unless they comply to the neighbourhood zoning. It is also the proposal not just the variance and severance which should be assessed separately. The tree section needs beefing up even though it is pretty strong already. After all the Op looks a couple of decades ahead.

My base evidence for 65 40th shows the sort of issues that should be dealt with up front in the OP.

The OP has the power to deter hearings, and though an effort has been made by you and your team , I feel it is a long way from being fully effective.

Please advise if these points and perhaps others ( I may look at Built Form but am about to leave the country for 3 weeks) can be included.

I have done this quickly to start a conversation so have ccd people who might be interested.

David 401 Lake Promenade M8W 1C3

5 November 2019, Letter to Steve Dixon, Planning Department

Hello Again Steve,

I have done a once over of PH7 Attachment 4 and there seem to be a number of weaknesses. I can see you have done a lot of work and added to policies to give more direction. It is a complex excercise and cannot be easily grasped by lay people.

The major one is that urban design incorporates reviewing impacts on people who live nearby as well as the public realm (the walls and rooms although not ceilings) . This seems to have disappeared yet is one of the subjects which takes up much time at hearings. Hearings of course are where the policies are tested. They need to be succinct so I am concerned Section 3 starting new development has been eliminated. The criteria need to be upgraded.Policies in Section 3 are like the policies in Section 4.1.5 which are easily applied. The upgrading of 4.1.5 was reached by settlement at LPAT and was a job very well done. this is lacking in the current policies and suggest that a team be put together to ensure that urban design policies can be effective at hearings.

In addition

1) the policies on trees need to be strengthened e) Preserving existing mature trees is noble but we lose mature trees all the time in approved severances. Also damaging trees is a concern even when they overhang from a neighbouring property. glad to see arborists reports are needed but this should be part of policy and submitted as part of a complete application. And it is not only mature trees that should be preserved.

2) No mention is made of human scale where buildings are to be stepped back both at the front on to the street and to the back. Christopher Alexander makes the case for 4 storeys so people on the high floor can speak to those on the street as well as allowing more light.

3) minor matters like what is a street tree we had a discussion on at the last TLAB hearing I attended. Clearly they are supposed to include trees on front yards. Why materiality rather than materials. this confuses as materiality means important.

4) Links should be made to other sections of the Plan eg Vision Section 2 and Land Use Section 4. At the moment Section 3 is floating as if it is something separate from planning.

My view from being at many hearings and attempting to give clarity to urban design policies is that the building successful Cities in Section 3 of the OP is weaker, less clear and comprehensible and will lead to greater confusion at hearings. We have some very bright lawyers and development planners working against the public interest for their clients

I suggest that a team of stakeholders meet to go over what are some of these points and identify more. The versions of 3.11. and 3.1.2 are a step back which is ironic because the original OP was a bold step forward giving credibility to urban design. Visual matters are becoming  mainstream and are critical to severance/variance applications in neighbourhoods.

I will be writing to Council Members alerting them of the flaws in these polices (and I am not discounting that I have made misinterpretations) saying that the draft does not pass muster and recommending more work be done before they are adopted. A group with urban design knowledge would lend itself to the  large volumes of material to review.

Please can you advise me of the steps that the document has to go through to reach formal approval and the opportunity for members of the the public to challenge the policies.


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