An Open Letter to Greater Sudbury Council Regarding the Draft Integrated Site Plan for the Kingsway Entertainment District

The following is an open letter to Council and select municipal staff with regards to the Integrated Site Plan for some proposed elements of the so-called “Kingsway Entertainment District”. It is intended to be my submission as part of the public consultation process. As I have been unable to submit this text via the online survey, I have instead emailed it direction to all members of Greater Sudbury Council and select staff involved with the Integrated Site Plan.
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Thank you for providing an opportunity to the public to provide Council with feedback with regards to the Integrated Site Plan presented to Council by staff and consultants on Wednesday, November 1, 2017, for lands which are now being called the 'Kingsway Entertainment District'. I have been following this matter quite closely, and I understand that it was Council's direction to receive a report in the form of an integrated site plan for the following elements: a) a community events centre; a casino; a hotel.

While I continue to maintain that there are no existing land use permissions for the establishment of either a casino or community events centre, and that the Integrated Site Plan is therefore a premature exercise (and a costly one for Greater Sudbury taxpayers), I will nevertheless focus the majority of my comments in this letter to you on elements of the Integrated Site Plan. For a much more fulsome analysis of the Integrated Site Plan and land use permissions for the 'Kingsway Entertainment District', you may wish to read more of my thoughts at the following link: “The Kingsway Entertainment District - How Council's Vision Fails Greater Sudburians," Sudbury Steve May, November 6, 2017.

Council may also wish to note that I have provided previous correspondence on the elements that I would like to see incorporated into the Kingsway Entertainment District (see: “An Open Letter to Greater Sudbury Council Regarding a Kingsway Entertainment District," Sudbury Steve May, July 11, 2017). I also participated in one of the earlier public open houses held at the Radisson, and shared my thoughts through that process with staff and the City's consultants. It is fair to say that I am quite saddened to see that very few of the elements that I have highlighted to the City on several occasions have been incorporated into the Integrated Site Plan.

High Quality Urban Design

Section 14 of the City of Greater Sudbury's Official Plan identifies urban design policies that the City will use, where it is able, for all new development within the municipality. In part, policies here advise,

“Urban design policies contained in this plan will apply to the City's public and private developments. Although there are limited planning tools available to Council to influence the design of private development, good design principles must be encouraged in order to improve the aesthetic qualities of our urban spaces.”

What this policy suggests to me is that the City will strive for high-quality urban design at all times – but that it recognizes high-quality design will be difficult to achieve where the developer is a private enterprise. And that also suggests that there is no good reason why a public facility shouldn't strive to have high-quality design elements – especially when that facility is intended to be a marquee facility that helps promote the City's image.

I have reviewed the Integrated Site Plan proposal, and it is not clear to me that the Site Plan is in keeping with the desire expressed in the Official Plan to promote good design principles with the goal of creating high-quality public spaces. There is little in the Integrated Site Plan that could be considered innovative, save perhaps the presence of a “Festival Square” and maybe a pedestrian skywalk linking the events centre to the casino/hotel complex. Given that the City proposes to spend between $80 and $100 million of scarce revenue on a public facility which may need to service the needs of residents for more than 30 years, I was extremely surprised to discover the lack of design ambition for this facility. I note that the Kingsway Entertainment District is presently a blank slate, and at least a part of these lands are intended to be developed by the City as a public facility. As such, there is no good reason here that the City should be striving for mediocrity in terms of design. For the outlay of public funding that taxpayers are being asked to make for this events centre to become a reality, we deserve more.

I further submit that locating a community events centre and other facilities in the midst of a sea of paved parking lots leaves a lot to be desired from an aesthetic standpoint. While I understand that the provision of ample parking at this location was one of the reasons cited by some members of Council as part of their rationale to support a new community facility on the urban fringe, I can't help but question why the Integrated Site Plan places the events centre and casino/hotel complex right in the middle of parking lots. Good urban design techniques would suggest trying to 'hide' parking at the rear of facilities, and creating a strong edge along traveled roads like the Kingsway with the close presence of the facilities themselves.

Energy Efficiency and Climate Change

One of the objectives of the Urban Design section of the Official Plan is to “promote a built environment that is safe, energy efficient, aesthetically pleasing and productive.” (from Official Plan Section 14.1, Urban Design Objectives). I point this objective out because one of my earlier comments pertained to designing the events centre in such a way as to be energy-neutral – to incorporate energy conservation measures along with energy production facilities, such as (maybe) solar panels or wind turbines. A district heating and cooling system (like the one that is in operation in the Downtown) would also go along way to help achieving #NetZero energy neutrality (or better). While there may be additional upfront costs to create facilities to achieve #NetZero objectives might, long-term savings should more than compensate. At the very least, Council should request a technical study which assesses the costs and benefits of achieving a #NetZero energy standard. That kind of design element would also go far with regards to helping the City achieve climate change objectives – something that siting a community events centre on the fringe of the City, making it primarily accessible only by personal automobile use – has already been exacerbated by Council's decision, in my opinion.

Designing for Winter Cities

Official Plan section 14.2 states:

“Council will encourage urban design solutions that enhance winter livability. Such methods may include: Fostering building design and orientation to take advantage of climactic conditions and utilizing passive solar heating and cooling techniques; Investigating the feasibility of covered sidewalks at key locations; Encouraging landscaping treatments which enhance winter microclimate conditions and which minimize wind chill level.”

Without question, Greater Sudbury is a Winter City – so it's no surprise to me to see urban design policies in our Official Plan that speak to how best to locate new buildings and other infrastructure in a way that is mindful of the effects of winter. Some Winter Cities, like the Cityof Edmonton, have developed entire plans to help guide developments and get people thinking about how to get the most out of our urban environment in the winter time.

While I heard from staff and consultants during the November 1^st presentation to Council that they themselves heard from members of the public that facilities should be designed for four-season use, there is little to no consideration for the impacts of winter in the Integrated Site Plan design. The outdoor elements of the Integrated Site Plan, especially the Festival Square, are to be located in extremely problematic areas with regards to winter weather.

With specific regards to the centrepiece Festival Square that will have large openings facing the northwest and the southeast, with multi-level buildings on either side (the community events centre to the northeast and the casino/hotel complex to the southwest), the layout here appears to create the perfect channel for winds to roar out of the northwest and right through your public open space.

Further, putting the taller of the two buildings (the casino/hotel complex) on the south side of the Square is also problematic. During winter afternoons when the Square could be used most often by the public, the casino will be casting a significant shadow on the Square.

To maximize exposure to sunlight, Winter Design Guidelines the world over suggest a southern orientation for open spaces like the proposed Festival Square – and yet the Integrated Site Plan for these elements of the Kingsway Entertainment District depicts one that faces northwest. There is some southern exposure, but the presence of an upper-level pedestrian walkway pretty much means that the focal point of the Square will be its northwestern opening – and that's where most of the people will be accessing the square from, given the presence of the Loop Access Road for buses and the many parking lots to the northwest. This orientation for open spaces uses appears to be at odds with designing for winter activities, as per the City's Official Plan. Frankly, I'm extremely surprised that this orientation was proposed at all – especially given the significant public feedback cited by staff and the City's consultant during the November 1^st presentation to Council related to a desire for all-season use.

A Better Design

Rather than having the parking lots as the central feature that facility users will see from just about everywhere when on the site, the casino and events centre should be oriented towards the Kingsway, so that they are largely fronting on one of the City's major thoroughfares. By orienting the buildings so that they both face the Kingsway, and are physically closer to it, the parking lots can be located behind the buildings and accessed via the interior of the site.

By having the entrances to the buildings face the Kingsway, the Festival Square could be located between the two buildings, with a south-facing exterior (one the faces the Kingsway). The Square in this location could be more easily accessed by foot traffic from sidewalks on the Kingsway and potentially from new cycling infrastructure along the Kingsway. Buses wouldn't have to go into the site via side streets and an Access Loop – there could be special bus lanes and bays right off the Kingsway to facilitate transit. Indeed, priority high occupancy vehicle lanes could be located along the Kingsway between at least Barrydowne Road and Levesque Street in order to better facilitate the use of transit to the site – which would greatly assist with another, somewhat surprising, issue.

Given that ample parking was identified as one of the reasons for selecting this site in the first place, from the presentation to Council on November 1^st, it appears that only a minimal number of surface parking spots are intended to be provided – less than are presently available in the City's downtown. With this in mind, the City should do all that it can to encourage alternative transportation options to the Kingsway Entertainment District, including prioritizing transit use and creating safe, separated all-season cycling infrastructure. Further, to encourage car-pooling to free up scarce parking spots, the City should establish a tariff for parking, based on the expected use of the event centre. A parking tariff – to help recover some of the costs for setting aside what amounts to a vast area of publicly-maintained parking – only makes sense. While I understand that this is not a site plan issue, I believe that the City should nevertheless consider a tariff, and being upfront with residents about having to charge for parking.

Additional Elements

I was surprised to discover that staff and consultant's recommended additional elements for Council's consideration as part of the Integrated Site Plan process. Specifically, an additional ice pad has been identified. An additional ice-pad is clearly beyond the scope of Council's direction for the Kingsway Entertainment District. The addition of another ice pad in this location should only be undertaken further to a cost-benefit analysis and a determination of how the City will pay for operating this new facility – and whether that might mean closing existing ice pads, such as the Carmichael Arena.

Going Forward

With the above comments in mind, it is certainly my hope that Council will send staff and its consultants back to the drawing board with regards to the Integrated Site Plan. Clearly, the plan lacks vision, will not implement high-quality urban design, is not in keeping with our Official Plan, and will prove problematic for facility users – especially during the winter. There is no good reason to rush this project. Please, let's take the time to get things right with regards to design. Should land use approvals ultimately determine the suitability of this site for the uses proposed, Council needs to bear in mind that this public facility will likely serve several generations of Greater Sudburians. We owe it to future residents to ensure that we are getting the design right.

And with that in mind, I would be remiss if I did not provide some comments with regards to the public consultation process that has been rolled out for the Integrated Site Plan post-November 1^st. Frankly, the narrow time-frame for public comment – less than one week – is an insult to Greater Sudbury residents. Council should not have agreed to this tight timeframe – nor to the opportunity to provide comments through an online survey that asks only a single question about whether one is 'excited about the future'. Truly, what's happening here makes a mockery of engaging the public. Greater Sudbury Council should be ashamed that it has insulted its citizens in this manner.

However, it speaks volumes that so many committed Greater Sudburians are providing feedback, despite what appears to be the City's desire to charge forward. Many of us recognize just how important a new community events centre is to our City and future residents, and have dropped everything in order to engage with the City on the Integrated Site Plan proposal. The respectful thing for Council to do now, in my opinion, would be to require staff to undertake a legitimate public engagement exercise with citizens with the aim of improving the Integrated Site Plan so that it is better able to meet everyone's needs, going forward. That real public engagement can lead to public buy-in for a project should not be under-estimated. But when you shut the public out of participating in decision-making that will impact us for decades, you should expect the sort of hostile feedback that I have no doubt this mockery of a public process has generated.

Again, I think you for your time – and for the opportunity to provide 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)