Tuesday, August 15, 2017

Open Letter to Greater Sudbury Council re: Kingsway Entertainment District Site and Building Design and the Need for Public Engagement

The following is an open letter to Greater Sudbury Council re: the Report to Council dated August 9, 2017, from CAO Ed Archer regarding Site and Building Design for the Kingsway Entertainment District.


I am writing today with regards to a Report to Council, dated August 9, 2017, prepared by CAO Ed Archer, with regards to the Kingsway Entertainment District and the community events centre development initiative (see: http://agendasonline.greatersudbury.ca/?pg=agenda&action=navigator&lang=en&id=1132&itemid=13757).  The Report proposes that Council endorse a number of actions as part of a way towards developing lands on the Kingsway for a community events centre and a casino, including confirming a single-source contract for Cumulus Architects, described as the architect for Gateway Casinos.  The Report also recommends that Council proceed with site and building design in conjunction with obtaining land use approvals.

I strongly urge Council to hold off on issuing a single-source contract to Cumulus Architects, and to not proceed with site and building design until appropriate land use approvals for a community events centre and casino are in place.  Similarly, I also strongly suggest that Council not finalize any property purchase until appropriate land use approvals are obtained.

At this time, the subject lands are not zoned to permit a community events centre or casino.  While I understand that the Report is recommending that Council add a 'community arena' use to the zoning for lands intended to be used for a community events centre, it is not clear that this approach is in keeping with the City's Official Plan, as community facilities of this nature appear to only be permitted in Regional Centres and the Downtown (the proposed use does not appear to be contemplated for lands designated Industrial by the Official Plan).  Further, the City has already expressed a position that a land use permission for a casino in the Kingsway location will require an amendment to the Official Plan.

Site and building design are likely to be constrained by specific land use issues unique to the site.  For example, we know that there are development constraints already on the site in the form of necessary setbacks from the existing landfill area.  An analysis of site topography may also identify restrictions for development.  On an earlier (2014) application to rezone part of this property, the City of Greater Sudbury identified two other significant issues which appear to require further study, namely: the potential presence of species at risk habitat on the subject lands (blanding's turtle and whippoorwill); and issues related to traffic.  Issues related to road salt and the contamination of surface water from runoff into the Ramsey Lake Watershed - a significant source of our City's drinking water - may also lead to further development constraints.

Proceeding towards site design at this time, without first knowing whether the proposed uses are appropriate for the lands, or what development constraints may be imposed through further technical studies related to natural heritage, community safety and traffic, is akin to putting the cart before the horse.  It may also lead to the costly duplication of designs and cause the City to spend more taxpayers money to resolve issues after the fact.

The single-source contract to Cumulus is suggested by the Report due to what are perceived to be time constraints with site and building design.  The Report does not appear to take into consideration the need for public consultation and engagement.  The Kingsway Entertainment District, anchored by a new community events facility and a casino, represents a once-in-a-generation opportunity for the City.   The development of this site should not be rushed.  Development, including site and building design, should benefit from significant public engagement.  For example, we have a chance to here to create true carbon-neutral facilities, which will assist the City in meeting its greenhouse gas reduction commitments.  We have the opportunity to influence the flow of traffic along the Kingsway through the creation of high occupancy vehicle lanes.  And we have the opportunity to design the site in such a way that it is truly integrated into the physical and natural environment, including the use of bioswales and permeable hard surfaces to address stormwater runoff issues.  There are likely many other design elements that the public would like to see addressed through a comprehensive design process that truly engages the public.

The legitimacy of the entire project may be at risk if Council does not receive the public's buy-in through significant engagement. After all, it's our tax dollars that are going to be paying for this project.  Any site and building design process that does not commit to fully engaging the public will be problematic for the City to obtain the social license it needs to move this development initiative forward.

With this in mind, I strongly urge Council to reject the Report submitted, and to not pass the recommended resolutions.  Instead, I urge Council to direct staff to undertake a Secondary Plan for the entirety of the Kingsway Entertainment District, so that all land use issues, including the appropriateness of the site for the development proposed, along with planning constraints, may be addressed in a truly comprehensive manner that engages the public.  I have written to Council about the need to for a comprehensive process for this new District in the past (see: "An Open Letter to Greater Sudbury Council Regarding a Kingsway Entertainment District," July 11, 2017).  I again implore Council to consider a Secondary Plan as the only legitimate way forward for the Kingsway proposal.

At the very least, please hold off on site and building design until land use permissions are obtained.  And please ensure that significant public engagement is built into any site and building design process.

Thank you for considering these comments.

(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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