March 11, 2021
Jason Brander, Planning Department
Dear Jason Brander
EPRA opposes the application. It argues that, at 24 and 32 storeys, the projected towers for Eglinton between Duplex and Henning are already tall enough. They should go no higher. Taller towers would cast longer shadows, loom even higher over adjacent housing, and burden infrastructure. And they would set a precedent, inviting imitation.
Our reasons, laid out in full, address both the history of our engagement in the planning process and the material and social consequences of taller towers.
On March 2, 2021, members of ERPA’s board attended the WebEx public meeting concerning 50-60-90 Eglinton West and 17-19 Henning. And then, on March 8, 2021, the EPRA board, at its monthly meeting, the board discussed our response to Madison’s proposal. As not everyone had managed to attend, often for technical reasons, you sent us a helpful link to a film version of the meeting, and we made sure that all members of the board received it.
EPRA – Eglinton Park Residents’ Association, speaks for the nine square blocks between Eglinton Park and Yonge Street, with Roselawn our northern boundary, and Eglinton our southern limit. We are entirely in Ward 8.
Our association has been deeply involved from the very start in the discussion about the evolving proposal for new buildings on the stretch of Eglinton between Duplex and Henning. In the beginning, only 90 Eglinton West was in question. We had extensive discussions with councillor Christine Carmichael Greb as the project evolved, and we went to the OMB to argue against it, as a building too big, too close, too abrupt, and too far across the Duplex boundary for high-rise buildings.
More or less at the same time as the OMB hearing, we learned that Madison had acquired the Toronto Hydro lands and that it was revising the design in the light of its larger footprint, aiming for two towers on a single podium.
In 2016 or 2017, Councillor Carmichael Greb invited EPRA to a meeting, held in a committee room at North York city hall. Madison sent representatives, and the councillor brought her chief of staff. Al Rezosky came for Toronto Planning. Tom Cohen and Gordon Floyd were there for EPRA. The councillor asked EPRA if it would be willing to accept Madison’s proposal, without protest. Those towers, at 24 and 32, were too tall, we said. Could we push them lower. Al Resozky, the city’s planner told us that the city and Madison had worked extremely hard on the design, with the city pushing for concessions that made the towers thinner, and thus further apart. Those changes, he told us, permitted a shift in the position of the eastern tower to reduce its impact on Henning and the houses to the north. Moreover, the planner told us, a single podium, a single excavation, and east-west passage, a single traffic entrance off that passage, a fine outdoor space on the roof, the widening of the Duplex sidewalk, the clever use of the heritage property: all these things were concessions, made by the developer, marking hard-won gains by the city.
EPRA, in light of those arguments, agreed. And we and Madison could look forward to a continued conversation about good design at ground level.
Then came the election of 2018, resulting in a Progressive Conservative Provincial government, with its pro-development stance, and, in 2019, Minister of Municipal Affairs and Housings Steve Clark’s energetic revision of Toronto’s Midtown-in-Focus plan, as adopted by Toronto’s city council. His revisions to OPA405 brought us a new secondary plan for Midtown, with much higher limits for towers. And then, in the summer of 2020, Madison called us to tell EPRA that they would be asking, for financial reasons, to add seven stories to the east tower and ten to the west tower, bringing them to 39 and 34 stories.
EPRA opposes this change adamantly.
1. First off, we had an agreement at a formal meeting: the original heights, the original design.
2. Second: precedent. Every proposed tower argues from a tower near at hand. At the March 2 meeting, the developer argued from the 65-storey 40 Eglinton East, a building not even approved. So taller buildings east of Henning will be a “camel’s nose” for arguments about buildings west of Henning, across to Edith. We could find our neighbourhood behind a Great Wall of China all along Eglinton.
3. Shadow, and loss of sky, not only for the single-family dwellers west of Henning, but also for the residents of the apartment buildings along Duplex, 411 especially, and in the Stanley Knowles Co-op tower, and for the office workers at RioCan. We note that shadow studies always confine themselves to discussing sunlight. Sky itself is enlivening; it is particularly important to apartment dwellers; an expansive view of the natural world is vital for emotional well-being if one’s interior space is small.
4. Morning shadow on Eglinton Park, not on 21 March, but in the winter months, when shadow will fall, especially on the playground immediately to the north of the parking lot. Children play there all year long, even when temperatures drop below freezing.
5. Transition to the residential streets to the north, Henning first off, and then Edith and Orchard View as well. That old orchard is, of course, long gone. The present view is growing ever shorter. Henning will be walled in and heavily shadowed.
6. Burden on services: EPRA is alert to how a rapidly growing population is stressing services of every sort, from water to parks to community facilities and to transit, which, post-pandemic, will once again be sorely stressed to accommodate the many thousands of new North Toronto neighbours as the many towers now under construction or permitted or projected fill up with people. Toronto may need to build more housing, but Midtown itself needs to stop, and to adjust to what housing is now arriving.
Given all those considerations: past agreements, design problems, and social consequences, EPRA opposes adding further storeys to these two towers.
Best wishes,
Tom Cohen for the EPRA board
cc Councillor Mike Colle
Eglinton Park Residents' Association 
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