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Letter of comment - Riverwalk senior living LOC2018-0143

In light of recent correspondence from residents with concerns over the development proposal at the corner of 5th Street and 25 Avenue ,CBMCA will reprint the letter of comments to the City of Calgary on this file, outlining our position.

Letter of comment - Riverwalk senior living LOC2018-0143

Cliff Bungalow-Mission Community Association

The CBMCA is pro-densification. We believe that inner-city communities each play an important role in accommodating the expected doubling in population over the next 60 years. However, we believe that densification can be achieved under current policies and in sensible ways. At nearly three-times the allowable height, the CBMCA is opposed to application LOC2018-0143 for the reasons described below:

  • We value good planning practices: We strongly believe that it is the City’s responsibility to provide a stable planning regime that provides residents with a sense of security as to what the future of Calgary looks like. The practice of spot upzoning is in direct conflict with this responsibility. Approving the proposed land use amendment effectively implies that the City hands over its planning function to developers, who now are in charge of deciding where increased height is ‘acceptable’ and ‘desirable’. Ad hoc height relaxation introduces a level of unpredictability that is inappropriate from the perspective of community residents, contradictory to good city planning, and could unintentionally set a precedent – moving even further away from a planned approach to sensible densification.

  • Our ARP continues to be a valid planning document: The application is in direct conflict with the objectives, policy and intent of the Cliff Bungalow ARP, which calls for sensible densification and a maximum height of 16 meters on the proposed site. The Cliff Bungalow ARP is the result of a seven-year process, hundreds of person hours and thousands of hours of volunteer capital, and was developed with the intent of accommodating inevitable growth while retaining the essential character and livability. We note that the Applicant questions the validity of the ARP – this is both disingenuous and incorrect. Disingenuous because it shows how little in tune the Applicant is with the community. In June, 2016 the CBMCA organized a community-wide workshop to hear directly from residents what they think of certain planning matters. The majority of respondents (85%) agreed that the ARP should be respected by the City and developers at all times. Of the people that agreed, 64% strongly agree, while 10% of the respondents don’t believe that ARPs need to be taken into consideration at all times. Taken together, these results show that ARPs are still considered valid documents in guiding future developments and conversations with developers. Incorrect, because the Cliff Bungalow ARP has, in fact, been reviewed by Planning and aligned to current LUB 1P2007 and the MDP, and is used by administration as the relevant statutory planning document. Also, the ARP is a values-based document. Those values are still relevant and up to date and very much reflective of the language and intent of the MDP.

  • Densification doesn’t equal tall buildings exclusively: At an average density of 8,945 people/km2, Cliff Bungalow-Mission already is Calgary’s third most dense community, yet its urban form remains ostensibly human-scale in comparison to its peer group (see for example, Chinatown at 8,274 people/km2 and Beltline at 8,999 people/km2). Cliff Bungalow-Mission is one of the most desired communities exactly for that reason – its ability to accommodate many people and small businesses while retaining a sense of place and cultural context. The introduction of excessively tall buildings (Cliff Bungalow currently has no building reaching 45 meters), does not align with these attributes and is likely to compromise the unique character of the community. Tall buildings have few if any benefits. There is a growing body of evidence that shows that they have poor environmental performance, threaten the social cohesion of communities, lead to poorer health outcomes, degrade the public realm and adversely affect the human scale of a city. This is being echoed by community residents. Results from our most recent community-wide workshop show that the majority of respondents (84%) agree that densification (i.e. taller buildings) should happen within existing allowed zoning, as opposed to spot upzoning. Of the people who agreed, 72% strongly agree, while 16% didn’t express real concerns with spot upzoning. This shows to us that height remains a concern and that height relaxation is not desirable when being proposed.

  • We already deliver on the MDP targets: Our community exceeds the MDP densification targets. The amount of people living and working in the community today is 50% beyond what the City asks us to accommodate. And if we would fully build out to existing zoning as approved under the ARP our density would be three times as high as the target. The argument raised by the Applicant that “as this Plan [ARP] no longer aligns with current city-wide objectives, the project team has looked to higher order policy documents including the Municipal Development Plan (2009)…” is simply incorrect and unfortunate, as it wrongfully suggests that the proposed development is necessary to deliver on “higher order policy”.

  • We value honest communication: We raise some concern in relation to the concepts that the Applicant introduces in its external communications for justifying the increased height ( The Applicant suggests that the site across 25 Avenue SW is a proposed Future Comprehensive Plan Area. This is both speculative and misleading, as this appears “self-proposed” and to our knowledge doesn’t have policy backing. We genuinely hope that the City does not make planning decisions based on speculative notions raised by developers and we hope that the Applicant is transparent and truthful about the speculative nature of concepts like Future Comprehensive Plan Areas when it uses this in conversations with external stakeholders.

  • We value facts: We are aware that councillors have argued that increased density should be situated around corridors or main streets. It is disingenuous to consider 25 AVE SW as either a corridor or a main street. The City’s own traffic studies and Main Streets program confirms this fact.

Going forward

This letter is not meant to suggest broad-based opposition to change or to the proposed use – quite the contrary. We’ve been welcoming much change in our community in recent years. Much of this change has been within the parameters of community values, reason and the ARP while contributing to the City’s objective of densification. We also take this development very seriously – that’s why we organized two community-wide workshops for two years in a row – reaching more than 150 community residents in person – with the objective of hearing the community’s stance on planning matters like height relaxation. Taking their input, and based on the rationale above, we strongly believe that the proposed development, at 45 meters and an FAR of 7.5, is out of place and harmful.

The MDP is the guiding document of planning for the City of Calgary. In section 2.3.2 it states as its objective: “Respect and enhance neighbourhood character and vitality. The “sense of place” inherent in Calgary’s neighbourhoods is a function of their history, built form, landscape, visual qualities and people. Together, the interaction of these factors defines the distinctive identity and local character of a neighbourhood.” Currently, the proposed development is surrounded by two to three story residences and businesses. The site also acts as a transition from the commercial area on 4th Street to the east and a gateway into the community from Elbow Drive and 4th Street to medium height residential use. There are strong indications that the scale of the suggested development is not compatible with the surrounding neighbourhood and the objective of the MDP.

We welcome conversations with the City and the Applicant to envision collectively what the proposed use could look like, while celebrating and respecting the community context and MDP objectives. For example, if the Applicant is set on a 45 meter building, we would be happy to explore opportunities south of 25 AVE SW (on the Mission side), or as part of policy in the concept plan for the Holy Cross site – areas where the proposed development would be supported by existing zoning.

We would also like to invite you to read our attached community workshop “What we heard” documents, as a testament to our community engagement efforts which figure prominently in imagineCALGARY, the MDP and the Cliff Bungalow ARP.

Kind regards,

Sander Jansen

Director, Development and Planning Committee

Cliff Bungalow-Mission Community Association

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