Bonus entry 5: My submission to Waterfront Toronto Quayside development consultations

Note: Waterfront Toronto’s initial consultations on Sidewalk Labs’ 1,496-page Master Innovation and Development Plan ended yesterday. The results will be used in some way to inform something that Waterfront Toronto has planned for the Fall. Maybe it’ll be a report on the feedback itself, as indicated in its Note to Reader. Maybe it’ll be input into its official response to the MIDP (which is weird since the Plan Development Agreement joins Sidewalk Labs and Waterfront Toronto at the hip in the development of the MIDP, but, you know, whatever). Or maybe it’ll be used to “design the second round of public consultation planned for this Fall.” Or maybe all of them! Or none of them! It’s all very TBD, which is probably not the best look for an organization that might want to convince the public it can manage a multi-billion-dollar smart-city project.

Anyway, since I’ve been liveblogging the MIDP it made sense for me to submit something. I’m not yet finished the report; I have a backlog of about 20 more posts at the moment (it’s a loooong report) but still have about 200 pages to go. Since Waterfront Toronto’s surveys don’t really allow for an easy way to get at the fundamental problems with the MIDP. I also didn’t feel like wasting so much time filling out an anonymous survey (that the only way to participate online is anonymously is a problem in itself).

So I emailed them my views on the project. I have no idea whether they’ll be accepted, arriving as they did in such an unorthodox manner.

Anyway, for the record, here’s my take on the MIDP, as someone who’s tried to pay very close attention not only to the report but the context in which it was written. In short, I believe the MIDP goes far beyond the RFP and fails to deliver a Quayside-only development plan. Between this failure and multiple process and substantive issues, the MIDP should be rejected.

Submission to Waterfront Toronto Quayside development consultations

Dr. Blayne Haggart
Associate Professor, Department of Political Science
Brock University
July 31, 2019

This submission is based on an almost-complete review of Sidewalk Labs’ Master Innovation and Development Plan. After having spent three weeks reviewing the Plan (chronicled on my blog), I have read to page 63 of Volume 3, or page 1,313 of the overall consolidated document. In this submission, I address fundamental problems with Waterfront Toronto’s consultation process; the inadequacy of Sidewalk Labs’ proposed plan when measured against Waterfront Toronto’s original Request for Proposals; and some of the more problematic aspects of a poorly thought-out development plan.

For the reasons discussed below, I strongly recommend that Waterfront Toronto reject Sidewalk Labs’ Master Innovation and Development Plan and sever its relationship with this company. If Waterfront Toronto remains interested in pursuing an innovative smart-city community plan, it must pursue the internal capacity to develop and evaluate such plans.

Flawed consultations process

This submission is lodged with the recognition that the consultation process that Waterfront Toronto has initiated to review this project is both compromised and fundamentally flawed. These flaws go beyond the substantive issues addressed in Waterfront Toronto’s Quick Survey and its Substantive Survey. For this reason, I am submitting a written brief, with my name attached, rather than filling out an anonymous survey.

Lack of review time for initial consultations

Sidewalk Labs released its Master Innovation and Development Plan (MIDP) on June 24. Waterfront Toronto initiated two rounds of consultations, one ending July 31 (today) and the other to be held sometime in the Fall. The first round of consultations, which consisted of a series of public meetings and information sessions held between July 8 and 25, and an anonymous short and long online survey.

The MIDP is a long, complex document that, if implemented, would involve extensive multi-level governance reforms and the implementation of currently non-existent technologies, or technologies that have not yet been proven at scale. It is based on assumptions regarding the future development of cities – such as the appropriate balance between cars (self-driving or otherwise) and public transit – that are policy-based, not technological. It invents terms, such as “urban data,” that are not in wide use (beyond these documents) and whose meanings are thus unclear.

It is, to be blunt, ridiculous bordering on absurd that Waterfront Toronto began its “Public Consultations on Sidewalk Labs’ Proposal for Quayside” only two weeks after the report was released, in the dead of summer. I have been reading, writing and blogging about it nearly non-stop for the past several weeks, and I will likely finish reading the whole thing tomorrow (August 1, one day after the first deadline). As for Sunday, July 28, Bianca Wylie, probably the person who’s paid the most attention to this file outside of Waterfront Toronto and Sidewalk Labs, had not yet finished reading and analyzing it. Choosing an arbitrary deadline 38 days after this report was released, in the summer, is a recipe for shallow or prejudged hot takes. Any public information that Waterfront Toronto will get from this process will be relatively useless.

As a barometer of public opinion, moreover, the anonymous nature of the surveys leaves the system open to being gamed by pro- or anti-Quayside partisans, will make it similarly useless.

Minimizing effective public input

What’s more, the exact nature of the Fall consultations and the overall timeline remains frustratingly opaque. Waterfront Toronto’s website cryptically notes: “Feedback received over the summer will help us design the second round of public consultation planned for this Fall.”

However, it does not make clear what the exact topic of consultation will be. Waterfront Toronto’s Note to Reader, released days after the MIDP as a seeming first reaction to the MIDP, merely states that submissions received up to July 31 “will be summarized and shared publicly by the end of August 2019.”

A July 17 Financial Post article that sources two senior Waterfront Toronto officials, reports that: “In September, Waterfront Toronto will publish a response to the MIDP pulling together criticisms and concerns based on public commentary and responses from the various levels of government.” Then, “After Sidewalk Labs receives the formal response document from Waterfront Toronto, the public agency says it will hold a second phase of public consultations toward the end of 2019 to solicit public feedback on any substantial changes that Sidewalk makes as they turn the draft MIDP into a final document.”

Finally, in correspondence with Waterfront Toronto, I’ve been told that the timing of the consultations is “TBD.”

This lack of clarity for consultations on a multi-billion-dollar project is profoundly disturbing. Is Waterfront Toronto merely writing a report on these summer consultations? Is it designing consultations based on the summer sessions? Is it preparing a formal September response to Sidewalk Labs, with the public only allowed full voice on a final, take-it-or-leave-it proposal?

Based on the Financial Post story, as well as the aggressive timelines Sidewalk Labs has proposed for the project (Volume 3, p. 203), it looks like Waterfront Toronto will be basing its formal response to the MIDP on three weeks of flawed (to say the least) summertime “consultations.”

If the Financial Post article is accurate, by delaying substantive public contributions until after Sidewalk Labs has released a final MIDP, Waterfront Toronto is denying the public the opportunity for meaningful feedback on the MIDP, since they will only be commenting on changes Sidewalk Labs would make. And at any rate, these consultations would have to address the quality of and recommendations in Waterfront Toronto’s September report.

At the very least, the process Waterfront Toronto is following needs to be made clear. An informed public’s voice – beyond the July consultations – must be included in Waterfront Toronto’s formal response to the draft MIDP.

Waterfront Toronto’s impartiality

Waterfront Toronto needs to explain the exact nature of its relationship with Sidewalk Labs. As I detail in a blog post, the Plan Development Agreement, which sets out  “a roadmap for the planning phase of the Project involving the preparation and creation of a Master Innovation and Development Plan” (Preamble), requires that Sidewalk Labs and Waterfront Toronto jointly produce the MIDP. However, Waterfront Toronto Chair Stephen Diamond claims, “Waterfront Toronto did not co-create the MIDP.”

This goes directly against what is in the Plan Development Agreement, as well as common sense. From the very beginning, as I detail in the aforementioned post, Sidewalk Labs and Waterfront Toronto have pursued a collaborative approach to governance:

a bold, first of its kind, and innovative approach to city-building to deliver transformative benefits in quality of life to a diverse set of residents, workers, and visitors in Toronto. This requires the collaboration of Waterfront Toronto and Sidewalk Labs to develop the MIDP. (Plan Development Agreement, Schedule J, 1.01(a)))

Diamond’s comments and Waterfront Toronto’s attempts at running a public consultation in the manner that it has comes across as an attempt to present Waterfront Toronto as the independent arbiter. However, the PDA and Waterfront Toronto’s past collaboration on this project render it impossible for Waterfront Toronto to play this role. It would have been far better for Waterfront Toronto to admit that this is a collaborative effort and proceed on those grounds. Instead, it is now very difficult to believe that these consultations are a sincere attempt to gauge public opinion or to incorporate it into the review process.

MIDP an inadequate response to the Request for Proposals

Beyond Scope

The MIDP represents an inadequate, over-reaching response to Waterfront Toronto’s original Request for Proposals. The RFP officially focuses on the 12-acre Quayside Development (RFP, p. 6), although it is envisioned as “a pilot environment for the broader eastern waterfront revitalization” (RFP, p. 14).

The RFP, in other words, clearly saw Quayside as the main focus, with Waterfront Toronto reserving the right to advance Quayside-developed “solutions, processes and partnerships across the eastern waterfront “as those lands become available to Waterfront Toronto (as per the established protocols with the City of Toronto)” (RFP, p. 6).

Instead of a Quayside development that could potentially be rolled out into the entire Eastern Waterfront “as those lands become available to Waterfront Toronto (as per the established protocols with the City of Toronto),” Sidewalk Labs’ MIDP presents a comprehensive plan for developing Quayside and part of Villiers Island, and for regulating and rolling out technology for a much larger part of the Eastern Waterfront, which it terms the IDEA District (Quayside plus what it refers to as the River District). While the MIDP claims that Quayside is the initial development, it is only the initial development in the way that installing a foundation is the initial part of building a house.

Moreover, Sidewalk Labs’ emphasis on bringing Google’s Canadian branch headquarters to Villiers West, which it would own, further suggests the extent to which this is an Eastern Waterfront, and not Quayside, development project. As the urbanMetrics-supplied economic analysis of Sidewalk Labs’ proposal remarks, and as Sidewalk Labs reiterates throughout these 1,496 pages, Google’s presence is designed to be the economic catalyst for this entire project:

Notwithstanding the range of other urban innovations proposed, this initiative alone presents an opportunity to cement the Eastern Waterfront as an innovative new district that could become an industry leader in advancing city-based technologies. (p. 15, emphasis added)

That Sidewalk Labs is not presenting a Quayside development that might be expanded into the Eastern Waterfront, but rather a comprehensive plan for development of a huge swath of said waterfront, is further reinforced by March 6, 2019, comments by Sidewalk Labs CEO Daniel L. Doctoroff. In a Canadian Press interview, Doctoroff indicated that Sidewalk Labs will abandon the entire project if light rail is not extended to the Eastern Waterfront: “At the end of the day, if there is no light rail through the project, then the project is not interesting to us, to be perfectly honest.”

In the MIDP Overview, Sidewalk Labs frames the light rail as part of its Quayside-plus plans to develop at “geographic scale”:

Quayside alone is not large enough to support the financing of the proposed LRT extension, a major, new public work; the density across a larger area is needed to cover the projected cost. (Volume 1, p. 225)

Doctoroff’s comments, combined with Sidewalk Labs’ positioning of light rail in terms of its overall project, make it pretty clear that Sidewalk Labs is not proposing a Quayside development phase, but rather a comprehensive Eastern Waterfront development project, of which Quayside is only one district, not a project in and of itself as envisioned in the RFP.

Based on this failure to follow the RFP, this MIDP should be rejected.

Substantive issues: Brief overview

I will be laying out my analysis of the substantive issues regarding the MIDP on my blog over the next several weeks. Due to the length and varied subject matter of the MIDP, this series will likely run until the end of August 2019. From a general perspective, however, I can make several points.

Overly optimistic proposal

Almost all (if not all; I still have a few pages to go) of Sidewalk Labs’ promised outcomes presented in the MIDP are based on absolutely nothing going wrong with anything. It presents no second-best scenarios, no assessments of the effect of particular parts of the plan not coming to pass. For a proposal that is based on using never-before-tried (either at all or at scale) technologies and convincing the three levels of government to change laws and regulations, the lack of such assessments is reckless.

Some of the most problematic assumptions are:

  • Self-driving cars. This proposal has as a fundamental assumption in its mobility plans that self-driving cars will become a transportation mainstay by 2035. This might come to pass. However, as an engineer once told me, self-driving cars are five years away, and will continue to be for the foreseeable future. Moreover, their arrival would require not only technological advancements, but also policy and regulatory changes that would be made at the national, if not international, level. This fact would leave the success of Sidewalk Labs’ plan dependent on factors outside its (if not fully Google’s) control.
  • A mass timber industry. The emergence of this industry would depend on regulatory changes as well as the industry proving viable at scale. Again, this might happen. Or it might not. Its success lies outside of Sidewalk Labs or Waterfront Toronto’s control.
  • Building currently illegal apartment units. Most of the economic efficiencies that Sidewalk Labs claim would allow it to build cheap affordable housing are based not on technological innovations, but rather on convincing the City of Toronto to change its laws to shrink the size of the smallest legal apartment. My first solo apartment was a miniscule studio in Toronto that could barely fit three people standing up. It was a legal apartment – my landlord was very conscientious. Personally, I can’t imagine allowing the construction of even-smaller apartments, but more to the point, Sidewalk Labs’ attempts to get this concession from the City of Toronto will be sure to attract vehement opposition from housing and tenants’ rights activists.

The main point here is that it would be very easy to imagine one or all of these things failing utterly and completely for reasons almost totally out of Sidewalk Labs or Waterfront Toronto’s control. That Sidewalk Labs does not introduce any plans for such contingencies means that we have to assume that the benefits of its proposals will almost certainly be smaller (perhaps much smaller) than they currently predict.

No cost-benefit analysis

With the slight exception of an analysis of the weather’s effect on outdoor activity, the MIDP does not include any attempts at quantifying the degree of “harms” that its technological solutions (in some cases, quite pricey solutions) are designed to solve. Heated sidewalks may be nice, but what is the current cost of not having heated sidewalks?

A more direct way to make this point is, why should Torontonians divert scarce resources to build the transit link that Sidewalk Labs claims is a deal-breaker rather than build the long-needed downtown relief line? It’s not that the case can’t be made for one or the other; it’s that Sidewalk Labs doesn’t even bother, in the MIDP, to make the case.

Sidewalk Labs’ failure to present such figures means that we have no idea, from reading this report, whether its proposals represent an efficient investment of public money.

Dramatic, inefficient expansion of bureaucracy

Perhaps the most surprising part of Sidewalk Labs’ plan is its proposal to create several new bureaucracies, including one that would either replace or rewire Waterfront Toronto itself.

The surprise comes from the shocking lack of specificity about the financial and human resources that these organizations would need to do the amazingly complex and varied tasks they would be asked to undertake. As it currently exists, Waterfront Toronto does not have the capacity to manage all the tasks Sidewalk Labs wants these new agencies to perform.

How many employees would be needed to run these organizations? Nothing in the MIDP addresses this question.

How much money would be needed to run them? Sidewalk Labs assures us, without providing any specifics, that user fees and a share of taxes can do the job? But this assurance is empty if it’s not accompanied by any kind of analysis.

Given its proposed dependence on user fees, Sidewalk Labs should provide a comprehensive tally of the extra taxes and user fees Quayside/Eastern Waterfront residents and users would be expected to pay.

Neither, in a report single-mindedly fixated on arguing that the Eastern Waterfront and not Quayside is the proper financial and technological scale for this project, is it ever justified (either financially or logistically) why the Eastern Waterfront – a relatively tiny piece of land in the scheme of the entire City of Toronto – is the correct scale for such bureaucratic changes.

Example: The Waterfront Transportation Management Association

The (uncosted) Waterfront Transportation Management Association provides us with a good example of everything wrong with Sidewalk Labs’ bureaucracy proposals.

As a subsection of the Waterfront Toronto-like agency supervising development, it would be responsible for coordinating “the transportation system in the IDEA district by deploying a mobility management system” (pp. 84-85). It would not have much of an effect at the Quayside level (Volume 2, p. 85).

Its roles would be varied, focusing mainly on the operational, technical and administrative:

  • Creating a mobility subscription package
  • Deploying a holistic mobility management system
  • Managing and setting prices for the curbside and parking systems
  • Procuring and operating new technologies, such as adaptive traffic signals, dynamic pavement, freight and deliveries, or other third-party systems and apps
  • Integrating systems with third-party navigation apps
  • Allocating space across the needs of mobility, access, safety, and the public realm
  • Reporting on performance targets related to congestion, mode share, and customer service (p. 86)

It would also:

  • Develop specific guidelines (p. 87);
  • “Oversee planning, operations and maintenance” of all roads, hardware and software for parking, curb and traffic management;
  • Set and enforce parking, curbside and road usage fees;
  • setting speed limits;
  • Manage street closures for construction or events;
  • handle data properly;
  • create a trip-planning interface/app Sidewalk Labs is all keen for;
  • Snow and debris clearing “beyond heated pavement”;
  • Constructing and financing roads or parking facilities; and
  • Run the “advanced mobility management system”.

These are a lot of roles, and it will take many people to fill them. It would require workers to do both physical labour and maintain complex IT systems, systems that are much, much more complex than anything Toronto has today, in part because everything is interconnected.

Again, how much would this type of bureaucracy cost? Can this cost be justified for such a tiny parcel of land?

This is not a concrete plan for an actual organization, but a list of things that Sidewalk Labs needs to be done for its project to work. That Sidewalk Labs has not fully thought this through – that they have not come up with a plan, but some ideas – is suggested by the lack of attention to resources needed.

It is also reflected in the fact that its sole concrete suggestion for a WTMA is that the agency responsible for plowing the roads, maintaining the software, closing off roads for block parties and collecting fees “would include a steering committee with representatives from all three orders of government” (Volume 3, p. 70). It makes less than no sense that this form of governance – a recipe for inaction that contributed to Waterfront Toronto’s inability to move quickly on waterfront development in the first place – be placed at the operational level. As proposed, the WTMA would not be a policy-making body; there would be no need for a tripartite steering committee here.

This kind of thing is Federalism 101. That Sidewalk Labs isn’t aware of this type of politics demonstrates the extent to which this report is not ready for prime time.

Sidewalk Labs as de facto governmental body

Sidewalk Labs sees one of its key roles as the de facto tech and infrastructure standards governor for the IDEA District. This would give it regulatory powers akin to those of a city, as it would determine the standards that residents and businesses would have to adopt.

This is a role that should only be conducted by an accountable body. Sidewalk Labs is not such an organization. Moreover, while Waterfront Toronto or its successor agency would have some official power in this area, nothing to date suggests that the organization is capable of dealing with issues of technological governance. Indeed, the Auditor General of Ontario’s December 2018 report into Waterfront Toronto noted that neither Waterfront Toronto nor the Province of Ontario had sufficient capacity in this area.

In the case of Sidewalk Labs, its involvement in the Eastern Waterfront raises the strong possibility that, as a Google company, it will adopt Google standards and technologies, which may not be the most appropriate for the area. Rather than run a competition to see what type of standard the districts should adopt, as would a normal government agency, in the MIDP Sidewalk Labs says it would implement a Google internet network technology called Super-PON. This proposal, a clear conflict of interest from a Google sister company, should be a harsh reminder that Sidewalk Labs’ primary loyalty will always be to Google. It would be unreasonable to assume that a de facto Google company like Sidewalk Labs would act otherwise. It suggests why it is a very bad idea to put companies in charge of standard-setting: the temptation for self-dealing is too great.

This conflict of interest from Sidewalk Labs highlights the fundamental flaw with the original Request for Proposals: it gave the responsibility for these powers to its private-sector partner. By asking a for-profit company to tell it how it should govern, rather than to help it carry out a plan, Waterfront Toronto abdicated its responsibility to the public.

Unclear data commitments

As I will be covering in my blog posts, Sidewalk Labs’ data commitments are much less than meets the eye. Its definition of “urban data” and “transaction data” serves to obfuscate more salient descriptions of data as “public” or “private.” Its commitment not to sell personal data or to use it for advertising is undercut by its claim that it will only do so if given “explicit consent.” The problem here is that, as Sidewalk Labs defines the term, urban data is data collected in public for which individual consent is very difficult. Consent must therefore come through some kind of collective regulation. This is not how most people would understand “explicit (individual) consent.”

This type of commitment is no commitment at all; at best, it defers the actual discussion about what data can and cannot be collected for another day, once the MIDP has been approved.


This paper represents a very incomplete analysis of issues arising from the MIDP, the process that led to it, and the current consultations process. As already stated, there are sufficient fundamental flaws with this process, as well as with what the MIDP promises to deliver, that it cannot be salvaged.

There is no independence between Waterfront Toronto and Sidewalk Labs. Sidewalk Labs has failed to deliver on what the RFP required. It has failed to fully account for the bureaucratic burden of its proposal while also failing to make clear, explicit commitments on data use. Waterfront Toronto does not have the capacity to implement a smart-city-style project. Finally, the consultation process does not give adequate voice to the public that Waterfront Toronto is supposed to serve. For these reasons,

I strongly recommend that Waterfront Toronto reject Sidewalk Labs’ Master Innovation and Development Plan and sever its relationship with this company. If Waterfront Toronto remains interested in pursuing an innovative smart-city community plan, it must pursue the internal capacity to develop and evaluate such plans.

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