Which way the wind is blowing: Overview of David Godley’s comments regarding revision of Toronto’s Official Plan

A previous post is entitled:

NRU Toronto newsletter shares details regarding Toronto’s official plan five-year review

The current post shares text from a document that David Godley of Long Branch has prepared:

urban design op

By way of a preamble to David’s text, it occurred to me some time back that how decisions involving use of land are made is a key aspect of local history.

I first became interested in local history when I learned in 2010 that a school in Long Branch, close to where we were living at the time (we now live in Stratford), was about to be sold. Thanks to efforts of local residents, the school remains in public hands.

When we heard of the impending sale of the school, we organized a letter-writing campaign, which convinced the provincial government to release $2.2-million (the cost would be higher now) to enable the school to be sold by one school board to another.

The school remains in use, the building has been thoroughly renovated, and the site has been extensively landscaped.

I helped out with this project. I had a good sense of how to proceed, as I had been involved in community self-organizing.

In such a form of organizing, many people work together to organize things rather than depending on just one or a handful of leaders.

Such an approach is also aligned with a culture of leadership succession, in short-term projects and also in neighbourhood associations. It’s the ideal situation when many people have a sense of ownership of such associations, and new leaders are thereby able to step in at once as time passes.

Everyday residents have skills that give rise to agency. We have skills and we have agency especially when we work together.

The letter that we put together to save Parkview school, with input from many people – such letters need to be well researched and well written – focused on the archaeological history of the school site. I received strategic advice from several people regarding how to proceed. That mattered as much as anything.

Until that time, I did not have interest in local history. Nor was I interested in land use. With help from many people, however, since that time I’ve been  getting up to speed.

My own focus is on the packaging of texts. This is not a complicated process. A capable writer works with a text until it’s clear and coherent. You want a text that a person can read and readily comprehend. If it’s not clear your message may get lost.

I often work with other people whose strengths include archival research and data visualization. On occasion at key junctures, I have also benefitted from strategic advice; strategy is a central component leading to positive outcomes.

Strategy, plus putting in endless hours to get things done within specified timelines, is what matters above all.

Sometimes packaging of texts means simply breaking longer texts into shorter paragraphs. Sometimes it means making a text shorter so that people actually read it. Facts and figures by themselves at times have little meaning; other ways often must be found to drive the message home.

When we work on any such projects, we do not know what the outcome will be. What matters is that we do what we can.

At the current post, I seek to share information about revisions to the Official Plan for Toronto.

Following text is from David Godley (see link to PDF version of document, at top of page) 

David Godley writes:

Dear Steven Dixon,

Thank you for the documents showing the changes proposed by the Planning Department.

I note they will be the subject of a Public Meeting of the Planning and Housing on December 10 2019 at 10am (or soon after).

Clearly a great amount of thought and time has been put into the 5 year review of these sections of the OP.

My comments are from the perspective of hearings I have attended on severances and variances. TLAB hearings are the only place these applications are tested and there are strong forces trying to undermine every element of the OP. (Read attached Star editorial and letters in the Star today).

We have relied on the sophisticated policies of the 2006 plan with a few changes and there is scope for clarification which was so well done for the review ofLand Use Designation policies in Section 4.1.5.

The latest version appears generally to be a diluting of the existing policies both in terms of strength and clarity. I note that much has been added on other relevant matters.

3.1.1 Public Realm

While the non policy text is not a legal part of the OP, the current lead in to the policies seems much stronger than the replacement.

To add in a definition of public realm is helpful however there is no link to urban design which has a three dimensional aspect.

This will cause trouble at hearings and needs to be amended to reflect the reality that urban design concerns what is seen from the public realm.

This means the building facades (as you point out) but also front yards, views through to back yards, vegetation and skylines, all which will be on private land. I suggest that the definition [be improved – I am guessing here] by adding “and includes all that can be seen from the public realm”.

Further clarification should be added that states that “Urban design is the three dimensional aspect of planning which related to aesthetics, safety and comfort”.

In addition “Character is referred to features of an area which are worthy of conservation. Character is established through a three lens process outlined in Section 4.”

These are simple definitions which help both professional and lay people to comprehend urban design, a subject around which misunderstandings are common. We need simplicity since these hearings go on for 5 days or so because meanings are not clear.

Likewise under policies some meaning and clarity is lost by the changes to section 5 on page 3. Changing “seek” to “encourage” for example is a weakening.

I would keep the text and enhance it d) instead of eliminating it by paralleling Section 4 by stating “No changes will be made through planning applications that are out of keeping with urban design principles. All such applications will enhance the public realm.”

As you know Long Branch has Character Guidelines adopted by Council and these such documents are increasingly being used as a way to tackle design excellence across Ontario. Such studies should be added to the list of policies as not only are they helpful for achieving OP aims they save time at hearings by defining the broad character of an area.

At the moment the broad character outside Long Branch has to be analysed for every hearing. So I suggest adding “Urban Design Studies” as an additional way of promoting excellence in urban design.

On the application requirements I wonder why variances are not cited as needing tree related studies where trees are impacted by a proposal. COA applications are always accompanied by building drawings so that impacts can be gauged and as TLAB have pointed out is is almost impossible to judge qualitative impacts without these.

As well complete applications in areas which are subject to Character Guidelines need to be accompanied by an analysis of character through the methodology in Section 4.1.5.

An analysis using the 3 lens approach outlined in Section 4 Land Use Designations where required by City adopted Urban Design/Character guidelines should be part of a complete application. Such a provision should apply to all applications under Section 4 of the OP. An example of one is attached.

3.1.2 Built Form

My main comments are on the criteria for judging good urban design in Section 3 on Page 5. These appear to have been disaggregated and in terms of impact on neighbouring property eliminated.

I oppose replacement of Section 3 starting “New development will be massed”. This beginning is a strong statement introduced relatively recently which enables those defending the OP some impetus.

Under d) I would add sunlight and separate from privacy. Privacy and overlook are common issues at TLAB. Another section should include views and skyviews and yet another dealing with large overbearing/oppressive walls and microclimate.

This latter issue which comes up at most hearings where the applicant wants to double density of a proposal and it extends way back beyond the next door buildings. Elimination of this section would also eliminate “harmoniously” to apply to all matters not just height and setbacks as mentioned later on in the new text. Harmonious is a key word in all hearings.

Under 1e Preserving mature trees should be added to by “and limiting damage to trees to be preserved”

The OP should clarify what infilling means. Is it just different types of housing in a neighbourhood that is to be redeveloped or does it also mean adding a house within a row.

Smaller items include “materiality” which means importance so “materials” is fine.

At the top of Page 2 I think “inform” should read “create”. Lower on the page walkways should be added after laneways. Page 12, 12a needs to be stronger so adding in “in a form that reflects overall architectural design.”

While you may have good answers to the points I raise, from an initial review these policies seem to be a step back in an era that is giving greater attention to urban design and is likely to do so in the future. It would be far better to resolve issues at this stage, before adoption, through consensus.

Please let me know asap how you intend to deal with these points.

Also please could you let me know how the appeal process works. Thank you.

Yours truly,

David Godley, retired Planner and Urban Design Specialist and Local Knowledge Expert under TLAB rules.

401 Lake Promenade
Toronto, M8W 1C3