Mr. Chairman and Members of the Commission:
I would like to make some general remarks about the CD Zone proposal and then spend the remaining time addressing the issue of environmental sustainability as it relates to the proposal. If implemented this proposal will result in a dramatic change in our present city character of being a friendly, livable small to mid-size city to that of becoming a big-city overnight with the introduction of a big city downtown. The major factors that would lead to this change are the excessive building heights and densities found in the CD Zone which are far beyond what is presently found in the downtown.
Thank you.
Our Downtown Plan which is the basis of the C-7 zone allows for building heights in the four block area under consideration of 6 storeys along the periphery of the area with a smaller portion along Lawrence and Leon Avenues at 12 storeys. The C-7 Zone allows a building height of 44 metres or between 12 and 14 storeys and a maximum density of 9.0 FAR. In a report on the Doyle Avenue highrise presented to the Commission last week, the Planning Department acknowledged “The FAR [in this zone] was intentionally set high with the expectation that no development would ever approach this upper limit.” In other words, it was never intended that any proposal be built out to an FAR of 9.0. The City and its consultant have shown you diagrams comparing the appearance of the proposed CD Zone to a representation of what the C-7 Zone would look like built to a density of 9.0 FAR. Given, what I have just reported, I would like the Commission to disregard this comparison because it is based on the faulty assumption of an unrealistically high density that was never intended for zone.
The present Downtown Plan remains in force until it is revised which has not yet been done. Accordingly, the public has every right to expect the proposed CD Zone to conform to the present Downtown Plan until City Council decides to revise it which it has not yet done. Therefore, it does not follow proper planning procedures to consider this CD Zone which is inconsistent with the existing DT Plan until the latter is revised with the full participation of the public. I would urge the Commission to instruct City Council to revise the Downtown Plan prior to considering the CD Zone.
Because of the time restriction that I am under, I would like to use the remaining time to address the issue of whether or not this project is environmentally sustainable particularly from the perspective of energy consumption and greenhouse gas emissions. The City claims that the proposed CD Zone is sustainable because it is near shopping and transit, is of high density, and incorporates green construction and technology. Let’s look at the claim that being of high density contributes to sustainability.
A recent study by CMHC revealed that a typical high rise apartment unit consumes more energy than any other type of housing unit including mid-rise apartments and single family homes. A study by the Australian national government showed similar results. Furthermore, the Australian study showed that highrises were responsible for 40% more greenhouse gas emissions than mid-rise units, 60% more than low-rise units, and about twice that of townhouses and villas.
The City claims that this project is sustainable in terms of energy because it is incorporating green building techniques and that the project is to a LEED gold standard. But how much does this mean in practical terms? The reasons given for why highrises use so much energy are because of the extraordinary heating and cooling needs of these buildings due to their unprotected exposure to cold winds in the winter and the hot sun in the summer. Many LEED points are given for things such as the fact that the project is near employment and shopping, but this will not by itself reduce the energy consumption of the building.
Montreal-based planning consultant Martin Laplante has said of LEED, “More and more architects are coming out and saying out loud what a lot of people have thought all along. Getting LEED certification is good PR but not necessarily a good way to preserve the environment. … The fact that the building is of a form that wastes huge amounts of energy is not a big deal as long as you have a long list of things that save energy, like bicycle racks. Having solar panels is a huge publicity boost and LEED points getter, even though it makes less impact to energy use than, say, the design of windows. Building two ordinary four story buildings is a lot more environmentally friendly than one 8 storey one, but it doesn’t get you LEED certification. You get that by building the inefficient building then adding gimmicks until you collect enough points.”
As an average highrise unit uses more energy and is responsible for more GHG emissions than low-rise or mid-rise buildings and if we dramatically increase densities as is proposed in the CD plan, that would then allow more of these inefficient units to be located in a given area. For example, this project with its approximately 1900 residential units would emit twice the GHG emissions as a project of one half the density and three times the emissions as a project of one-third the density. So with get hit with a double whammy of energy inefficient units and lots of them.
The City is applauding itself for its “smart growth” design and the fact that energy is being saved as residents are closer to shopping and employment. But what is the relative contribution of residences and transportation to overall energy consumption and GHG emissions? For 2005, Natural Resources Canada reported that the total energy used in that year for space heating in homes was greater than all the energy used by cars in the country and that doesn’t even include the energy used for water heating, appliances, lighting and space cooling. In a presentation to Kelowna City Council on April 7 of this year, Sustainability Action Plan committee member Randy Cleveland reported that buildings are responsible for 50% of all energy consumed in North America and estimated that here in Kelowna buildings are responsible for almost double the GHG emissions from transportation fuels. Therefore, it is apparent that we should be paying at least as much attention to the type of structures that we build as to their spatial organization.
And I haven’t even begun to address the topic of the urban heat island effect which is caused by packed concentrations of concrete, asphalt, steel and glass, concentrations such as found in highrise structures. The heat island effect has been said to be a contributor to global warming. Considering their impact on energy use, GHG emissions, and the urban heat island effect, can highrise structures be said to be sustainable? Definitely not!
The environmental problems posed by highrises have caused environmentalist James Howard Kunster and world-renown architects Susan Roaf and Nikos Salingaros to become harsh critics of highrises and high density cities and advocates that building height be kept to a maximum of between 6 and 8 storeys. But I don’t want the Commission to just take my word for it. I would like to ask the APC to request that the City commission a study on the energy consumption and GHG emissions of the proposed CD Zone and to compare that to the energy consumed and GHG emitted by buildings of between 6 and 8 storeys height. Last week the Governor’s Office of Planning and Research for the State of California issued a technical advisory instructing approving authorities in that state to quantify or estimate GHG emissions for all proposed plans and projects and to identify project alternatives or impose mitigation measures. California’s environmental policies have become a model for those of the Campbell government in British Columbia and it’s just a matter of time before the same requirements will be found here. I ask the Commission to be proactive and recommend that such a study be done now.
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