Letter to Stantec written by resident Doug Charles
We Haven’t Finished the First City, Why Start Another with 546 Acres Supporting a Parking Lot with Attached Hospital?
Section A: Summary
The hospital committee, advised by Stantec Consulting, attempts to obligate the city for zoning changes for the 60 acre hospital site, as well as changes to development plans for 546 acres. Despite the need for hospital expansion, there is no need to violate the intent of most city plans, based on provincial planning policies.
Plans for the Sandwich South Secondary Area are based on future growth needs for residential areas, employment areas and/or institutional space. The population has remained relatively stable since 1970, and there are no predictions significant growth for 30 years, beyond that any prediction is purely speculative.
I will however speculate that when hospital regeneration is necessary or desired, in perhaps 50 years, this will still be considered a poor location relative to the population. Hospital regeneration is used to excuse the desire for 60 acres when the site selection states 40-50 acres is preferred but less may be considered. Surface parking another excuse for lot size, appears to cover over half of the scale conceptual site diagram (attached). The hospital appears to fill only about one fifth of the diagram.
An appropriately located hospital with a parking garage on 30 acres would be preferable to the citizens over a new 546 acre subdivision to support a parking lot with attached hospital. Allowing development surrounding the hospital would be breach of statutory duty and fiduciary responsibility.
Section B: Reasons for Zoning and Plan Amendments
The request by the hospital to change agricultural zoned land to institutional zoning, and to forego city and provincial planning policies for 546 acres total development, is an arrogant demand for exemption from municipal and provincial policy, and an assertion this is the only logical site.
David Musyj stated “This zoning change process is routine in developments of this nature; it is similar to what would have been required for many of the sites proposed for a new hospital.”1 The development of a low population density area into a whole 221 hectare subdivision roughly the size of downtown, the heart of Sandwich town, Forest Glade or Devonshire Heights, is hardly a routine institutional request. This will not only have dramatic effect of the chosen area but the rest of the city.
Assume an opposite scenario were true; that they chose a traditional location in a high density area but had requested control of development for the surrounding area so that as buildings vacated zoning was to change and further development discouraged. Zoning might be considered routine, but citizens would expect council to reject the entire proposal. That is essentially the same as what they are requesting: that development of the entire city be shifted to suit their demands.
The reasons for amendments to suit this particular location deemed necessary should be sound in terms of the triple bottom line: socially, environmentally and financially. The request for proposed (RFP) sites anywhere within the catchment (service) area suggests any location would do, provided it passed the criteria. The proposed site however was chosen based on criteria that now require additional construction, changes, or amendments to meet the conditions of that criteria.
1) http://www.wrh.on.ca/Site_Published/AcuteCare/RichText.aspx?Body.QueryId.Id=73763&LeftNav.QueryId.Categories=774
Section C: Site Selection Criteria
In the following paragraphs words in bold italics refer to site criteria used.
Zoning and Official Plan Designation are the present subject of review, typically requiring routine amendments, but the location is far from a routine choice. Most hospitals are located based primarily to reflect the Service Catchment Area, built among high density populations within the existing city framework. Building a hospital where there are no people is impractical. If this development were approved, and possibly successful, a medium density population may develop within the area that is still isolated from other densely populated areas.
This isolation prevents smooth connections for Site Amenities and User Access. The location next to the airport will maintain isolation for user access into the future. The location of the only ER and hospital next to an airport, and on the opposite side of the densest populations, just seems intuitively wrong in terms Proximity to existing EMS / Police /Patient Transfer Sites / Disaster Preparedness.
Transit Routes. The site is approx. 3 km from existing transit routes which will have to be added or adjusted, along with adjustments to other routes at municipal expense. For the user however transit is a poor option: it is not city-wide 24 hr, travel times are lengthy, and includes a user fee.
Safe and convenient access for pedestrians / bicycles / e-bikes; Relationship to other supportive Institutions; Distance to United States Border Crossing; Neighbourhood Compatibility The remote location defeats any idea of non-vehicular transport for most. It is 3.5 km from Walker and Cabana Rds., a 45 min. walk by itself in addition to whatever travel time to that intersection. The location does not provide proximity to supportive institutions or the U.S. border. Nor should it have been ranked on Neighbourhood Compatibility, there is no neighbourhood.
Servicing (Established or Potential, Redundant Services for Electrical and Water required) Roadway capacity Arterial / Collector Road Access The isolated, remote location also has insufficient current servicing for the hospital, and there would be no reason for increase servicing otherwise. The Arterial and collector roads will forever be hindered by the airport. Plans to include services to the site would be a fiscal drain on the municipality and contrary to Provincial Policy Plan 1.6.1, 1.6.3.a.
Heritage and Environmental Features (Rivers / Streams) / Archaeological; Vegetation; Protected Wetlands: Heritage and environmental concerns are misdirected. These were only addressed as impediments to construction during site selection. A healthy community was not the priority here. Most other locations would equally meet these criteria.
Expansion Scenarios; Flexible Site Development /Campus Planning Scenarios; Parcel (Shape and Geometry); As far as ease of construction and possible expansion the site excelled at these four criteria. However, ease and lower cost of construction for the hospital comes at a cost to both city finances and the healthcare of the community.
Helicopter Flight Potential / Proximity / Access to Fixed Wing Aircraft Landing; Impact of Restrictions (By-laws, Rights-of Way, Easements); Two Road Frontage (Established or Potential); Visibility; Topography Servicing; Drainage; Wind; Noise; Air Quality: It is not surprising Helicopter Potential was highly ranked here but many sites could achieve the same potential. The other criteria that have minimal relevance to construction or to healthcare specifically at most locations in around the region although there is a need for them to be considered.
Parcel Size (including future growth) was also considered for ease of construction over community or healthcare needs but the public kept hearing 60 acres were preferred and almost essential. There is no mention of 60 acres in the site criteria, 40-50 acres are the preferred range but less would be considered. The reason given are government commitment for up to a 100 years and for future replacement/renewal. Governments in a democracy change and I’m sure that in 50 or a 100 years this will still not be considered an Ideal location if hospitals still exist by that time.
“…the Ministry favours a minimum area of 40 acres of developable land with 50 acres being preferred. Nevertheless, property less than this favoured or preferred parcel size will be considered.”
Parking Potential: Parcel size seems to have been determined for the sake of parking potential for surface parking, which in turn led to a non-traditional urban location. Parking garages were not sufficiently considered. A ball park estimate would put the cost of parking garages at $60-$90 million for 3096 spaces, making that the overall less expensive option. Estimates for infrastructure costs to the city generally exceed that, but there are additional potential costs such as additional transit services and EMS services as well as serious social and environmental costs.
In addition, insufficient consideration was given to street parking. At the time of writing the current number of on-site parking spaces is a closely guarded secret by the hospital requiring a Freedom of Information request, but estimating from the number spots for disabled persons, there are about 2650 on-site spaces between the two campuses. Using GIS software, there are another estimated 1000 street parking spaces within a 10 minute walk of Met, the number around the Ouellette campus are likely comparable. Using a conservative guess, there are perhaps 250 street parking spaces available for use at each campus. The additional 500 street spaces would put the total at 3150 spaces, slightly more than proposed at the new site, yet currently parking is in short supply.
The remote location prohibits walking or cycling, makes reliance on transit difficult, if available, resulting in more vehicular traffic and thus potential parking shortages. The very reason this site was chosen, surface parking to save to hospital money at the expense of the city, seems potentially problematic.
Provisions for any Allied Services: One criterion I find telling is in the definition:
“…may or may not involve reserves for a medical office building …or smaller components within the Facility such as commercial pharmacy, restaurants or other retail outlets. These facilities should be accommodated on the Site, but may also spur similar development in the neighbourhood”.
Possibly the real reason for the selection, a healthcare mall isolated from other competition.
Site criteria begins on PDF page 44 of the following link:
http://www.wrh.on.ca/Site_Published/wrh_internet/Document.aspx?Body.Id=58779
Section D: Provincial Planning Policy Violations
Allowing development surrounding the hospital would be breach provincial planning policies 1.6.3, 1.6.4, and 1.6.5:
1.6.3 Before consideration is given to developing new infrastructure and public service facilities:
a) the use of existing infrastructure and public service facilities should be optimized; and
b) opportunities for adaptive re-use should be considered, wherever feasible.
1.6.4 Infrastructure and public service facilities should be strategically located to support the effective and efficient delivery of emergency management services.
1.6.5 Public service facilities should be co-located in community hubs, where appropriate, to promote cost-effectiveness and facilitate service integration, access to transit and active transportation.
http://www.mah.gov.on.ca/AssetFactory.aspx?did=10463
An Analogy and Conclusion
As mention earlier there is reason to believe this site was selected for parking and for a healthcare mall, filled with revenue generating potential, along with a hospital. So imagine the response if Stantec was consulting for a more purely private firm and made similar recommendations for a shopping mall.
A business declaring, “We should be allowed to build anywhere we want, the city must allow us to do so because they need this mall” would outrage citizens. Statutory obligations and wisdom would prevent a mall in the far reaches, requiring the city to spend on upgrades to access it, particularly when the equivalent number of stores in the city were forced to close. Citizens would resent the business making demands on the backs of taxpayers, outraged at the city for cooperating and at the loss of business for themselves or neighbours.
How dare the hospital expect changes to development plans for 546 acres when they are only plan to buy 60 acres without development fees? Perhaps if the location were chosen primarily for healthcare needs, rather than arbitrarily for surface parking, ease of construction and possibly a revenue generation monopoly in the area, citizens could accept the costs and losses to the city, but that is far from the case. Very few site selection criteria have much to do with healthcare.
Healthcare needs would have required determining a general area, such as a city ward or a municipality, chosen based on existing population and accessibility, with an eye for possible future changes. Only then could a specific site be found or even pieced together in the near proximity to make it work for healthcare purposes.
It is incumbent upon council to consider their statutory duty and fiduciary responsibility in term of the triple bottom line, social, environmental, and financial costs of the proposal. Removing access to healthcare from the main frame of the city to be replaced with only one primary location, requiring additional travel and the reorganization of the entire city, is just a bad idea. This plan may not happen once successive municipal and provincial governments take over, but allowing the development based on this plan will forever harm the city. For those who plan on being a part of those successive governments, I would highly recommend you oppose this unreasoned plan.
Section A: Summary
The hospital committee, advised by Stantec Consulting, attempts to obligate the city for zoning changes for the 60 acre hospital site, as well as changes to development plans for 546 acres. Despite the need for hospital expansion, there is no need to violate the intent of most city plans, based on provincial planning policies.
Plans for the Sandwich South Secondary Area are based on future growth needs for residential areas, employment areas and/or institutional space. The population has remained relatively stable since 1970, and there are no predictions significant growth for 30 years, beyond that any prediction is purely speculative.
I will however speculate that when hospital regeneration is necessary or desired, in perhaps 50 years, this will still be considered a poor location relative to the population. Hospital regeneration is used to excuse the desire for 60 acres when the site selection states 40-50 acres is preferred but less may be considered. Surface parking another excuse for lot size, appears to cover over half of the scale conceptual site diagram (attached). The hospital appears to fill only about one fifth of the diagram.
An appropriately located hospital with a parking garage on 30 acres would be preferable to the citizens over a new 546 acre subdivision to support a parking lot with attached hospital. Allowing development surrounding the hospital would be breach of statutory duty and fiduciary responsibility.
Section B: Reasons for Zoning and Plan Amendments
The request by the hospital to change agricultural zoned land to institutional zoning, and to forego city and provincial planning policies for 546 acres total development, is an arrogant demand for exemption from municipal and provincial policy, and an assertion this is the only logical site.
David Musyj stated “This zoning change process is routine in developments of this nature; it is similar to what would have been required for many of the sites proposed for a new hospital.”1 The development of a low population density area into a whole 221 hectare subdivision roughly the size of downtown, the heart of Sandwich town, Forest Glade or Devonshire Heights, is hardly a routine institutional request. This will not only have dramatic effect of the chosen area but the rest of the city.
Assume an opposite scenario were true; that they chose a traditional location in a high density area but had requested control of development for the surrounding area so that as buildings vacated zoning was to change and further development discouraged. Zoning might be considered routine, but citizens would expect council to reject the entire proposal. That is essentially the same as what they are requesting: that development of the entire city be shifted to suit their demands.
The reasons for amendments to suit this particular location deemed necessary should be sound in terms of the triple bottom line: socially, environmentally and financially. The request for proposed (RFP) sites anywhere within the catchment (service) area suggests any location would do, provided it passed the criteria. The proposed site however was chosen based on criteria that now require additional construction, changes, or amendments to meet the conditions of that criteria.
1) http://www.wrh.on.ca/Site_Published/AcuteCare/RichText.aspx?Body.QueryId.Id=73763&LeftNav.QueryId.Categories=774
Section C: Site Selection Criteria
In the following paragraphs words in bold italics refer to site criteria used.
Zoning and Official Plan Designation are the present subject of review, typically requiring routine amendments, but the location is far from a routine choice. Most hospitals are located based primarily to reflect the Service Catchment Area, built among high density populations within the existing city framework. Building a hospital where there are no people is impractical. If this development were approved, and possibly successful, a medium density population may develop within the area that is still isolated from other densely populated areas.
This isolation prevents smooth connections for Site Amenities and User Access. The location next to the airport will maintain isolation for user access into the future. The location of the only ER and hospital next to an airport, and on the opposite side of the densest populations, just seems intuitively wrong in terms Proximity to existing EMS / Police /Patient Transfer Sites / Disaster Preparedness.
Transit Routes. The site is approx. 3 km from existing transit routes which will have to be added or adjusted, along with adjustments to other routes at municipal expense. For the user however transit is a poor option: it is not city-wide 24 hr, travel times are lengthy, and includes a user fee.
Safe and convenient access for pedestrians / bicycles / e-bikes; Relationship to other supportive Institutions; Distance to United States Border Crossing; Neighbourhood Compatibility The remote location defeats any idea of non-vehicular transport for most. It is 3.5 km from Walker and Cabana Rds., a 45 min. walk by itself in addition to whatever travel time to that intersection. The location does not provide proximity to supportive institutions or the U.S. border. Nor should it have been ranked on Neighbourhood Compatibility, there is no neighbourhood.
Servicing (Established or Potential, Redundant Services for Electrical and Water required) Roadway capacity Arterial / Collector Road Access The isolated, remote location also has insufficient current servicing for the hospital, and there would be no reason for increase servicing otherwise. The Arterial and collector roads will forever be hindered by the airport. Plans to include services to the site would be a fiscal drain on the municipality and contrary to Provincial Policy Plan 1.6.1, 1.6.3.a.
Heritage and Environmental Features (Rivers / Streams) / Archaeological; Vegetation; Protected Wetlands: Heritage and environmental concerns are misdirected. These were only addressed as impediments to construction during site selection. A healthy community was not the priority here. Most other locations would equally meet these criteria.
Expansion Scenarios; Flexible Site Development /Campus Planning Scenarios; Parcel (Shape and Geometry); As far as ease of construction and possible expansion the site excelled at these four criteria. However, ease and lower cost of construction for the hospital comes at a cost to both city finances and the healthcare of the community.
Helicopter Flight Potential / Proximity / Access to Fixed Wing Aircraft Landing; Impact of Restrictions (By-laws, Rights-of Way, Easements); Two Road Frontage (Established or Potential); Visibility; Topography Servicing; Drainage; Wind; Noise; Air Quality: It is not surprising Helicopter Potential was highly ranked here but many sites could achieve the same potential. The other criteria that have minimal relevance to construction or to healthcare specifically at most locations in around the region although there is a need for them to be considered.
Parcel Size (including future growth) was also considered for ease of construction over community or healthcare needs but the public kept hearing 60 acres were preferred and almost essential. There is no mention of 60 acres in the site criteria, 40-50 acres are the preferred range but less would be considered. The reason given are government commitment for up to a 100 years and for future replacement/renewal. Governments in a democracy change and I’m sure that in 50 or a 100 years this will still not be considered an Ideal location if hospitals still exist by that time.
“…the Ministry favours a minimum area of 40 acres of developable land with 50 acres being preferred. Nevertheless, property less than this favoured or preferred parcel size will be considered.”
Parking Potential: Parcel size seems to have been determined for the sake of parking potential for surface parking, which in turn led to a non-traditional urban location. Parking garages were not sufficiently considered. A ball park estimate would put the cost of parking garages at $60-$90 million for 3096 spaces, making that the overall less expensive option. Estimates for infrastructure costs to the city generally exceed that, but there are additional potential costs such as additional transit services and EMS services as well as serious social and environmental costs.
In addition, insufficient consideration was given to street parking. At the time of writing the current number of on-site parking spaces is a closely guarded secret by the hospital requiring a Freedom of Information request, but estimating from the number spots for disabled persons, there are about 2650 on-site spaces between the two campuses. Using GIS software, there are another estimated 1000 street parking spaces within a 10 minute walk of Met, the number around the Ouellette campus are likely comparable. Using a conservative guess, there are perhaps 250 street parking spaces available for use at each campus. The additional 500 street spaces would put the total at 3150 spaces, slightly more than proposed at the new site, yet currently parking is in short supply.
The remote location prohibits walking or cycling, makes reliance on transit difficult, if available, resulting in more vehicular traffic and thus potential parking shortages. The very reason this site was chosen, surface parking to save to hospital money at the expense of the city, seems potentially problematic.
Provisions for any Allied Services: One criterion I find telling is in the definition:
“…may or may not involve reserves for a medical office building …or smaller components within the Facility such as commercial pharmacy, restaurants or other retail outlets. These facilities should be accommodated on the Site, but may also spur similar development in the neighbourhood”.
Possibly the real reason for the selection, a healthcare mall isolated from other competition.
Site criteria begins on PDF page 44 of the following link:
http://www.wrh.on.ca/Site_Published/wrh_internet/Document.aspx?Body.Id=58779
Section D: Provincial Planning Policy Violations
Allowing development surrounding the hospital would be breach provincial planning policies 1.6.3, 1.6.4, and 1.6.5:
1.6.3 Before consideration is given to developing new infrastructure and public service facilities:
a) the use of existing infrastructure and public service facilities should be optimized; and
b) opportunities for adaptive re-use should be considered, wherever feasible.
1.6.4 Infrastructure and public service facilities should be strategically located to support the effective and efficient delivery of emergency management services.
1.6.5 Public service facilities should be co-located in community hubs, where appropriate, to promote cost-effectiveness and facilitate service integration, access to transit and active transportation.
http://www.mah.gov.on.ca/AssetFactory.aspx?did=10463
An Analogy and Conclusion
As mention earlier there is reason to believe this site was selected for parking and for a healthcare mall, filled with revenue generating potential, along with a hospital. So imagine the response if Stantec was consulting for a more purely private firm and made similar recommendations for a shopping mall.
A business declaring, “We should be allowed to build anywhere we want, the city must allow us to do so because they need this mall” would outrage citizens. Statutory obligations and wisdom would prevent a mall in the far reaches, requiring the city to spend on upgrades to access it, particularly when the equivalent number of stores in the city were forced to close. Citizens would resent the business making demands on the backs of taxpayers, outraged at the city for cooperating and at the loss of business for themselves or neighbours.
How dare the hospital expect changes to development plans for 546 acres when they are only plan to buy 60 acres without development fees? Perhaps if the location were chosen primarily for healthcare needs, rather than arbitrarily for surface parking, ease of construction and possibly a revenue generation monopoly in the area, citizens could accept the costs and losses to the city, but that is far from the case. Very few site selection criteria have much to do with healthcare.
Healthcare needs would have required determining a general area, such as a city ward or a municipality, chosen based on existing population and accessibility, with an eye for possible future changes. Only then could a specific site be found or even pieced together in the near proximity to make it work for healthcare purposes.
It is incumbent upon council to consider their statutory duty and fiduciary responsibility in term of the triple bottom line, social, environmental, and financial costs of the proposal. Removing access to healthcare from the main frame of the city to be replaced with only one primary location, requiring additional travel and the reorganization of the entire city, is just a bad idea. This plan may not happen once successive municipal and provincial governments take over, but allowing the development based on this plan will forever harm the city. For those who plan on being a part of those successive governments, I would highly recommend you oppose this unreasoned plan.
Looking to read more? See CAMPP's analysis by clicking here.