Front Street Environmental Assessment Review

FRONT STREET ENVIRONMENTAL ASSESSMENT REVIEW Prepared For: And July 2012 www.c2planning.com July 10, 2012 To: Alan M. Heisey, Q.C. From: Christian Chan Partner Partner PMH Law C2 Urban Planning Standard Life Centre 676 Huron Street Suite 510, 121 King St. W. Toronto ON P.O. Box 105, Toronto, ON M5H 3T9 M5R2R9 Re: Evaluation of Municipal Class Environmental Assessment for Front Street Reconfiguration You have retained us on behalf of Cycle Toronto as planning consultants to evaluate the recommended design contained in the environmental study report “Front Street Reconfiguration (York Street to Bay Street), Municipal Class Environmental Assessment – Final Report”, dated April 2012 (the “Report”). The project concerns the reconfiguration of Front Street at Union Station (the "Project"), for which the City of Toronto (the "City") is the proponent. The Project is closely related to the revitalization of Union Station, which is also a project of the City. The subject site is located on Front Street between Bay Street and York Street in the City of Toronto. The subject site includes the entire Front Street right-of-way. The Report presents 14 alternative solutions comprised of nine alternatives and five sub-options. The Report ultimately selected alternative 2B (with modifications) as the basis of its preferred design.1 The purpose of this letter is to evaluate the Report’s alternative solutions and alternative design concepts, and ultimately, its recommended (technically preferred) design. These are compared against the Province of Ontario’s and the City of Toronto’s planning policies, plans and guidelines. In our opinion, the preferred design -- particularly with respect to cycling -- does not conform to and is not consistent with the City of Toronto Official Plan or with several provincial policies, plans and guidelines. The proposed inclusion of “sharrows” and unmarked bike lanes, instead of clearly demarcated bike lanes, does not satisfy the tests and other evaluative frameworks under many provincial and municipal planning criteria for infrastructure projects, as described more fully below. The absence of bicycle parking on the Front Street entrance further illustrates the lack of conformity to provincial and municipal cycling-supportive policies, plans and guidelines. Should you require any additional information or have any questions with respect to the foregoing, please do not hesitate to contact the undersigned. Christian Chan, B.U.R.Pl Partner – C2 URBAN PLANNING 1 Report, p. 113. C2 U R B A N P L A N N I N G www.c2planning.com TABLE OF CONTENTS Page SUMMARY OF HOW THE PROJECT AND EA REPORT ADDRESSES CYCLING 1 CONSIDERATIONS SHARROWS 2 TORONTO BICYCLE/MOTOR-VEHICLE COLLISION STUDY, 2003 4 SUMMARY AND EVALUATION OF PROVINCIAL AND MUNICIPAL PLANNING POLICY 4 IN RELATION TO THE RECOMMENDED RECONFIGURATION OF FRONT STREET THE PROVINCIAL POLICY STATEMENT (“PPS”) 6 GROWTH PLAN FOR THE GREATER GOLDEN HORSESHOE 8 PROVINCE OF ONTARIO – MINISTRY OF TRANSPORTATION - TRANSIT-SUPPORTIVE 11 GUIDELINES CONFORMITY WITH THE CITY OF TORONTO OFFICIAL PLAN OFFICIAL PLAN 16 SECONDARY PLANS: RAILWAY LANDS EAST SECONDARY PLAN 18 METROLINX BIG MOVE PLAN 19 METROLINX MOBILITY HUB GUIDELINES 21 LACK OF BICYCLE PARKING AND THE INADEQUACY OF BIKE STATION PARKING 24 CONCLUSION 24 REFERENCES 25 C2 U R B A N P L A N N I N G www.c2planning.com SUMMARY OF HOW THE PROJECT AND EA REPORT ADDRESSES CYCLING CONSIDERATIONS The Report provides that the reconfiguration of Front Street is to create a pedestrian priority zone, while enhancing the cycling environment, and the development of a cycling amenity strategy. The Technical advisory Committee included members from the City of Toronto Transportation Services Cycling unit and stakeholders such as the Toronto Cycling Advisory Committee. The Front Street reconfiguration was identified as a short term priority for implementation as part of the Union Station District Plan; a cycling review was to be included in this recommendation. A Needs and Opportunity review in the Report includes a provision for a more “complete street”, and a balance between motor vehicle, cycling and pedestrian zones. The addition of cycling facilities at Union Station provides for the accommodation of roadway functions and operations, which indicates the application of a balanced approach with respect to addressing potential conflicts within the right-of-way. Furthermore, the Union Station Master Plan and District Plan place emphasis on the integration of cycling and transit for commuting. The Report provides a rationale for alternative solutions, and explicitly states the objective of minimizing overall impacts with motorized traffic, as well as the creation of a safe and convenient cycling environment. In other street configurations presented in the Report, cycling conflicts with pedestrians were identified – with the intention to give the Union Station Plaza a pedestrian priority focus. The Report addresses feedback received with respect to bicycle lanes, with the stated intention that Union Station will increasingly become a cycling destination, in concert with the bike rental (BIXI) station, as well as the private sector providing initiatives such as businesses offering bicycle commuter facilities. The Report recognized these concerns, yet the preferred design provided only a shared curb lane (with sharrows). This is despite the Report’s cycling safety concerns, stating that the occurrence of vehicle parking manoeuvres would take precedence over the safety of cyclists. Non-conformity to Toronto’s Bike Plan was explained: that the intent of the design was to be more pedestrian-oriented to minimize pedestrian crossing distances and roadway widths; however, full motor vehicle access was provided for in the Technically Preferred Design. Some comments on alternatives designs by participants and stakeholders supported better cycling infrastructure. The Report dismissed those concerns, so that the reconfiguration could provide a more “pedestrian oriented design”. The Report stated that the addition of bicycle lanes would widen the roadway, thereby increasing the crossing distance for pedestrians. As such, the sharrows were proposed in the Technically Preferred Design simply to remind drivers to be aware of cyclists. The Technically Preferred Design includes the introduction of a signed bicycle route with shared curb lane outside the mid-block crossing area. Overall, the Technically Preferred Design provides for a 4.7 metre wide travel lane on Front Street, to be signed as a shared bicycle route and 3 metre wide lay-by areas along the curbs. The City of Toronto has road design guidelines that provide 3.0 metres of lane-width for an arterial road; so there are 1.7 metres available for a clearly demarcated cycling lane. It is noted that the design intent of safety is provided for with the provision of visual cues such as pavers of differing colours, in order for cyclists, drivers and pedestrians to move with caution throughout the area. 1 | P a g e C2 U R B A N P L A N N I N G www.c2planning.com The Report explicitly states that the purpose of the Environmental Assessment is for the reconfiguration to result in better coordination of all transportation modes, including cycling. It was noted in the stakeholder consultations that there were concerns regarding the provision of bike lanes as Front Street will be increasingly used by cyclists as a result of the Union Station Revitalization. Further on in the Report, Phase Three consultation activities also included concerns about the lack of bike lanes and continued concerns regarding “sharrows.” The concerns of some stakeholders regarding cyclists having a dedicated lane on Front Street, as opposed to sharrows, are that the cyclist may “race” through their space, endangering pedestrians. It was noted in the Phase Three consultations that the Fairmont Royal York Hotel had concerns with the plan encouraging increased bicycle traffic on Front Street, and wished that cyclists are redirected away from the Hotel for their patrons’ safety. Redcliff Realty, the lead lessee of Union Station, shared concerns about cycling safety. It is important to note that the July 5 2010 “Changes to Front Street at Union Station, Questions and Answers, Public Information Centre #1" did not address any questions in regards to the provision of bike lanes as part of the reconfiguration. Comment forms for the Public Information Centre #2 of November 3, 2011 provided that from the vehicle driver perspective, they liked sharrows as the best way to share the roadway. There were no categories that provided the cyclist perspective with the ability to provide comments; the comments were exclusively framed around the perspectives of drivers and pedestrians. In review of the configurations provided in the Report and in reference to our commentary as maps and visual submissions, Figures 7-1, 7-2, 7-3, and 7 – 4 all show what are known as “Sharrows” to indicate some form of right-of-way for cyclists in the Front Street Reconfiguration. Section 7.1, Figure 7-5, 7-6, and 7-7 show the Technically Preferred Design’s recommended typical cross sections. SHARROWS The Report identifies that its solution for providing cyclists with a safe right-of-way on Front Street is through the design intervention of a recent Transportation Services practice of placing quasi bike lanes, called “sharrows” or shared lane markings, on roads. In order to conceptualize the implication of these sharrows, it is important to explain what they are, their development and appropriate use – in relation to their evaluation against provincial and municipal planning principles. Sharrows are a type of bicycle lane marking used on various Toronto streets. They are a recent addition to the inventory of cycling interventions that are meant to provide cyclists with increased safety placed on right-of-ways in the City of Toronto. In 2004, San Francisco pioneered the implementation of sharrows on roads as an indication to drivers of cyclist access to the entire right-of-way, in the direction indicated.

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