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Letter to Mayor and Council re Extension, March 2015

Dear Mayor and Council,
Please consider deferring (or even rejecting) acceptance of CAO Hunt’s Wellington St. Extension Report #15-208 for two major reasons:
1) The recommendation to conduct a new EA is both premature and not consonant with the spirit of Council’s previous motion.  In the previous March 3 motion, Council advised staff to prepare a report describing the scope of work to explore alternative solutions for the Inner Harbour IN PLACE OF the Extension.  The spirit of the March 3 motion is to demonstrate an alternative vision for the Inner Harbour that is pro development but also in keeping with the city’s stated values re sustainability and the importance of maximizing green space and that is more in line with current global trends.  Surely that report should precede a very expensive EA on the current proposed alignment that may, in fact, not be needed.
2) The report contains a number of omissions, questionable assumptions, incorrect facts, biased and misleading statements and Exhibits that should be corrected before the report is accepted.  In addition, the report is narrow and outdated in focus.  Below is a very quick one day summary of some of the more serious problems.

Pages 263 and 264 (Pages 2 and 3 of 37)
1) “Smart Growth through intensification remains a cornerstone goal” Yes, Smart Growth is key.  However, the WSE is not necessarily needed to achieve this in the Inner Harbour.  Other new roads created in consonance with the existing grid system might well accomplish the same thing more cheaply.  We await the May report.

2) “The K&P Trail completion to Anglin Bay is dependent on the WSE”.  False Statement: Several possibilities actually exist for completing the K&P.  The simplest would be to simply use existing roads.  The most beautiful solution would be to use the route behind the CAS and Police stations on Division St. that requires minimal discussion re easement or land acquisition.  A third possibility would  be a combination of existing roads and the Hagermann section.  A fourth would be the WSE alignment.

3)  “The Douglas Fluhrer Park Master Plan. ..demonstrated that the park use… and the Wellington Street Extension can co-exist to meet the various needs to the community at large”. Misrepresentation.
a) Although it is true that there was public consultation in the visioning exercise, there is no public record of the huge opposition to the WSE that occurred at every single meeting.  The outcry was huge.  It is unethical practise that no public record of this enormous opposition exists.
b) What people said they valued most about the park was the peace and quiet, the refuge from busy traffic and the growing abundance of wildlife.  The WSE totally flies in the face of these stated most important values.  In addition, the threatened Northern Map Turtle would not survive the extension when it crosses the road to lay eggs along the retaining wall.

4) Misleading assumptions/ suggestions and/or inaccurate statements re potential impacts:

a) First bullet:  “Requirement to undertake a new EA to identify an alternative north-south transportation corridor..”  A single north-south corridor may not be needed if the old grid system can be revitalized and added to and alternative possibilities such as one-ways, traffic circles examined more thoroughly.  In addition, traffic requirements needed by the new urban demographic may be reduced given a serious effort to improve transit, number of park and rides, smart apps etc.  Again, awaiting the May report.

b) Fourth bullet:  “Reduce the City’s ability to effectively revitalize the Inner Harbour area”.
Not necessarily true if alternative solutions are found.  Again, we await the May report.

c) Fifth bullet: “Increase the risk of not achieving the housing and density targets.”  This may be partially true although population projections are notoriously faulty.  One cannot accurately predict.  Note the 2001-2026 population projection that was dramatically wrong in the Williamsville area. Such unreliable futuristic projections should not be a keystone for expensive decisions such as road construction.  Waiting until the need is demonstrated as with the widening of John Counter Blvd. is a wiser and more prudent use of tax dollars. 

d) Sixth bullet: “Threaten the completion of the K&P to Anglin Bay.”  False – see #2) above.

e) Seventh bullet: “Delay the implementation of the Douglas R. Fluhrer Park Master Plan..”  Actually, given the huge public discontent with the visioning exercise that was done without allowing full discussion of the WSE impact, and problems with the design that many consider over –cutsey and utterly destructive of what people value most – the peace and quiet and wildlife, many residents would be happy with a delay.  This represents either an inadequate reading of public sentiment or a refusal to abide by the wishes of the public.

f) Eighth bullet:  “Impact acquisition of properties completed by the city…”  It is a little difficult to see how the properties already acquired would suffer an impact concerning their acquisition.  Inaccuracy.

g) Ninth bullet:  “Costs to amend the Development Charges By-Law…”  Surely costs re amending a by-law can’t be excessive.  It would be other costs of fixing up the existing infrastructure and creating some new access roads to complement the existing grid system that would require funds.  But some of these new subsidiary roads would also be necessary – even with the extension.  Possible inaccuracy here.

Page 266 (Page 5 of 37)
5) “an Environmental Assessment update, as recommended in the Transportation Master Plan Update (2015).. include specific requirements as detailed in Council motion dated March 3, 2015..”
As stated earlier, it would be better to complete the May report first – less expensive and a more rational approach – rather than trying to include all the elements of the May report in an overall very expensive EA. 

6) I am addressing the Transportation Master Plan Process only briefly here to complain that the public process appeared shamefully lacking on openness and transparency to the point of being unethical.  The survey was extremely limited and there was no room for comments of any kind.  The public meeting consisted of billboards with pictures and when I asked who to speak with re concerns about the WSE, I was told this was not the place.   Instead I was invited to write a comment on an index card.  Many members of the Friends of Kingston Inner Harbour left in utter disgust.  No public record of any opinions is available as far as I know.  I have requested such information from both the mayor and CAO to no avail.  Outrage has also been expressed by members of KCAT.  Their official letter that was part of the update process seems not to be available publicly and members have commented on the unintelligibility of some of the billboards at the public meeting.  In short, public outreach was woefully inadequate.  Public meetings should include both public presentations as well as opportunities for community members to voice their concerns and their names and addresses should be written down and included as part of an accessible public record.  Otherwise the process resembles a sham.
When I asked the consultant why there was no opportunity for public comment, she said that staff had said they were afraid things “would get out of hand!”  If such barriers to opportunity for public discourse are routine, how can staff realistically state that there was opportunity for public input?
As the recommendation for a new EA is proceeding from the Transportation Master Plan to the Official Plan, and as it did not include adequate public outreach, and as it is not appropriate to do a new EA before the May report, the recommendations suggested in this report should not be accepted at this time.

7) The recommendation “That staff prepare a list of projects that will be impacted…”, suggests negative impacts.  Positive impacts to be derived from an alternative vision of the whole area that maximizes green space and increases quality of life while also encouraging development should also be a part of this accounting.

8) An accounting of how both the WSE as currently designed and an alternative vision without the WSE are (or are not) in keeping with current global trends re waterfront development, smart growth, quality of life and public health should also be part of the May report.  Kingston’s vision of the city should not be at odds with global trends re quality of life and re attracting young professionals and entrepreneurs who increasingly choose job location based on quality of life issues, and for whom using the WSE alignment to create an expanded trail system could be a real draw.  In addition, research consistently shows that 80% of tax payers would agree to taxes being raised for parks and increased green space.  There is huge bang for the buck and consequent voter support here.

Page 267 (6 of 37)
9) “Public Policy has identified a new north-south arterial road as necessary to significantly improve pedestrian…access to the downtown core.”  Actually this can be accomplished in many other ways -such as sidewalks on existing roads.

10) “Transportation corridors require significant long term planning and multi-year implementation to protect future uses and once gone would be…extremely difficult to replace.”  Waterfront green space is even more of an issue than transportation corridors here. Once waterfront greenspace is lost, it is  definitely extremely difficult to replace.  Why was this not mentioned?  A serious omission.

Page 268 (7 of 37)
11) The issue of revised cost estimates.  Up until mid-January of this year the cost of the proposed extension was conservatively estimated at $35 million.  Suddenly the cost estimates have been revised down.  When I first saw this reduction, I contacted Mark van Buren, expressing interest in the rationale for this downward revision – given that I have an interest in Brownfields and helped organize a community forum on Brownfields for KEAF a few years back.  He replied that there would be an accounting in the March 24 report.  It is not here – still only vague statements as to “new/advanced technologies that would aim to minimize the potential costs associated with any contaminated soil/ground water in the corridor”.  Not even a statement that the new technologies would actually minimize the potential costs.  This is simply not good enough when the cost reduction is 7 million dollars.
Tax payers need a better explanation!

12) Planning Implications.  Problem with selecting only relevant sections of the Provincial Policy Statement.  This is not good enough!  The Provincial Policy Statement 2014 also stresses the importance of waterfront and green space as part of the “interconnected master planning documents for community development purposes”.  Why were these elements of the PPS not included?  And once again, the rationale used is population, housing and employment projections which may well be faulty as demonstrated in the 2001- 2016 projection concerning future development in Williamsville.

13) Once again this report lists emphatically all of the various reports that have been done to add weight to the suggestion that the extension has been really well thought out and is inevitable.  The problem becomes serious when year after year these reports are cross-referenced until people are simply caught up in the inevitability of the process.  It need not be so.  Change is real.  Global changes are real.  We must not be locked into what seemed appropriate 40 or 50 years ago.  We have to change along with global shifts in economic and lifestyle priorities.  Admittedly change is difficult.

14) I would dispute that the Waterfront Working Group would consider recognizing that “The Wellington Street Extension and corridor are important to the development and redevelopment of the Inner Harbour and the Old Industrial Area.  I am a member of this group and this concept has never been discussed to my knowledge.

Page 269 (8 of 37)
15) Section 1.1 of the Provincial Policy 2014 Statement includes `providing an appropriate range and mix of housing forms to meet the needs of the community.”
This can also be done without the Extension.

16) ”The Wellington St. Extension provides for both vehicular and bus movement but also shows as a pedestrian and cycling route out of downtown.”  This can be done easily without the Extension.
And the Extension would be created at what cost?  Loss of incredible green space including off-road cycling and walking possibilities that could encourage the 35% of the population that are reluctant cyclists as well as a huge untapped cycle tourism demographic.

17) “The EA addressed the location of the proposed Extension in relation to the waterfront and why a setback less than 30 metres is appropriate, without concern related to adverse impact. The Wellington Street Extension is shown as a main corridor out of the downtown, which the OP identifies in need of protection”   Is this truly the “efficient use of existing and planned infrastructure” for a waterfront Ribbon of Life?  There are lots of other main corridors out of the downtown that are existing infrastructure and with reformulating the old grid system, there could be many alternatives.  To use waterfront green space for this purpose is actually an outrage.

Page 270 (9 of 37)
18) “Any proposed amendment to the City’s Official Plan… concerning the Wellington Street Extension would need to be consistent with the policy direction of the 2014 Provincial Policy Statement.”
Absolutely – protection of waterfront and green space!

Page 271 (10 or 37)
19) “The Official Plan also recognizes that the City of Kingston is subject to economic, social and environmental forces that may change over time and have competing or opposing demands.”  Exactly!

Page 272 ( 11 of 37)
20) “The Planning Act …includes giving proper notice of the proposed amendment and solicitation of public feedback.”  Due process is always advised.  And “land use planning rationale” is good provided it is in line with all aspects of the new Provincial Policy Statement of 2014.

Page 273 (12 of 37)
21) “Without an efficient transportation corridor many of the (Inner Harbour) developments will need to add expensive local road improvements without the Wellington St. Extension.  Actually, as noted earlier, local road improvements will have to be created with or without the Extension.

Page 274 (13 of 37)
22) “The Kingston Transportation Master Plan established a “New Direction” that emphasized non-automobile modes (walking, cycling, and public transit) as the preferred methods of transportation and also recommended further improvements in Transportation Systems Management to increase demand management strategies to reduce travel demand during peak travel periods.” However more serious attempts in this direction are clearly warranted.  No mention of Park and Rides, Smart App Car Sharing, Transit in Countryside, promoting more than one person per car, reducing transit rates for special groups etc.  The nod in this direction seems to have been pretty cursory.

23) “A level of service ‘E’ allows for an acceptance of some increased congestion and delay for vehicles during the peak travel period.” Well done! As we all know, traffic congestion in Kingston is honestly not a problem compared with other jurisdictions like Toronto.  However, there remains a need to reduce the number of people in single occupancy vehicles coming to Kingston for work and getting away with very minimal parking fees or filling metres because it is so cheap.  Look at other jurisdictions.  There is a need to increase City’s parking revenue and decrease the number of cars parked in the downtown.

Page 275 (14 of 37)
24)  “enhance road network connectivity in conjunction with future plans for the widening of John Counter Blvd and the construction of the Third Crossing bridge across the Cataraqui River.”
No mention of the AECOM TransCad Model Update Report that examines 9 scenarios of roads connecting the whole city to a Third Crossing and concludes that the top three do not need the Wellington Street Extension. Serious omission here.

Page 276 (15 of 37)
25) “Transportation Systems Management (TSM)… not examined in detail.”  As part of the May report, these alternatives should actually be examined in detail along with a more complete examination of AT options and alternative uses of the existing grid system.

Page 278 (17 of 37)
26) “If a road is to be removed from this list, then an update to the Development Charges and Impost Fees Background Study and Bylaws would be required to reallocate the funds, which would make the change subject to OMB appeal.´ Interesting.  But deals can always be made to create alternate routes within the existing grid system (plus added connectors) to satisfy the needs of these developers out of court.

Page 279 (18 of 37)
27) Here is a cursory accounting of what might be done by way of Brownfield clean-up to reduce cost although it is hard to see how a savings of 7 million would be possible. Omission!
Further fleshing out of these details is definitely needed.

Page 280 (19 or 37)
28) “The northern part of the Old Industrial Area is an integral part of the proposed long term supply and strategy for Employment Lands.  The northern part of the Wellington Street Extension is required to permit access to and to service some of the lands in the Old Industrial Area and also to improve the development potential of the broader area.’  Actually in keeping with current planning theory old grid systems should be retained, improved and beautified and industry will percolate. Yes, alternative subsidiary roads would be needed to accompany the existing grid but most probably at much less expense than creating a mega four-lane road.  In addition the integrity of the mixed residential and industrial neighbourhood could be retained more easily than with a destructive road ripping through an existing community.

29) “The K&P Trail alignment from John Counter Boulevard to Anglin Bay is tied directly to the design and proposed route of the future Wellington Street Extension”. This is one possible alignment only! There are other, better alignments,  that do not require the extension.  See previous False Statement note #2.

Page 281 (20 of 37)
30) “Off road and isolated urban trails in industrial lands can be successfully implemented with an expectation of safe and respectful use when they are constructed in an appropriate and active urban environment.  The conditions in the area currently include a number of vacant and underutilized industrial properties, and, as such, the trail section would not be expected to achieve the same type of success as it would if the area was otherwise revitalized.”  In other words, the beautiful trail section behind the Division St. CAS and Police Station is considered unsafe despite the fact that both CAS and the Police Station are open 24 hours with “eyes on the street” at all hours of the day and night.  Let us remember that many jurisdictions all over North America are creating “isolated” trails along old rail lines and it is considered a best practice.  To reject this possibility in Kingston out of fear is wrong-headed.

Page 282 (21 of 37)
31) Douglas R. Fluhrer Park Master Plan.  This process was flawed from the start because participants’ grave concerns about the extension and how it would utterly destroy the peace and quiet that people valued most about the park were never recorded and never became part of the public record.  The Extension reared its head at practically every public meeting.  So, although any outside observer might think that the process was a success, it actually was not.  Many innovative and exciting design ideas emerged – particularly the “articulated wild” concept and the shoreline riparian improvements as the shoreline is receding.  However the vast majority of participants would still prefer the park to remain simple without the Wellington Street Extension.  In addition, although a canoe and kayak dock was finally included in the plan (a needed addition considering the Inner Harbour is probably Kingston’s best small craft location) no Frontenac Biosphere Paddling Trail Head has been included in the plan despite the fact that less than a dozen places on the planet can boast having both UNESCO World Heritage Status as well as being part of a UNESCO Biosphere.  A serious omission especially when one considers lost tourism potential.

Page 287 (Page 28 of 37)
32) “Three accessible overlooks in a variety of sized and built form are proposed to provide opportunities for viewing the water, sitting, gathering, for water appreciation and passive relaxation.”
From what I have been hearing from local residents, this seems like overbuilding when picnic tables would do just as well and be more in keeping with the relaxed and laid back nature of the wildlife park.  There is a general concern with overbuilding – designing more than is needed or wanted.
33) “Community feedback on the overall draft master plan of October 2013 was favourable”  On the surface yes, but actually this remains a big question.

Page 288 (27 of 37)
34) “While the road won’t create more vehicles on the road….”  Actually research repeatedly shows that if roads are created they become used and then congested – requiring the building of yet more roads.  It’s time to break the cycle.

Page 289 (28 of 37)
35) “While most brownfield properties within the CIP Project areas are well serviced with infrastructure to provide water, sewer, electric, gas and toad access, some…are either without road access or are inderservicec to allow for the density of development possible.”  Most Inner Harbour Brownfields then have road and utility access.   Those that don’t can be serviced with small new roads subsidiary to the existing grid system.  A current best practice worldwide.

Page 290 (29 of 37)
36) “The Wellington Street Extension may not be operationally warranted, when considering the Davis Tannery on its own.”  Yes.  Especially with the new urban demographic that walks the 15 minutes to the downtown and doesn’t need then to worry about parking.  It is also not mentioned here that both Ric Barr, owner of the NGB and John and Michael Sinclair, managers of Living Rooms in the NGB don’t want the Extension, don’t see it as in any way essential to their businesses. In fact, they see it as a source of congestion. Seriously biased omissions. 

37) Opening up the grid system by removing the barriers at River and Russell Streets seems like a good idea.  With Cataraqui St. being the only access to the Woolen Mill, if it were blocked, fire services would be unable to reach the Woolen Mill.  Also the intersection of Cataraqui and River is a dangerous intersection with limited visibility.  Once again, opening up the old grid system is advised.

Page 291 (30 of 37)
38) ‘The proposed Wellington Street Extension is presumed to be regarded as advantageous to this property’s redevelopment potential.” Not quite sure why this should be the case if the owner of the neighbouring NGB is against the Extension because of the congestion it will cause.  Possible false assumption here.

39) “The developable portion (1.5) acres of (ABNA) property has frontage only on the proposed Wellington Street Extension”   There is no reason the parking lot can’t be reconfigured to allow this building to front on Cataraqui Street thereby having no need for the Wellington Street Extension.

40)  It would appear that the only area actually in need of a new road is the section between Railway and Elliot.  Smaller roads than a four lane Extension could accommodate growth more sustainably here.

Page 296 (35 of 37)
41) `The new road extension also provides road and associated municipal infrastructure to support potential infill developments south of John Counter Boulevard and will also serve as an alternative route from downtown to the future Third Crossing.` As stated previously, of nine possible complementary road scenarios to accompany the Third Crossing, the top three consultant choices did not include the Extension.  (TransCad Model Runs – 3rd Crossing Project Support Report)
Serious Omission.

42) Finally, the picture (Exhibit D) showing the Extension through Douglas R. Fluhrer Park is highly misleading.  In actual fact, there would have to be a 10 – 12 metre space between the wall and the beginning of the road.  In this picture, the road hugs the wall, allowing for apparently more green space in the park.  It really is misleading.  Further – there are misnamed parks in the final Exhibit.

43) Also, not yet stated –THE BOTTLENECK PROBLEM.  If one were to try and create a bottleneck in the downtown, one could not do better than the current WSE design:  create a four-lane road, reduce it to a two-lane road (with no dedicated left or right turn lanes) and then include 7 stoplights (at each of 7 downtown blocks) followed by 2-3 stop signs and end the road at a T junction at a park.  This is not a smart arterial.  It will inevitably create further congestion in the downtown and also increase cut-through traffic through the downtown residential core.  As stated in the EA, this cut-through traffic problem will necessitate future studies to determine future solutions.

A few previously stated reasons why the Extension is not a good idea:
1) North end residents don’t want it.
2) It destroys existing off-road cycling trails – turning them into bike lanes.
3) It is not necessary for Inner Harbour development (use grid system instead)
4) It is bad for wildlife – esp threatened turtles.
5) It is very expensive.
6) It is not in keeping with many values expressed in the OP and Provincial Policy Statement 2014
7) It increases air and noise pollution
8) it is not in keeping with the new non-car urban demographic.
9) It reduces green space – turning existing green space into gray space.
10) It jeopardizes the ON THE WALL street art festival – a promising future cultural tourism draw.
11) Doug Fluhrer Park is needed green space for future downtown population intensification.
12) In combination with traffic coming across the Causeway, it causes further congestion.
13) It decreases public safety in Doug Fluhrer Park esp for seniors and children as park access involves crossing a busy road.

Mary Farrar,
President, Friends of Kingston Inner Harbour