Letter to the Local Planning Appeal Tribunal
Letter to the Local Planning Appeal Tribunal
Local Planning Appeal Tribunal
655 Bay Street, Suite 1500
Toronto, Ontario,
M5G 1E5
RE: PL170714
Dear LPAT Member,
SPEAKingston is an organization comprised of a diverse group of Kingston individuals which formed several years ago to promote smart growth in our community. We have over 104 founding members and several hundred members and followers and we continue to grow. Our organization represents the values and interests of its constituency as it relates to various dimensions of public policy, hence the name SPEAK: Social. Political. Economic. Action. Kingston. Our organization objective is to promote smart growth in accordance with the following four tenets:
• Strengthen infrastructure - physical, technological and cultural
• Grow the economic base by expanding employment and housing options and competitive taxes
• Foster attractive, vibrant, walkable and safe urban core and neighborhoods
• Protect historical assets and natural environment in responsible ways
To achieve these goals, we believe that it is imperative to foster a robust downtown area, one which accommodates a variety of residents, visitors and enterprise. We recognize that the status quo has resulted in a prohibitive environment for many forms of development, creating a dearth of quality housing in the downtown area. The shortage of housing has important implications for local businesses and general health of the downtown, resulting in high commercial vacancy rates (almost 75,000 square feet in the downtown Business Improvement Area alone and a dwindling tax base. The current pandemic, with an unknown longevity has only exacerbated these factors.
Given our tenets and the current economic climate in Kingston, SPEAKingston fully supports the Homestead's proposal to develop two mixed use buildings of 19 and 23 storeys along Queen Street and Ontario Street, for reasons that shall be detailed below.
Affordable Housing Crisis
According to Recommendations to Increase Kingston's Housing Supply for All, a recent report completed by the Mayor's Task Force on Housing, Kingston has an affordable housing crisis.
The City's rental housing stock decreased steadily over five years, culminating in a vacancy rate of 0.6% in 2018, the lowest of any municipality in Ontario. Although the rate increased in 2019 to 1.9%, it is currently at a healthy rate of approximately 3% and one year of improvement after five years of decline is hardly encouraging. As is highlighted by the Mayor's Task Force on Housing Report, this is emblematic of a housing deficiency that has persisted in recent years, resulting in high inflation rates, precarious housing opportunities and subsequent difficulties attracting human capital to the City.
The Report identifies several markets and companies whose workers have been particularly impacted by a lack of affordable housing available in the City which is caused, in part, by excess demand and accompanying inflation:
• Kingston's Canadian Forces Base which is a notoriously stressful job posting for entry level workers due to the tight housing market
• St. Lawrence College which is limited in its ability to intake non-commuter students as a result of limited affordable rental opportunities
• Empire Life which has lost its competitive advantage given its inability to attract entry-level workers
• Queen's School of Graduate Studies which has lost prospective Ph. D students to alternate institutions due to the high cost of family housing in Kingston
Impact on Key Employers
The impact on these entities is particularly problematic as the Rental Market Housing Analysis Report on which the aforementioned Housing Report is based states that a third of economic growth between 2016-2046 is estimated to accrue from "the City's major institutional employers including Queen's University, St. Lawrence College, Corrections Canada, Canadian Forces Base Kingston and Royal Military College of Canada."
The fact is that dysfunction in the housing market permeates the wider economy, threatening the City's prosperity for the foreseeable future should major industries lose their competitive advantage. The housing forecasts presented by the Mayor's Task Force indicate that a high volume of new housing is needed to accommodate future growth, at least 5,700 purpose-built units that need to be constructed between 2020 and 2046.
Need to Support for Local Businesses- Rising Commercial Vacancies
In addition to stunting the labour market, the City's housing crisis has had adverse impacts on the commercial sector, resulting in a lack of exposure for downtown businesses which are already struggling to compete with online shopping. As of February 2021, 74,188 square feet of vacant ground floor commercial space was identified in the downtown area alone as indicated by the inventory included in Appendix A.
Although it is acknowledged that the pandemic is responsible for some of the City's vacant commercial space, the diminishing demand for retail space in the City is an undeniable phenomenon that is rooted in changing consumer preferences. Online shopping platforms and large power centres are often favored by consumers for their convenience, resulting in a decrease in demand for small and moderately-sized businesses in the City's downtown core. The Report provided by the Mayor's Task force on Housing acknowledges this, highlighting the growing trend in Canada to infill underutilized retail spaces with residential development.
The development proposed by Homestead seeks to provide additional residential units within the City's Central Business District, offering businesses future exposure and supporting the recruitment of workers to the City's downtown offices. The proposal also includes a municipal art gallery, an attraction that will likely attract consumers to the downtown area and result in additional revenue for local businesses. The proposal also conforms to the following policies provided by the Official Plan in regard to the establishment of mixed-use communities and cultivation of a strong tourism sector:
• Section 1.4, which defines transit-supportive development as that which is compact, contains a mix of uses and exhibits a high density of residential and employment land uses
• Section 2.3.9 which states that spaces, facilities and services used to sustain and generate cultural vitality will be supported
SPEAKingston supports the approval of the Homestead Proposal and the approximately 380 residential units proposed by Homestead should be approved. This project alone would account for over 6% of the units for which demand is anticipated by the year 2046 with the Mayor's Task Force Report. We ask, if not here, then where? The subject sites are located within the Central Business District, an area for which intensification is explicitly prescribed by the Official Plan in accordance with the following policies:
• 2.2.7 which states that intensification in the form of high-density residential development shall be considered in the City's Centre and also identifies the Centre as the commercial nexus of the City
• 3.3.C.3 which outlines those locational criteria by which the appropriateness of a site for high density residential is to be evaluated, all of which are objectively satisfied by the proposal:
o The property is located within a Centre or Corridor;
o The property is within walking distance of commercial land uses;
o The property is within walking distance of parkland, open space facilities or community facilities; and
o The property located on an existing arterial road
• 3.4.1 which states that within Centres, the commercial land use designation is intended to foster residential intensification;
• 8.1 which speaks to the importance of quality architecture, pedestrian-friendly streetscapes, and vibrant neighbourhoods in the context of implementing urban design goals that contribute to sense of place and community significance.
Sustainability
The definition of sustainability reflects the interdependence of economic, environmental and social outcomes. The state of Kingston's downtown core exemplifies this principle, the area suffering from an affordable housing crisis, an economic downturn, amplified by suburban sprawl which decreases the effectiveness of the transit system. The proposed redevelopment would contribute substantially to the housing supply in the downtown, thereby improving upon the area's economic, environmental and social health.
The Report issued by the Mayor's Task force on Housing speaks to the impact that housing has on the City's economy, impacting the availability of human capital and undermining opportunities for innovation and learning that are often subject to economies of scale. Additionally, the Report illustrates the social dimension of the City's housing shortage, highlighting the fact that owners benefit from the constrained supply of housing, demanding higher rents and pressuring tenants to vacate units that are subject to rent control. As a result, residents are incentivized to live outside of the downtown area, undermining opportunities for resource sharing and reducing the efficiency of public services.
It should also be noted that capacity exists to accommodate residential intensification in the downtown area given recent large-scale capital works projects initiated by the City in the downtown area. These projects, collectively termed the Big Dig, include improvements to City infrastructure such as streets and public building. Additionally, investments have been made to support increased servicing levels and additional programming amongst institutions such as libraries, churches and hospitals in the downtown area.
The proposal put forth by Homestead constitutes a sustainable form of development, conforming to the following policies which address sustainability in the Official Plan:
• 2.1.1 which states that new development will be directed to areas where it can best result in sustainable practices
• 2.1.4 which states that new development shall be efficient and satisfy the socio-economic needs of the community
• 2.3 states that the City will support compatible forms of intensification in order to minimize land consumption, optimize infrastructure and reduce air pollution
Increased Tax Revenue
The Homestead Proposal will generate significant tax revenue for the City, contributing to the stable source of income for the City. Given that commercial enterprises tend to weather taxation more poorly, the City has become over-reliant on the residential sector to generate revenue, having imposed an average increase in the taxation rate of 1.9% in the midst of a pandemic; thus, the high housing prices discussed above are compounded by a high taxation rate which inevitably trickles down to the rental market and perpetuates the housing crisis.
The Homestead Proposal for two high-rise towers will contribute to the City's tax base without incurring any substantial increase to the City's spending (i.e. it can be supported with current infrastructure), enhancing the public realm and improving the overall affordability of the downtown area. The proposal is also consistent with those policies from the Official Plan which provide direction for the provision of public services and cost-efficacy of new development:
• 2.1.1 which promotes the maximized use of investments in infrastructure and public amenities
• 2.4.1 which states that the City supports compact development that is capable of reducing infrastructure costs
• 2.5.11 which states that "more intense" mixed-use Centres are required to support the use of public transit
• 6.2.13 which promotes increased density in buildings as a means to support transit
• 1O.A.3.4 which promotes a concentration of development in proximity to transit stops in order to improve the accessibility of the transportation system for all citizens
Built Form
Opponents to Homestead's proposal have contested the project on the basis of its perceived lack of compatibility with its surrounding context. SPEAK does not agree with this assertion and finds the proposal to complement the surrounding neighborhood. The proposal seeks to develop two residential towers along Queen Street with Blocks 3 and 5 of Kingston's North Block Area. The towers, though large in scale, incorporate mitigating elements of their design wherever possible. Both towers have been designed to mimic the setbacks of surrounding buildings, resulting in an architectural rhythm which is lacking given that both sites are currently vacant. Both of the buildings at Block 3 and Block 5 include commercial space at the ground floor, leveraging underutilized land to round out commercial uses along Queen Street and encourage pedestrian circulation throughout the downtown area. In addition, both buildings include a substantial amount of programmable amenity space at the ground floor, providing flexible, active spaces which encourage communal usage thereby enhancing the pedestrian realm. Both of the buildings would be surrounded by an extensive landscaped area that would encourage pedestrian movement. Given that several of the development's abutting sidewalks along Ontario and Queen Street are less than 2.0 min width, the proposal stands to improve overall walkability and pedestrian safety in the neighborhood.
The proposed development would also have a negligible impact on the character of the surrounding area given its location on Queen Street, a transportation corridor that has long supported a high intensity of uses. The development also includes significant variation in its massing, thereby providing an alternative to the monolithic buildings that are often equated with high-rise residential development. In doing so, the development seeks to maintain the prominence of those heritage buildings in the downtown area whose magnitude defines the neighborhood. It should also be noted that the proposal will not result in shadowing along Princess Street, as demonstrated by the Shadowing Study, apart from during select dates during which time shadowing will be brief and mild.
Summary
In summary, we feel that Homestead's proposal will contribute to the vibrancy, sustainability and financial health of the downtown area and wider City. We believe that the additional 380 units proposed by Homestead will contribute to the affordability of the downtown area, resulting in increased inclusiveness and sustainability.
We thank you for your time and consideration. Sincerely,
Brian Cookman
Chair, SPEAKingston
www.SPEAKingston.ca