April 6, 2014

To: Madeleine Demers & Lucie Bureau
Cc: Sandra Pecek & Jocelyne Moncion

Hello,

Please find below my comments on:

– the Capital Urban Lands Master Plan, March 2014 draft
– the CULMP Appendices
– the updated NCC Policy for Parkways, March 2014 draft

I would have preferred to share my draft comments with others in the community and send you comments on behalf of the Greenspace Alliance of Canada’s Capital that would incorporate the views expressed by others and reflect their concurrence. The time frame of this consultation simply does not allow that, which is unfortunate.

General

+ That we have before us a draft master plan is, by itself a major accomplishment, given the history of this endeavour. The NCC is to be congratulated for having gotten this far.

+ I am very pleased to see the map on page 12: It so clearly illustrates how the residents of the national capital area ought to think of their urban surroundings, despite the fact that all other authorities do their best to draw jurisdictional lines separating each side of the Ottawa River. The NCC is the only government entity expressing the unity of our region and I am grateful for you doing so.

+ The absence of references to the Aboriginal Peoples’ contribution to the national capital area, including urban lands within the scope of the Plan, is disturbing.

+ I am supportive of the Vision, Mission, Roles and Goals of the Plan (p39).

+ It is not evident what the identification of Capital Realm/Non-federal Capital Realm” (pp66-67) contributes to the Plan. It appears to be just another layer of theorizing.

+ The document takes a long and slow ascent toward the “meat” of the Plan — the land designations and policies. As a veteran document reader, I confess to having been overcome by a sense of numbness reading through the rather abstract descriptions in the first three chapters, only to be confronted once again with more “context” in chapter 4 and the various sections of that chapter which again hover on a level of theory or abstraction that is, frankly, distracting. My spirit was exhausted when it came to the recapitulation in section 4.7 (pp108-114).

+ Much contributing to that esoteric feeling was the absence of specific location references. For the most part, one needs to go to Appendix 3 to see what’s what where. I strongly recommend that you bring specific names and lists into the main body of the Plan, as you already do in the margin for some components.

+ This absence of specific “grounding” is especially unhelpful when, in section 4.4, the Plan finally comes down to Orientations and Guidelines, and Authorized and Unauthorized Uses. Without having the map handy that shows specifically what these Valued Natural Habitats, Capital Parks, and Capital Urban Green Spaces are, it is difficult to make up one’s mind on whether the proposed Orientations etc.are valid or not. Some of the maps on pp92-95 name some of the sites. The references should be complete and comprehensive. I have not found the time to carefully check the section 4.4 proposals against the affected sites.

+ Like anything else done by the NCC and the City of Ottawa (and possibly as well the City of Gatineau), there is no evidence (beyond sweet words) of substantive integration of plans, let alone of realities on the ground. I implore the NCC to show on their maps, even if only in a lighter colour, what facilities exist under municipal jurisdiction. That would be a concrete first step of integrated planning. For example, the vast network of pathways on Ottawa’s maps should be shown alongside the NCC’s. That would provide a very different picture than what the map on p105 shows.

+ Specifically, it would show that the “Other lands” shown on p83 are not as isolated as they appear. It would show that the Pinecrest pathway in fact continues south, encompasses the Woodroffe-Merrivale and Southern Corridors and, east of McCarthy Woods, continues through the Alta Vista Corridor to the Rideau River.

+ I urge the NCC to embrace the Poets’ Pathway concept. It fits under each of the three roles set out for the Urban Lands and the NCC’s mandate: It commemorates a cultural facet of Ottawa that has national importance (the Confederation Poets), doing so in a manner that is appropriate to their contribution (experience of nature), thereby contributing to the region’s quality of life and offering an attraction to visitors from across Canada and the world. A number of markers have already been established (see http://www.poetspathway.ca/ for details). It is high time for the NCC to get on board and provide support for this highly innovative initiative.

+ Doing so would be entirely within the spirit of the NCC’s 2004 report on cultural landscapes (Definition and Assessment of Cultural Landscapes of Heritage Value on NCC Lands [9.5 MB]). Here is an opportunity to extend the range of experiences available to residents of and visitors to the region through an “Associative Cultural Landscape,” combining natural and cultural elements.

A few more detailed comments

+ The title of Chapter 1 does not correspond with the table of contents.

+ The Components map (p21) appears incomplete. E.g., the “green” on both sides of the Rideau River is not shown (compare p26 in Appendix 3). The “double” designation for the Experimental Farm is awkward; the Farm is not recognized in the Legend, hiding under “Cultural Institution.” “Other Green Space” is elsewhere and throughout the rest of the Plan called “Urban Green Space.”

+ Re Other Lands (p33), what is the meaning of the future tense when saying that the Plan “will endeavour to provide clear indications as to the role” that these lands could play? Similarly, on p57, future use and management of the “Other NCC Lands” is said to be clarified in the future, though the veil is lifted somewhat with the reference to “urban consolidation, transportation infrastructure or the development of mixed-use urban environments.” A further ominous signal comes on p97 with the reference to “the current context of Capital and NCC asset rationalization.”

+ The consultation documents ask to indicate what the respondent’s first , second and third priorities area mong the three roles. Such a question does not make any sense to me as the three roles are all equally important.

+ An example of what appears to be theory for theory’s sake: “The Urban Lands holdings are generally designated for several possible uses, with one dominant use” (p59). What is the point?

+ On p66 one is informed that a review of the National Interest Land Mass will follow the completion of this MP and the revised “Plan for Canada’s Capital 2067.” Greater transparency of this review process would be much appreciated. Similarly, on p73 one learns that a new NCC Built Heritage Policy and a new Archaeological Assets Policy are being developed. Concurrent or related policy projects should be stated and explained at the beginning of the document.

+ I have to suspend much disbelief when I read on p70 what standards of environmental impact that proposals received by the NCC have to meet, when I know that the NCC caved in to the City of Ottawa when confronted with a proposal to turn Old Richmond Road through Stony Swamp into a 4-lane divided highway.

+ What is the meaning (on p74, re signage) of the NCC having “permitted the temporary identification of sponsors of the NCC”?

+ I applaud the referencing of international standards or standards developed elsewhere such as ICOMOS (p73) on monuments, Florida (p74) on lighting and, especially, IUCN Class IV (p87) for Valued Natural Habitats.

+ On the Land Designations map (p83), Rochester Field/Maple Lawn should be marked as “Cultural, Historic and Artistic” as most of the attributes described on p91 for such identification apply to it.

+ Map 14 – Capital Urban Green Space Network” (p86) is not much of a network. Here is where green space networks maintained by the municipal governments are most missed. Recognition and acceptance of the Poets’ Pathway would fill several of the gaps!

+ The map on p83 identifies three Special Study Areas but I find no further information about these as such. The map and text on p98 reveal a bit about two of the three and add Booth Street but the Special Study Area east of Tunney’s Pasture remains a mystery. There are no specifics whatsoever in section 4.6 – Special Study Areas.

+ Many times on pp87-90 there is reference to development of ‘Capital Discovery Routes.’ What this refers to is unclear.

+ The description of cultural, historic and artistic functions on p96 does not correspond with the map on p95.

+ There are numerous instances of poor syntax, superfluous words and influence of literal translation from the French. For a fee I’ll send you an annotated copy!

+ Almost no value should be attached to the results of the 2010 on-line survey, completed by just 225 people (Appendix 7). I’m one of these 225 and remember it to be very poorly designed. Unfortunately, the current on-line survey is little better, nor is the Discussion Guide offered to attendees of the public meetings of 25-26 March 2014. The NCC should invest in more professional survey design.

+ In the Updated NCC Policy for Parkways, it is a bit of a stretch to say that the first use of the term “parkway” in 1866 was “during the same time” as the local works of Todd, Holt and Gréber (p6).

+ Lady Grey Drive is not shown on the map.

+ The document recognizes the conflict with the use of the parkways as part of the regional commuter traffic network but then tries hard to deny that role. It is a dilemma that is not solved by this document and may be without solution. Even so, I fully support policy 8.7, that the parkways should put people first. I urge you to stand firm against municipal forces that would want to turn the parkways into nothing more than commuter routes.

+ The categorization Urban / Natural / Waterfront appears to make little sense. E.g., the Aviation Parkway is “urban” only north of Montreal Road, below that it is distinctly “natural.” Similarly, several of the “waterfront” parkways are clearly “urban.”

+ Policy 8.14 fails to note that parkway alignments may have to be rethought in light of environmental concerns. I believe it has been noted before that the John A. Mcdonald Parkway runs too close to the shoreline in places. This Parkway also clearly is a barrier to access to the Ottawa River. I am therefore pleased to read that providing “unimpeded and continuous public access to the Ottawa River shoreline” is a priority endeavour for the short term (p23).

+ Please re-write policy 8.34.

+ I do not support policy 8.36 calling for bicycle lanes at the outer pavement edge of parkways, for reasons of both safety and quality of experience. I support policy 8.48.

+ In this document again there are many instances of poor adaptation from what presumably is the original French text. The subtitles of section 8 are a prime example.

I trust these comments are helpful and would be pleased to receive clarification of any of the questions raised.

Regards,
Erwin Dreessen