The following is an Open Letter to Greater Sudbury
Council Regarding a Kingsway Entertainment District.
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I am writing today with regards
to the recent decision to locate a new community events centre on a
site located on the Kingsway, east of Falconbridge road. It is my
sincere hope that Council reconsiders this recent decision, in light
of the progressive policy environment which exists in the City's
Official Plan, the Downtown Master Plan, and “From the Ground Up”,
the City's strategic economic development plan – all of which have
been the subject of significant public and consultation, and all of
which indicate that a new events centre facility should be located in
the City's downtown. By making a decision which ignores the public
promise made by this and previous versions of Greater Sudbury Council
– and without the benefit of an appropriate public consultation
process - you have betrayed the trust of Greater Sudburians, along
with the long-term development vision established for our community.
Council should reconsider the
events centre decision based on recent decisions to locate the
Synergy Centre, a library and arts gallery downtown, possibly through
a shared facility. An events centre could easily be a part of shared
community facility as well, possibly saving the City substantial
costs. At the very least, the option for sharing a single facility
ought to be evaluated prior to Council proceeding any further with
decisions related to the Kingsway site – an industrial site which
has never been evaluated for a community events centre, unlike our
City's downtown.
At this time, the site selected
by Council has never been evaluated for its appropriateness to be
home to a community facility like an events centre. The site is
designated Industrial in the City's Official Plan, and zoned M1-1 –
a zoning category that permits a range of uses, but not a community
events centre. It is not clear that a simple change to zoning – or
a minor variance that adds an event centre use to the current zoning
permissions – will conform to the City's Industrial land use
policies in the Official Plan. Indeed, as far as I can tell,
institutional uses like community facilities are not permitted in
Industrial designations. Also, establishing a new community facility
use in this location appears to fly in the face of the City's
Downtown and Regional Centre policy environment.
Further, there remain several
known constraints to development which have not be adequately
explored, including the generation of traffic from the events centre
use, and from other uses which appear to be contemplated and
contingent upon an event centre locating on the Kingsway site. It
is not known whether the existing transportation network in this
location can handle anticipated traffic volumes – or even what
those traffic volumes might be.
Also, the subject lands, while
designated Industrial, may be home to species at risk, including
blanding's turtle and whip-poor-will. At this time, to my knowledge,
the lands have not been evaluated to determine whether they contain
species at risk habitat. An evaluation that assesses the lands for
the existence of habitat must be undertaken prior to any change in
land use.
The subject lands are located in
the watershed of Ramsey Lake – a critical drinking water source for
the City that is already experiencing issues with phosphorus and salt
loading from surface run-off. The events centre use appears to
contemplate significant surface parking, and other uses which may
occur in the area similarly will likely require significant surface
parking. Surface parking in this area may exacerbate existing
problems in the watershed. As such, careful evaluation of stormwater
is necessary and should inform any decision to change land use
permissions.
The presence of a landfill site
to the east of the subject lands also represents a development
constraint that will need to be considered, going forward.
With the above in mind, I
strongly urge Council not to move forward with any changes to the
zoning of the subject lands – or other lands in this area – until
appropriate technical evaluations have been concluded that address
these known issues. Proceeding in absence of technical studies, and
based solely on Council's site selection decision, will be premature
and will put the City and we taxapayers at risk of an appeal to the
Ontario Municipal Board – an appeal that the City could very well
lose, if appropriate technical studies are not first carried out
prior to a change in use. A change in zoning must be based on sound
planning principles – and those have yet to be demonstrated for the
community facility use proposed for the subject lands.
With that in mind, I also submit
that it is premature for the City to acquire the subject lands from
the current owner. I strongly urge the City to wait until
appropriate zoning is in place before acquisition occurs. It would
be irresponsible of the City to acquire lands for a use which has not
been demonstrated to be appropriate – and which may never
ultimately be demonstrated to be appropriate for the proposed
community use, given the industrial setting.
While I am clearly not in favour
of locating our new community events centre on the Kingsway, if it
remains Council's will to proceed, at the very least the range of
uses in addition to a community events centre which have been
publicly proposed for lands on the Kingsway – namely a casino,
hotel and motorsports park, along with other possible uses such as a
waterpark and restaurants, and a community recreational use in the
form of an additional ice pad – should go through a comprehensive
land use evaluation to determine whether they are appropriate for the
subject lands, and if determined to be appropriate, to set out a
policy direction for development.
Council should use this
opportunity to direct staff to undertake a Secondary Plan for a new
Kingsway Entertainment District. A comprehensive land use exercise,
undertaken as an amendment to the City's Official Plan, that
addresses known and unknown development constraints and identifies
through policy a vision and direction for future development on the
lands, would be preferable to a piece-meal approach where every
proposed used comes forward individually with site-specific
applications for Official Plan amendments and re-zoning. The
creation of a new district within the City on a greenfield site
represents a golden opportunity for the development of a Secondary
Plan.
So as to be in keeping with our
existing Official Plan, a Kingsway Entertainment District Secondary
Plan should look at design options for proposed development that
minimize vehicular traffic and prioritize transit and alternative
transportation options. Low-impact development options should be
required, along with the use of living, green infrastructure to
manage stormwater. Carbon neutral or carbon negative buildings
should be required, so that these new facilities are doing their part
to mitigate against climate change.
Policy should be informed by a
complete cost-benefit analysis that determines the overall costs of
the project for the City, and identifies anticipated benefits. A
cost-beneft analysis should also identify the quantity of greenhouse
gas emissions that the City should expect from the new uses, and
include options for off-setting emissions. The cost-benefit analysis
should also consider whether the addition of a community recreational
ice pads on the Kingsway may lead to the closing of community
recreation centres in other locations, and what impacts those
closures might have on travel time and emissions for residents. The
cost of lost economic activity from the closure of the existing
community events facility in the downtown should also be weighed
against anticipated new economic development.
At every opportunity, evidence
and analysis should inform how a new Kingsway Event Centre is shaped
and built, through a comprehensive process that prioritizes
sustainability and minimizes costs to taxpayers.
If Council refuses to revisit its
recent decision and remains committed to the Kingsway, we have just
one chance to get things right – to create an Entertainment
District in this location that is sustainable in the long term –
economically, socially and environmentally sustainable. Based on
designs that I have seen in the public realm for a community events
facility in this location, what appears to be clear is that no one is
thinking along the lines of sustainability or comprehensive
development. If Council remains committed to the Kingsway, than
please use this opportunity to direct staff to undertake a Secondary
Planning process – so that we Greater Sudburians can have the
facilities that we'll need to position ourselves to meet the
challenges of the 21st Century.
(opinions expressed in this blog are my own and should not be interpreted as being consistent with the views and/or policies of the Green Parties of Ontario and Canada)
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