175 Third Avenue

Ottawa, K1S 2K2

September 14, 2023

Krishon Walker

City Planner

City of Ottawa

Re: Comments regarding proposed OPA and Rezoning of Lansdowne Park

I am writing on behalf of the Glebe Community Association to provide comments on the proposed rezoning and official plan amendments for 945 and 1015 Bank Street. These comments are based on extensive conversations within our community, including an open house.

Lansdowne Park is adjacent to the UNESCO-designated Rideau Canal in the heart of downtown Ottawa. This city-wide asset has a long history of bringing residents together to enjoy green parkland, for sports, exhibitions, entertainment, as well as a weekend farmers’ market.  The GCA has been working with the City of Ottawa, the Ottawa Sports and Entertainment Group (OSEG) as well as the Glebe BIA for many years to enhance the vibrancy of Lansdowne Park and improve the site so that it can continue to benefit both this community and residents across the City.

The City’s new Official Plan designated Lansdowne Park as one of its “Special Districts” and we support good stewardship of this publicly owned land in the centre of our city.

The GCA is in favour of the City’s growth management objectives for intensification, which includes increased density in the Glebe and the downtown core and we support the City’s overall objective of becoming the most liveable mid-sized City in North America. 

The GCA is concerned about overdevelopment, the loss of accessible green/park space, and the impact on public space of the proposed redevelopment that could make the site less, rather than more, attractive to visitors.

Bearing all of the above in mind, we offer the following comments more specifically to the proposed Official Plan Amendment and Rezoning related to Lansdowne Park:

Transportation issues

  • Transportation studies do not take into account the traffic demand and impacts from events in the urban park itself (i.e. music festivals/cultural events in the Great Lawn area, etc.)  The studies seriously under-estimate traffic demands and how multiple activities in the entire site will affect traffic.
  • Transportation studies do not take into account the increasing use of online shopping and food ordering and related delivery activity. The demand created by new residents on the site could be significant.
  • There has been no assessment or evaluation of the current traffic impact—other than during Red Black games. Transportation infrastructure is insufficient to handle current activity at Lansdowne given there is no LRT or Rapid Transit service available, and nor will there be within any reasonable planning horizon.
  • One of the key objectives of Lansdowne 2.0, according to OSEG, is to attract more people to Lansdowne Park.  And yet, the transportation study says there will be no increased demand or impacts. This defies logic, unless the assumption is that the only additional “visitors” or patrons to the commercial areas and events hosted at Lansdowne will be residents in new towers.  That is a very risky assumption on which to base a prudent analysis of transportation impacts.

Scale and Massing of residential towers

  • It is greatly concerning that this proposal appears to be requesting permission to rezone an area that includes both the playing field and the south side stands.  There is no rationale provided for why this land should be included.  These areas should be removed from any rezoning proposal, unless it represents the City’s recognition of the risk that this redevelopment proposal poses to taxpayers and it anticipates the demise of the football stadium and team play, and further development of residential towers onsite to assist in bailing the City out of further financial difficulties.
  • The proposed maximum height and massing of the towers is not supportive of a vibrant public realm that Lansdowne Park is intended to provide, and in fact, must provide, if it is to attract visitors and become financially sustainable. The City’s own UDRP has voiced strong concerns in its July 2023 review of the proposal, backing up the concerns of the GCA. 
  • A narrower floorplate, as per the City’s high-rise guidelines of 750 sq. m, must be adhered to, to reduce sun shadow effects as well as to create buildings that don’t dominate their surroundings.  The towers do impose themselves and detract from the attractiveness of the site – critical to the financial success of Lansdowne, which is the problem that the City is trying to solve.  The UDRP makes this point quite strongly in their comments from July 2023.
  • This amount of density is not appropriate given lack of LRT or Rapid Transit – particularly on a site that already suffers from traffic congestion.  

Heritage issues

  • The proposed new event centre and extended berm will encroach into the framing lands and Great Lawn south of the Aberdeen Pavilion.
  • The placement and height of the event centre will also compromise the prominence of Aberdeen Pavilion. 
  • The placement of the third tower will completely change the cultural landscape of the Aberdeen Pavilion, a national historic site. This building is meant to be set in open surroundings and was historically used for mass public events. A high-rise tower will irrevocably change the prominence of this historic centrepiece of Lansdowne Park.
  • The high-rise towers (all three of them) will block light going into the transom windows of the Aberdeen Pavilion and will change the public experience of this heritage building.
  • High-rise towers compromise the visual primacy of the Aberdeen Pavilion as the centrepiece and symbol of Lansdowne Park. Views of the Aberdeen Pavilion will be blocked from the Bank Street Bridge and from QE and Colonel By Drive. The whole character of the site will be changed. 

Proposed Official Plan Amendment 

The Proposed Official Plan Amendment attempts to leverage what is described as a lack of clarity and direction in the newly-minted Official Plan.  

With respect to greenspace, the OP Special District policy is very clear: development of greenspace goes against the clear intent of the newly-minted OP, and will result in significant loss of greenspace. The Special District policy in this regard was further reinforced by Council at the same June 2022 Council meeting in a motion sponsored by Councillor Kitts that specifically referred to such policies, and that any proposal for Lansdowne Park should respect them.  The motion specifically contemplated the policy of and intent of the Official Plan – again, this was not a matter of an oversight that needs to be corrected.  The City’s Planning Rationale for this OPA states that the Council-approved in principle concept should take precedence and that the Special District policy is “considered to be an oversight.” This is very clearly not supported by the clear intent of this motion, which reinforces the clear intent of OP policy for the Special District, that is, “development within Lansdowne Park should be focused on existing built areas, avoiding or maintaining the established areas of greenspace and public space.”   

The City’s Planning Rationale goes on to say that, “the Official Plan Amendment for the subject property will provide direction and improved clarity regarding the applicable designations on the site and conflicting policy direction throughout the Official Plan.” Again, there is no lack of clarity regarding applicable designations or conflicting policy direction.  The language and intent of the newly-minted Official Plan is in fact very clear.   When it talks about greenspace and public space it means space that is currently green, space that is currently public.  It is not referring to land use “designations” – and how it should be interpreted in light of the Special District policy.  Again, it is a clear statement that the City should not proceed with development on “established areas of “greenspace” and “public space”.  And it is abundantly clear that the existing “Hill” and “Great Lawn” within the exclusively public areas of Lansdowne Park are just that.

The loss of (usable) greenspace that will result from this proposal is important.  The City knows that inner urban areas, including the area where Lansdowne Park is located, are underserved in relation to the City’s own standards for greenspace.  Bearing in mind that the intent is to continue to intensify, and more residents will join the immediate neighbourhood, this gap in the amount of greenspace will only widen even without this redevelopment proposal.  With the arena build, the gap becomes even greater, and suggests that Ottawa is willing to sacrifice both its greenspace and its’ important livability goal.

Designating Lansdowne Park as a Special District in the new Official Plan was a prudent and deliberate move since Lansdowne Park is a vital city park in the heart of Ottawa along Rideau Canal UNESCO World Heritage site with great historical importance. It is therefore vital that any future planning approaches to Lansdowne Park adhere to these policies.

In trying to lay out a case for the Official Plan Amendment, the Planning Rationale links a number of misleading or unsupported statements.  Broken out, they are:

Planning Rationale:  “The proposed event centre will be located within the existing grass berm of the Great Lawn at the east end zone of the stadium.”

In fact, the actual footprint of the proposed event centre extends beyond the footprint of the existing berm, and into the Great Lawn area, although this and other representations of the arena proposal obscure this reality.  Importantly, the arena will also rise roughly 2 ½ storeys above grade, presenting a significantly larger massing than the green berm that exists currently.  The Urban Design Review Panel had this to say:

 

  • The Panel has concerns with the event centre in terms of how it blocks and interrupts the pedestrian experience of the site.
  • The Panel encourages the applicant to consider alternate sectional studies and provide further analysis to better inform the end result.
  • The Panel strongly recommends lowering the event centre into the ground and seamlessly connecting the park with its roof to create a park space for public enjoyment, despite additional cost.

Then there is the issue of how the proposal intends to transition the eastern 2 ½ storey “wall” of the arena down to the level of the Great Lawn. Assuming a new berm is created (that provides music festival seating in warmer seasons, and a well-loved toboggan hill in winter) with similar slope to the existing one, the Great Lawn will be reduced by a further 30m or roughly 30-40% (roughly) of the existing grassy area. 

Planning Rationale:

“The proposed event centre will be integrated into the existing berm, and a green roof will be considered during a future Site Plan Control application.”

“The proposed concept, and more specifically the event centre, will maintain the integrity of the Urban Park as it exists today. The existing berm will be reinstated after construction of the event centre is completed, and a green roof will be considered when determining the detailed design of the building. A future green roof will respect the open space that currently exists and will complement the park.”

The above statement is not credible on a number of points:

  • It is highly misleading, if not simply untrue, to state the existing berm will be reinstated after construction of the event centre is completed.  If a berm is built to transition the new arena to the reduced Great Lawn area, it will be an entirely new berm, and built in an almost entirely new location to the east of the existing berm.  It will occupy what is now the Great Lawn area.
  • Staff have been directed to identify costing of structure to enable use of the roof area, but no estimate has been confirmed so there can be no confidence whatsoever of future use.   

With respect to height and massing within Special Districts, the newly-minted OP, backed up by Councillor Kitts motion that was approved by Council, is also clear.  It is not the case that the OP provides limited direction, as per the Planning Rationale:

“As the site is subject to the Lansdowne Special District policies, there is limited direction regarding height and massing. As such, an Official Plan Amendment to create an area-specific policy is proposed to create clearer direction for the site as it relates to land uses, height and massing.”

The Official Plan is in fact very clear:

  1. d) With the exception of Kanata North, the permitted building height will be the higher of the:
  2. Existing zoning in place at the time of adoption of this Official Plan; or
  3. As provided through an adopted Secondary Plan.

The proposed rezoning and OPA far exceed the height permissions as outlined above.

Summary

In summary, the GCA has strong concerns regarding the proposed OPA and Rezoning for this site, which do not appear to be driven by good planning.  Rather, the redevelopment plan for Lansdowne Park appears to be driven by an effort to support financial engineering to present this redevelopment as “revenue neutral” or no cost to taxpayers.   

In addition, the City has decided not to address calls by this community and others to pursue exploration of alternatives that could potentially develop positive solutions to problems faced by the City, that are first and foremost in the public interest.

Submitted on behalf of the Glebe Community Association.

Carolyn Mackenzie

Chair, GCA Planning Committee