Tuesday, July 11, 2017

An Open Letter to Greater Sudbury Council Regarding a Kingsway Entertainment District

The following is an Open Letter to Greater Sudbury Council Regarding a Kingsway Entertainment District.


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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