Sustainable Calgary Society Submission on the Keystone Hills ASP Council Public Hearing, June 11, 2012

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1 Sustainable Calgary Society Submission on the Keystone Hills ASP Council Public Hearing, June 11, 2012 This submission on the Keystone Hills Draft ASP is divided into five parts. 1. The Proposed Community and Neighbourhood Design 2. The Rationale for Growth 3. Alignment with MDP Goals 4. Affordable Housing 5. Energy Conservation, GHG Reductions and Ecological Footprint Proposed Community and Neighbourhood Design: A Step in the Right Direction. Overall this component of the ASP is an improvement over previous ASPs and attempts to honour the MDP and CTP. We support 1. The positioning of Neighbourhood Activity Centres and Neighbourhood-scale Commercial Centres in the heart of neighbourhoods. We feel this is crucial to vibrant and pedestrian oriented neighbourhoods and should be non-negotiable. 2. The prescriptions for Community Activity and Commercial Centres. 3. The grid or modified grid street pattern. 4. The schematic bicycle network. It demonstrates a desire to make bicycling a pleasant, safe and efficient mobility option throughout the district. 5. The designation of a transit network within the district. 6. We agree with the inclusion of Water and Energy guidelines within the Green Communities section but note that with the use of soft language such as should and consider it remains a possibility that development may proceed without any of these policy measures being implemented. 7. The requirement for District Energy and Co-Generation Assessment. But, we feel this assessment has to be undertaken at the ASP stage. 8. We are generally supportive of the Major Activity Centre but concerned with the inclusion of surface parking. It is our opinion (and this was communicated in consultations with the planning team) that the Major Activity Centre should not allow large surface parking. The intensity of uses in the Centre should be seamlessly integrated into a fine street grid with parking, predominantly underground or stacked in structures that fit within the grid pattern. Our concern is that with large surface parking all of the other good design features will be undermined by what will in practice be an auto oriented Activity Centre. It is unclear whether the ASP would allow the formation of Major Commercial Centre in a BigBox format. We feel it would be inappropriate to do so.

2 We recommend that a linear development of the Major Activity Centre be provided that would make better use of the street front along the arterial and feeder road system including the Boulevard. We feel it is possible to avoid the notion that feeder and arterial roads are nothing more than transportation corridors. Every street should be a complete street pleasant, safe, and productive urban space. 9. We support the aspiration that the Industrial and Employment Centre should also be pedestrian and transit-oriented with complete streets. We urge diligence in the design of the Employment Centre to ensure this aspiration is realized in practice. 10. We are concerned that the use of language like should and may in reality means that there is little likelihood of measures described in those terms will ever find the light of day in these communities. The Rationale for Growth is Very Weak. Point 1. Advancing MDP and CTP. The document states that The extent to which the development of the Plan Area advances the objectives of the MDP and CTP is contingent on achieving mixed-use Activity Centres and transit supportive land use in a reasonable time frame. This does not inspire confidence that those conditions will be met in any reasonable timeframe for at least two reasons. First there is no commitment to implementation of transit infrastructure. No timeline is given for the LRT and no commitment is given that even a BRT will be deployed until such time as the LRT is built. Second, there needs to be some assessment of the impact of Cross Iron Mills (a regional auto-exclusive shopping centre already serviced by major roads) on the potential for the Activity Centres to achieve a level that is transit supportive. Point 2: City Financial Capacity. The document states that only a portion of the Leading Infrastructure costs and none of the costs associated with Transit are currently noted in the 10-Year Capital Plan or the 3-Year Capital Budget and that Additional costs of growth, such as LRT station will require infrastructure and services outside of the Plan Area, which are not included in this document. Further it states that the costs do not represent the full costs to service the community and there may be additional costs not foreseen at this time. (Appendix B) Lacking cost allocations and lacking the full costing of significant pieces of infrastructure it is unlikely that revenue from the area will be sufficient to cover costs leaving tax-payers vulnerable. Point 3. Need for Planned Land Supply. This document does not demonstrate that need. As stated current land supply is in the range of years. With this ASP land supply will far exceed the targeted supply. Most importantly, as the document states this does not include redevelopment and intensification potential in established areas. In fact the City of Calgary Geodemographics report Land Use and Travel: Plan It Calgary and

3 CALGARY METROPOLITAN PLAN Scenarios Series provides estimates of how that population can be accommodated in established communities. Approval of this ASP should not be granted until the City s Land Supply Strategy has been developed as part of the Corporate Growth Management Project. Point 4. Operating and Lifecycle Costs. The report offers no assessment of whether the city has the capacity to pay for these costs? The city faces a severe infrastructure deficit (Long Range Financial Plan 2011 Update), and that current development levies fall far short of covering infrastructure costs. Until that assessment has been completed, it is fiscally reckless to give this ASP the green light. The estimates of the Civic Camp Governance, Finance and Infrastructure Group to the STP in 2011 (The Opportunity To Manage Growth Sustainably) forecast that between the developers will pay less than 50% of the cost for leading infrastructure in new Greenfields, with ongoing operation and lifecycle costs, and lagging infrastructure costs on top of that. Point 6: Transit Supportive Land Use. The document states that an interim rapid transit service by bus along the future LRT alignment until LRT is implemented may be a possibility So not only is there no guarantee that LRT will ever come to this community, but there is no commitment for even a compensating level of bus service. This will not be a transit-oriented community. Even if, eventually there is an LRT line into the community, it will serve only as a commuter system into the downtown core. In all likelihood these communities will be de facto car-dependent communities. Point 8. Community Interest. We object to the assertion in this document that No significant concerns were identified by the general public during the engagement process This submission, much of which was communicated during meetings with the planning team, represents significant concerns on our part as a group of concerned citizens. We would agree that Positive feedback and support for the general principles of Neighbourhood Design and Complete Communities is an accurate assessment of our communications with the planning team. The Proposed ASP Does Not Meet the MDP Goals MDP Goal: A Prosperous Economy. This ASP endangers a prosperous economy. High maintenance suburban sprawl damages our competitive position. There is no assurance in this document that this plan contributes to a sustainable municipal financial system and it is our belief that it will compromise quality of life for current and future Calgarians.

4 Just last week a major study from Queens University, the first of its kind, was published estimating that inactive lifestyles of Canadian adults costs the health care system almost 7 Billion dollars annually. ( That is about 212 million dollars annually for Calgarians and doesn t even include the health costs to our kids. The sedentary lifestyles associated with car dependent communities are a large contributor to these health costs. Both Calgary Economic Development and The Calgary Chamber of Commerce have also raised concerns in the past about the costs of continued Greenfield development in Calgary. MDP Goal: Shaping a More Compact Urban Form. Development of this Plan Area will not result in a more compact urban form. The target densities are lower densities than existing inner city neighbourhoods and of existing new communities. There is no guarantee of anything more than transit stops. No LRT infrastructure is committed and no level of service guaranteed that would support a more compact urban form. This plan supports connectivity within the Plan Area but connectivity beyond the Plan Area will be auto-dependent. This community will be surrounded by major roadways and will separated from the nearest community to the south by Stoney Trail. Transit Map 9 shows that the only transit connection to communities to the south across Stoney Trail will be the LRT route and there is no guarantee in this document that the line will ever be built or even that a rapid bus transit will be provided in the interim. We note that this ASP acknowledges that there will be no library or multi-use recreation centre in the ASP and that the nearest library and multi-use centre will be 3 km from the centre of the ASP on the other side of the Stoney Trail. These facilities will not be within realistic pedestrian or bike access. Given the limited pedestrian access across the Stoney Trail, the 3 km distance is misleading and an underestimation of actual travel distances. It is unlikely that people will choose to travel by foot or bike across a 0.5 to 1.0 km span of the Stoney Trail and its right of way? It is our contention that Transit infrastructure LRT, and either streetcar or bus service - must be considered as leading infrastructure, as critical as roads or water and sewer and that this development not should proceed without the ability to provide these services from Day One. Furthermore we suggest that it should be the responsibility of the developer to provide such infrastructure. Precedent for this approach can be found in development agreements recently signed between developers and the City of Vancouver with respect to SkyTrain infrastructure. These recommendations are compatible with the MDP s and CTP s priority for walking, biking, and transit. MDP Goal: Improving Housing Diversity and Choice (Affordable Housing). We have concerns about affordability given that this community will be car-dependent. Transportation is the second highest household expenditure and for low-income households often the highest expenditure. Furthermore it is highly variable and undependable (car troubles can throw a low-income family into crisis). Even if

5 affordable housing is built in this community car-dependency will be a significant impediment to affordable living. Sustainable Calgary has recently completed CMHC sponsored research on Affordable Living in Calgary. The report demonstrates that alongside the direct provision of affordable housing, the provision of a level of transit service that allows households the realistic option of not owning a car or of reducing the number of cars required by a household is the best way to improve affordability and choice. The executive summary of that report is included at the end of this submission. The ASP Will Result in a Community That Undermines the City s Policy Objectives for Energy Conservation and GHG Reductions We applaud the call for a District Energy and Co-Generation Assessment but we feel it needs to happen at the ASP stage. Integrated energy systems are complex. If it is left to the community development stage we are doubtful that the required patience and coordination will be a priority for the developers and it will be easily sidelined. We also recommend that energy intensity targets need to be set to induce developers to take seriously all of the aspirational but non-binding shoulds contained in the document, and to comply with existing city policy to reduce the Ecological Footprint and achieve GHG targets. It is standard practice in Europe to set energy intensity targets for new communities. For example in the community plan for Kronsberg, Hannover, Germany there is specification for targets for energy demand per m 2 of building; and a climate change program itemizing the CO 2 emission reductions from building efficiency, Combined Heat and Power district energy and use of renewable technologies wind and solar. Source: Hannover Kronsberg Handbook ( We note that the Keystone Hill Area Structure Plan 2020 Sustainablity Direction/Triple Bottom Line Appraisal clearly demonstrates that the current plan will not meet the policy objectives of the Ecological Footprint or GHG Reductions Strategies. It states that the ASP will result in greater demands on the Earth s biosphere than the current citywide baseline. Given that this development would achieve build out over perhaps 30 years (between now and 2042) it is unacceptable and irresponsible that communities will be built out to less than today s GHG and Ecological footprint baseline at a time when our GHG targets and Kyoto Protocol commitments will be fast approaching (2050). Just this past week the United Nations released its 2012 Global Environmental Outlook The Report states that the environmental outlook is grim and that only 4 of 90 indicators are moving in the right direction and that the scale, spread and rate of change of global drivers are without precedent. Burgeoning populations and growing economies are pushing environmental systems to destabilizing limits and that drivers typically have high inertia and path dependencies which can act as barriers to effective action.

6 Calgary s sprawling and expensive form of development is a perfect example of the drivers the report refers to. The Approval of This ASP Will Lock The City Into Unsustainable Development that Undermines the MDP and CTP for the Next 30 Years. This ASP will lock its communities into the old, financially unsustainable pattern of development. It does not meet the expectations of Calgarians as expressed through the imaginecalgary and Plan It processes and it undermines the MDP and the City s financial stability. This ASP will result in 60,000 more Calgarians living in auto-oriented communities. Though the design may achieve active and transit mobility within the Plan Area, travel beyond these communities will be predominantly auto-dependent. Without energy intensity and GHG reduction targets these communities will undermine the City s Ecological Footprint and GHG Reductions Policies. These communities will do very little to enhance housing affordability and choice for the average Calgary family. It is debatable whether this ASP is necessary from a land supply perspective even when only considering greenfield supply. The inclusion of established community growth potentials in the land supply assessment would clearly make this ASP unnecessary. We oppose the adoption of the Keystone Hills ASP until the serious flaws are addressed and until such time as a city-wide land supply assessment demonstrates the need. Sincerely, Dr. Noel Keough, B. Eng, MeDes, PhD Chair of the Board Sustainable Calgary Society th Ave SW Calgary, T2R 0G9 Sustainablecalgary.org

7 Executive Summary: Action Research on Transportation and Housing Affordability Principle Researcher: Dr. Noel Keough This research test the hypothesis that housing choice and affordability, in large Canadian cities, particularly for marginalized groups, can be significantly enhanced by the right municipal transportation policy choices. Transportation is one of the central policy levers available to municipal governments and is typically the largest spending item in city budgets. It is also typically second only to housing as a percentage of private household spending. This research estimates total transportation spending in Calgary by all levels of government and by private households; it proposes a model for explanation of households mobility perceptions, attitudes, preferences and behaviours with particular emphasis on households at risk. It maps changing spatial patterns of affordable living across Calgary using car-owner and car-free scenarios and proposes a structure for a housing-transportation affordability index; and it reports on a workshop in which some of Calgary s key housing and transportation policy actors identify the most promising transportation policies in support of affordable living. The research team provided as comprehensive a picture as possible of transportation spending over the 10-year period from Total cost of transportation for Calgary is estimated to be 66.6 billion dollars. Private household spending of 52.5 billion dollars represents 79% of the total. The provincial and federal governments spent 1.75 billion dollars and 75 million dollars respectively. Municipal spending is by far the largest portion of government spending at 5.2 billion dollars. Surprisingly the social costs of transportation 7.1 billion dollars - exceeds spending by all levels of government. The research team sought to understand the phenomenon of household decision-making with respect to housing and transportation choice. The study found that housing and travel decisions cannot be treated separately as they are intimately linked and often co-determined. Housing and travel choice is largely activity-based and results from a complex interaction of constraints, imperfect knowledge and complex activity patterns. The research demonstrated that household housing and travel choices are co-determined while at the same time neither public nor private policy considers these two phenomena to be bundled. Based on householder interviews the study concluded that private automobile ownership is impossible or burdensome for many households. It also found that there are many constraints to walking and bicycling in Calgary, including: 1. Distances to destinations are often too great for these modes. 2. Infrastructure for safe walking and bicycling is very limited. 3. Parents with children can only employ these modes over very short distances. 4. There are many days when weather precludes walking and cycling. The study concluded that to be effective transit must be affordable, comfortable, rapid, reliable, frequent and legible. Legibility and reliability have particular meaning in the context of this research. A transit system is legible when the user can easily understand routes and timetables. Reliability refers not only the conventional idea that a route is on time, but that the route has some permanence over time. Based on these research findings the following recommendations were proposed: 1. The city should provide transportation information to new homebuyers.

8 2. The city should actively promote the creation of location efficient mortgages 3. The city should implement policy to support carsharing cooperatives and investigate the possibility of city-run carsharing as a part of its transportation policy 4. The city should make transit infrastructure in industrial and retail (big box) employment districts a priority. 5. The characteristics of effective transit favour railed-based transit over bus transit. Rail-based systems are particularly appropriate in terms of legibility, ability to attract investment (jobs creation in proximity to Transit) and permanence. Housing location choices are less likely to be influenced by an impermanent bus route versus a more permanent rail route. Mapping Affordable Housing The affordable house purchase mapping showed that, according to the 2006 census data, if a household was able to avoid the purchase of an automobile, the number of census tracts in which it could afford the purchase of the average house increases up to 1700%, with the greatest numeric increase in choice (93 of 202 tracts), occurring for household incomes at $80,000. Based on MLS data between 22% and 1100% more homes sold would have been available to a home-buyer based on 2006 sales data. The greatest percentage increase in choice occurs for the 60,000 income bracket (1100%); followed by the 50,000 income bracket (327%) and the 80,000 income bracket ( 207%). The greatest numeric increase in affordability of sold homes occurs at $80,000 income (6069 homes) and at $100,000 income (6171 homes). Based on MLS data, depending on income level, between 26% and 1800% more homes for sale would have been available to a home-buyer based on June 2011 data. The greatest increase in choice occurs at 60,000 income (1800% or 1677 homes), followed by the $50,000 income bracket (1570% or 848 homes) and the $80,000 income bracket (125% or 2228 homes). In Calgary, the four city quadrants (NE, NW, SE, SW) are significant descriptors of where you live. The 2011 Calgary Real Estate Board data (Table 6) shows that in the car ownership scenario, for an 80,000 dollar income household, in only one of those quadrants would the average home price is affordable. In the car free scenario, that same home-buyer has a choice of several communities in every quadrant of the city. The affordable rental mapping exercise showed that if a household was able to avoid the purchase of an automobile, the number of available rental units within an affordable range increased up to 1300% with the largest increases occurring at a household income of $20,000 (423 units). At $20,000 income the percentage of all rentals available increases from 1.7% in the car ownership scenario to 23.4% in the car free scenario. At 30,000 income the percent of all rental offerings available increases from 11.4% to 44.7%. For $40,000 income the increase is from 42% to 71.7% of all rental units. In the estimation of housing and transportation stakeholders the most promising policy interventions identified by this research are the creation of a housing-transportation index by community; a transit access rating by community; and greater investment in bicycle and pedestrian infrastructure. The preferred policy options were chosen with an eye to the probability of achieving the policy. The more significant transportation system investments, that would actually increase transit availability above existing conditions, were considered to be difficult to achieve. Based on this research, such changes could result in significant improvements in affordable living and in doing so increase housing affordability and choice under existing housing market conditions in Calgary. (The full report can be found at sustainable.org)