From Eglinton Park Residents’ Association

To: LPAT

Date: February 13, 2020

Re: Revised Submission: 2400-2440 Yonge Street

Background

Eglinton Park Residents Association is a party on this file. Our territory is the nine square blocks between the northwest corner of Yonge and Eglinton and Eglinton Park. Our eastern boundary is Yonge Street, our southern boundary is Eglinton, our western boundary is Eglinton Park, and our northern boundary is Roselawn. The proposed development is slated for the northeast corner of our domain. We have been actively engaged in discussion of the site and tried our best to prevent the destruction of the BMO building at the hands of Main and Main, the previous developer.

To the north is another residents’ association, LPRO (Lytton Park Residents Organization). EPRA and LPRO are closely allied on this file. LPRO drew up a detailed critique of the new development, to submit to the tribunal. Our board has reviewed that document and voted unanimously to endorse it and to co-sponsor it.

As we do so, we wish to underline our central considerations.

We begin by acknowledging that in many ways the current proposal is an improvement on its predecessor. The architecture has a good deal more life; the street frontage on Yonge is more lively.

But, as LPRO also notes, this project, when rejected by planning in 2017 as too massive, came back not smaller but bigger.

The podium rose from nine storeys to twelve, an extraordinary height for a podium.

The towers, no shorter than before, grew fatter: their floor-plates increased.

The height of the towers concerns us. From Eglinton, going north, the towers step down, from 31 storeys (107.2 metres) at Whitehaus, to 27 storeys (84 metres) at Montgomery Square, to 14 storeys (50 metres) at the Capitol Theatre site. Supporting Document 2, the formal submission for the new project, shows the proposed new 27 storey tower, at 97.2 metres, to be some four storeys, or 13 metres, taller than Montgomery Square (84 metres), immediately to its south.­­ The the planned towers in this project should step not higher, but down further, to maintain a harmonious progression.

In addition to the points raised in the submission from LPRO, we point to the following:

1. In the blueprints, the apartments are almost always very small, generally one bedroom. Meanwhile, in North Toronto, ever more, apartment towers are full of children. We need a mix of housing types to accommodate families of every shape.

2. Although the Yonge frontage is more articulated, and more lively, than in the 2017 design, it offers nothing public: no space to retreat from the street, no place to sit, no place for public art. In that, this plan is far less successful as a public place-maker than is the Montgomery, to its south. We would like to project to contribute more to enlivening Yonge Street as a public place.

3. The Montgomery, adjacent to the south, gestures to the history of the space, site of Montgomery’s Tavern. This new building, on historic Yonge Street, adds nothing to our sense of collective history. Meanwhile, the Capitol Theatre, two blocks north, is keeping its facade and movie marquee. We want the developers, through art and imagination, to join in the celebration of Yonge Street’s long history.

Dear Councillor Colle,

The Lytton Park Residents Organization (LPRO) and Eglinton Park Residents Association (EPRA) wish to consult with you as soon as possible regarding the upcoming LPAT mediation for the proposed development on Yonge Street, from the north edge of Anne Johnston Health Station to Roselawn. We are very concerned by this proposed development, which is situated on the boundary of our two residents groups. The proposal is inconsistent with the City of Toronto Official Plan, Yonge-Eglinton Secondary Plan and the Tall Building Design Guidelines. We understand that permitted building heights in the Secondary Plan Area have increased; however this application is even taller. It is the first in Ward 8 that fails to comply with the direction provided in the new Secondary Plan (OPA 405).

We look forward to speaking with you about this application shortly. Executive Summary
Our main concerns with the proposal are:

1. 1)  Excessive tower height
2. 2)  Excessive base building height
3. 3)  Excessive tower floor plate
4. 4)  Inadequate tower setbacks
5. 5)  Inadequate on-site parkland dedication

Consequences of the current proposal being approved:

1. a)  Precedent for inappropriate tower heights on Yonge Street
2. b)  Precedent for failing to comply with height transition policy in Secondary Plan
3. c)  Precedent for inappropriate base building heights on Yonge Street
4. d)  Precedent for inadequate tower setbacks from Yonge Street
5. e)  Precedent for inadequate tower-to-Neighbouhrood separation
6. f)  Severe shadow impacts on the Neighbourhood
7. g)  Severe shadow impacts on Yonge Street
8. h)  Significant loss of sky view
9. i)  Lack of regard to adjacent heritage buildings
10. j)  Missed opportunity for park at Yonge and Roselawn (proposed in Secondary Plan)

Each of our five main concerns are elaborated on below:

1) Excessive Tower Height
Both the existing built form and new Secondary Plan support a height peak at the intersection of Yonge and Eglinton with building heights decreasing in all directions. This is of even greater importance on the west side of Yonge Street, north of Eglinton where there are Neighborhoods adjacent to Yonge Street. The proposed building is shown within the existing context below.

The proposed development is 17.7 metres taller than the high rise building to the south, despite being located farther from Yonge and Eglinton. The Yonge-Eglinton Secondary Plan permits buildings of 20- 30 storeys between Orchard View Boulevard and Roselawn Avenue, decreasing in height towards the north. Given that the building is at the north end of this area a height of roughly 20- 25 storeys would conform with the policy. With a maximum height of 97.2 metres, the proposal is roughly the height of a 31 storey building due to the tall floor heights. The proposal does not take into account the decreasing heights moving northward on Yonge Street reflected by approved development applications and the policies of the Secondary Plan. The subject site should be developed with a maximum height of 65- 75 metres (20- 25 storeys).

2) Excessive Base Building Height
According to the City of Toronto Tall Building Guidelines, base buildings are required for new tall buildings to fit within the existing context of the street, to maintain sky view and minimize shadow impacts. The proposed base building height is 49.1 metres and 12 storeys. The first two floors will be double height, which will make the podium appear to be 14 storeys when viewed from the street. The table below summarizes permitted and proposed base building heights.

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Tall Building Guidelines

Montgomery Square Character Area (Yonge-Eglinton Secondary Plan)

Proposed Building

*assumes normal floor heights

Maximum # of Storeys

7 6

12

Maximum Height (metres)

21.6 20*

49.1

The proposed base building represents 227% of the maximum height permitted in the Tall Building Guidelines and roughly 246% of the maximum height permitted in the Montgomery Square Character Area of the Yonge-Eglinton Secondary Plan. The proposed base building does not mitigate the perception of the tall building, match the existing context of the street, nor preserve sky view and sunlight. The proposal fails to meet the objectives of a base building.

3) Excessive Tower Floor Plate
Smaller tower floor plates are required to maximize sunlight and sky view while minimizing shadow impacts. The maximum permitted tower floor plate in both the Tall Building Guidelines and Yonge-Eglinton Secondary Plan is 750m2. The development proposal includes two towers with floor plates of 844m2 and 860m2, well in excess of the maximum permitted. The towers should have a maximum floor plate of 750m2. The excessive tower floor plates proposed contribute to the shadow impacts and loss of sunlight and sky view that would result from the proposal.

4) Inadequate Tower Setbacks
The placement of the towers is also of concern. Both the north and south towers have minimum setbacks from Yonge Street between 5 and 6 metres and are setback from the base building between 3 and 3.5 metres. This is not in line with approved developments in the area, which have two to four times the tower setback of this proposal. This is summarized in the table below.

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Building

2360 Yonge Street at Helendale

2384 Yonge Street at Montgomery

Proposed: 2400 Yonge Street at Roselawn

2490 Yonge Street at Castlefield

Setback from Yonge Street

22.7 metres 20- 23 metres 5- 6 metres

13.8 metres

Setback from Base Building

21.2 metres
9.6- 10.3 metres 3- 3.5 metres

13.8 metres

The south tower is only 5.4 metres from the south property line. The Tall Building Guidelines require all new tall buildings to be 12.5 metres from adjacent properties. This is even greater importance on the subject site as the adjacent building to the south is a designated heritage building, former Police Station #12. This building forms part of a grouping of 3 heritage buildings significant to the history of North Toronto. The Yonge-Eglinton Secondary Plan states that new tall buildings in the Montgomery Square Character Area should respect and “accentuate” heritage buildings. Both the Secondary Plan and Tall Building Guidelines state that when a tall building site is adjacent to a heritage building, the tall building should include additional separation distance. The proposed placement of the tower is too close to Yonge Street and the south property line, fails to conform with City policies and reflect the context of approved local development applications. Furthermore, the inadequate base building setback from Yonge Street will obstruct the view of Police Station #12 from the north.

5) Inadequate Parkland Dedication
The revised proposal requires an on-site parkland dedication of 755m2, but only 414m2 is proposed. The developer is proposing to satisfy 55% of the required parkland with an on-site dedication. The Yonge-Eglinton Secondary Plan envisions a public square on the southwest corner of Yonge and Roselawn. The site is large enough to accommodate a park, it is located in the rapidly intensifying Yonge-Eglinton Area, it is located within a parkland priority area and clear direction regarding this site is provided in the Yonge-Eglinton Secondary Plan. The full parkland requirement should be provided on-site with an acceptable location and configuration.

It is the position of EPRA and LPRO that the development as currently proposed is inappropriate for the site. The tower heights, base building heights, tower floor plates and tower placement do not take into consideration the context of the surrounding area, approved development applications, the Official Plan, Yonge-Eglinton Secondary Plan and the Tall Building Guidelines. If approved the development would restrict sunlight and sky view, create

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significant shadows on both Yonge Street and the adjacent Neighbourhood, diminish the presence of the adjacent heritage building, set a precedent of overdevelopment and appear from the street as a large slab. EPRA and LPRO believe it would be possible to develop the site with a more appropriate development proposal.

Sincerely,

Eli Aaron Tom Cohen LPRO Director EPRA Chair

December 3rd 2019
To: Councillor Mike Colle, Ward 8

Thank you for hosting the Midtown Town Hall on Monday November 25th 2019. We were pleased to see how many people attended and heartened by the three councillors’ commitment to keeping our streets safer.

We at EPRA would like to reaffirm the Group Letter on Street Safety that was presented at the meeting by John Taranu, product of the collaboration of the members of FoNTRA (Federation of North Toronto Residents’ Associations). To summarize, the letter contained three main points:

1. Build Safer Streets
2. Increase enforcement
3. Require safer trucks and vehicles

We were pleased to hear that the although police enforcement was reduced in the past, there was a request by Toronto Police Chief Mark Saunders for a dedicated traffic enforcement team: https://www.cbc.ca/news/canada/toronto/vision-zero-enforcement-team-saunders-1.5360797

In addition, we want to acknowledge the presence of the police officers who have been there on Edith street between 7-9am for those turning onto Edith from Roselawn illegally, as well as from 4-6pm for the northbound traffic on Edith.

EPRA would like to propose three other options for consideration:
4. Reduction of the speed limit on residential streets from 40 to 30 km/h.

In the last few years, there has been talk of reducing the speed limit in the City of Toronto, and the speed limit on Avenue Road between Lawrence and Eglinton was successfully reduced from 50 to 40 km/h, with a radar speed sign installed near Allenby Public School.

5. Penalizing the tinted windshields and windows that are darker than allowed by law.

Mutual eye contact between driver and pedestrians or cyclists at intersections is crucial. However, we too often note, some tinted windshields and windows are too dark to allow this. The law has been around since the Highway Traffic Act R.S.O 1990 c. H.8, s. 73 (1),(2),(3) (revised in July 2016): https://www.cbc.ca/news/canada/windsor/ontario-limits-amount-of- allowable-window-tint-cyclists-rejoice-1.3657694

6. Consider banning or controlling carefully the installation and use of LED (light emitting diode) lights on car lights

The City and, especially, the Provincial and Federal legislators, need to become up to date with the current issue of ‘blinding’ headlights, ever more noticeable as the new, ultra-bright LED car lights are ever more installed. For oncoming drivers, these lights bleach out everything around them, making it very hard to notice pedestrians or cyclists. We have all experienced this in one way of the other.

In other jurisdictions, authorities are gaining information on the situation:

https://www.huffpost.com/entry/ban-blinding-headlights_b_5a4baf5ce4b0df0de8b06d20 https://www.bbc.com/news/uk-43525525

In the UK, the Royal Automobile Club has become involved in the discussion.
The UN Working Party on Lighting and Light Signalling seems to be aware of the problem and

working on it: https://www.unece.org/trans/main/wp29/wp29wgs/wp29gre/grerep.html

The American Medical Association has recognized that some LED lights on street lights are harmful.This can be extrapolated to car lights: https://www.ama-assn.org/press-center/press- releases/ama-adopts-guidance-reduce-harm-high-intensity-street-lights

In summary, we applaud you for holding the Town Hall, and we hope the six points above can be helpful in further making our community livable and safe.

Sincerely

Carla Lutchman (vice-chair) and Tom Cohen (chair), on behalf of the Eglinton Park Residents’ Association

NOV 2019

I write on behalf of EPRA — Eglinton Park Residents’ Association, on the matter of the old Capitol Theatre at 2490-2506 Yonge Street.

Our Residents’ Association has a catchment area in the northwest quadrant of the intersection of Yonge and Eglinton. We are lodged in the nine city blocks east of Eglinton Park, with Roselawn our northern boundary. Another organization, LPRO – Lytton Park Residents’ Organization – sits on the tract in which the building in question lies. In many matters, this one among them, EPRA and LPRO consult very closely and support one another. So, although the theatre, after a fashion, “belongs” with LPRO, it is, and long has been, of intense interest to our group, just as, in the recent past, the fate of our “Postal Station K” interested LPRO.

The theatre has always been part of our larger neighbourhood. It has stood there more than a century. It is a fine piece of early twentieth-century streetscape (finished ca. 1914), a work of in part of Murray Brown (renovations of 1923-1924), the same Toronto architect who designed Station K, and we are keen to keep both buildings as part of his legacy to the city.

The movie house has excellent street frontage, with small shops of the sort that enlivened our streets in the streetcar epoch. Keeping it will help preserve the character of that stretch of Yonge.

Over the past five or so years, EPRA, like other groups, has been in repeated consultation with the developer, Madison, about their evolving plans for the site. At the outset, Madison intended to take the theatre down, and merely to recycle bits of the facade elsewhere in a large, complex project. By this fall, however, the plan had evolved, with a less massive mixed-use building, lower, and more accommodating to the facade and the interior of the theatre. We in EPRA welcome that change. We prefer to see old structures put to new uses, in creative ways that respect the past in an inventive fashion. We do not insist on preserving the old building in its entirety, but we look for a re-use that makes it visible and distinct. Mere facadism is not a good solution, so we hope for good design that brings out both the old and the new.

Tom Cohen

Chair, EPRA

Ministry of Municipal Affairs and Housing
Municipal Services Division
Municipal Services Office – Central Ontario
777 Bay Street 
Floor 13
Toronto ON
M5G 2E5 …
Phone: (416) 585-6226 
Toll Free Phone: (800) 668-0230

I chair the Residents’ Association at the northwest corner of Yonge and Eglinton. Our catchment is the nine square blocks between Eglinton Park and Yonge. As RAs go, we are small but feisty. We were deep in both cycles of Midtown in Focus, the first all about public realm, and the second far more comprehensive, with an eye to built form and to what activities go on in the form that does get built. It was an exhaustive and exhausting process, with many meetings and consultations, and deep involvement by many many of us citizens.

To our eyes, the results are really good. Thoughtful, thorough, and keenly needed. At the end of the political process a debate broke out, about height limits in the northeast quadrant, and some developers may be caught with stranded assets, having bought a plot from which they cannot expect a gain. That fact, we suspect, has stirred up opposition to the whole larger vision, and pressure to block OPA 405. If that happened, we would be in a terrible spot, as, by the time a new version came about, the genii of development would have spent so long out of the bottle that a lot of what OPA 405 aims for would have become impossible or really hard. Down to now, the rules at Yonge and Eglinton have been too lax, so that the scale of construction and the rise of population threaten to overwhelm all services: transportation, parks, schools, sewer lines, sidewalk space, and so on. And the push to residential-only has led to an unhealthy imbalance: we need an urban zone that provides jobs as well as bedrooms, the better to cash in on the coming Crosstown line. To make this vital Midtown intersection into a hub, there must be a fair, clear-eyed plan and a set of guidelines that help developers to make good choices that pay off in the long run.

In sum, EPRA are keen to see OPA 405 made official. If there are quirks that need adjustment, adjust them at the Provincial level. But please don’t kill it or send it back. The intense work over the past five years will have gone to naught, and a second go-round will be painful, slow, and risky.