This Volume is essential reading for anyone wanting to cut through Sidewalk Labs’ PR hype and see exactly what Sidewalk Labs is proposing. For those of us foolish to had read the whole thing front-to-back, it’s a distillation of what we’ve read before.

These final five posts will highlight those issues that stood out to me as being the most significant, or whose importance I hadn’t previously fully understood. This first one is a long one, because it’s time to end this series. Let’s get to it.

Previous Master Innovation and Development Plan liveblog entries and relevant documents available here

This chapter discusses a proposal for the consideration of government to achieve these aims by designating a public administrator with the development authorities needed to administer a new targeted innovation strategy for the IDEA District. (p. 48)

Introduction (pp. 52-61)

It’s telling that this section is targeted at the “IDEA District” level, rather than at Quayside, with the rest of the waterfront as a the secondary objective. This proposal’s driving theme is “IDEA District or bust.”

The IDEA District would have “three essential components,” discussed in the rest of this chapter (p. 56):

• A public administrator

Mandate: “oversee and steer key real estate, infrastructure, and technology decisions — all with a focus on better addressing the core urban challenges facing Toronto.”

Its mission would be economic-focused: “promote innovation and development within the geography”

• A modified regulatory framework

In other words, it would be subject to its own particular laws and regulations. This would involve changes to various laws at all three levels of government. It would also require the introduction of new regulations specific to this area.

In other words, Sidewalk Labs – the brains of this outfit – is looking to convince the three levels of government not only to change their laws to suit their needs; it is looking for the right to set its own rules and regulations, in the guise of its Innovation Design Standards Guidelines.

• Financing mechanisms

Fees, development charge credits, local governments ponying up cash, “the use of local land proceeds,” and, potentially, tax-increment financing.

In short, this is gonna cost the Toronto taxpayer.

Confusing geography

I just figured out that the River District is the IDEA District minus Quayside and Keating West. (p. 59)

Keating West is included in all the area-level results predicted by Sidewalk Labs. So why do you have something called the River District? So confusing.

Every time I see “could,” I also see, “or maybe something else will happen. Who knows?”

I thought the purpose of a “plan” was to offer a proposal to do something specific:

The IDEA District

could be established through a Community Improvement Plan (CIP). (p. 61)

Incrementalism?

Quayside, then Villiers West, then the rest of Sidewalk Labs’ desired land. (p. 61)

The decision to move forward would involve

hitting certain performance targets tied to Waterfront Toronto’s priority outcomes … (p. 61)

Outcomes that, per the RFP, Sidewalk Labs was given the responsibility of setting. The administrator might be administering the test, but the student chose the questions and the grading rubric.

When it comes to setting my final exams, I will not be offering this innovative, imagineered option to my students.

The Everything’s Going to Work Perfectly school of urban planning

For analysis purposes, the MIDP assumes that all private landowners opt in to the IDEA District. (p. 61)

Part 1: IDEA District Component 1: A Public Administrator (pp. 62-71)

In which it is proposed that a public administrator that may or may not be Waterfront Toronto be given many responsibilities (p. 62).

“Specifically, the public administrator should be granted the authority to:

1. Set innovation and development objectives for the IDEA District;
2. Impose additional requirements on developments within the district, consistent with the objectives described in Item 1;
3. Determine whether new developments can access the regulatory relief approved for the district;
4. Perform precinct and infrastructure planning for waterfront development;
5. Certify development and construction permit applications before their submission to city agencies;
6. Develop a master transportation and infrastructure plan for approval by relevant city authorities, in phases, and give final approval before construction;
7. Receive and direct infrastructure contributions for the infrastructure proposed for, or built in, the district; and
8. Enter into and oversee agreements with developers, vendors, and partners, including Sidewalk Labs as Innovation and Funding Partner.”

One of the big problems with Waterfront Toronto, as the Auditor General of Ontario laid out in his report, is that its structure and lack of authority impeded its ability to actually develop the waterfront. In this section, Sidewalk Labs says it will attempt the neat trick of providing the public administrator (which may or may not be Waterfront Toronto) with “a greater ability to collaborate with all orders of government to streamline the development process and advance an integrated innovation strategy” (p. 63) all the while not displacing current city, provincial, or federal authority.

After reading this page over several times, I’m not sure how what Sidewalk Labs proposes would break this gridlock. It seems to be based on “granting the administrator [which may or may not be…] a clear mandate and the tools to be successful” (p. 63). Which seems to be simply stating the obvious. I would think the only way you could break this gridlock, as the Auditor General seemed to note in his discussion of a similar agency in Winnipeg, would be by granting decisive powers to the administrator (#WMOMNBWT). It comes down to authority. If you don’t have it, you’re reduced to begging and cajoling.

Public administrator role in planning and implementation (pp. 64-67)

The public administrator (WMOMNBWT) is asked to do A LOT: “to oversee a comprehensive innovation and development strategy,” with the goal of cultivating and expanding “the diverse ecosystem of real estate developers, service providers, employers, design firms, public agencies, research institutions, non-profits, and others — all working together in the IDEA District to advance job creation and economic development, sustainability and climate-positive development, housing affordability, new mobility, and urban innovation.” (p. 64)

Let’s leave aside the fact that this paragraph assumes a great deal more unity of purpose among diverse entities than is observable in the real world.

Planning would be done with the City of Toronto (a non-exhaustive list of agencies is provided) (p. 64).

The “planning deliverables”:

• An Infrastructure and Transportation Framework Plan “for areas of the IDEA District with no existing infrastructure master plan” Question: Would the public administrator (WMOMNBWT) coordinate with the city to ensure compatibility?
• Innovation Design Standards and Guidelines. Although, as we’ll learn below, despite this formal authority, Sidewalk Labs would play a key role in creating these. And based on Waterfront Toronto and Ontario’s (and, I’d guess, the Government of Canada’s) lack of expertise in the area of smart-city development, these rules would be Sidewalk Labs’ to write. (p. 64)
• Precinct plans and implementing bylaws. This would seem to insert Waterfront Toronto and Sidewalk Labs formally into the City of Toronto bureaucracy. I’d love to hear more from municipal government experts about whether it is normal to allow outside agencies and companies bylaw-setting powers. From my vantage point, given Sidewalk Labs’ central role in planning in its IDEA District, this would be a key vector for the privatization of the bylaw-setting process, as well as an indirect way for the federal and provincial governments (via Waterfront Toronto) to similarly set municipal bylaws.

Sidewalk Labs doesn’t want to wait for bylaws to be passed

The administrator may also elect to permit the development of certain land parcels following the completion of a precinct plan and prior to the adoption of implementing bylaws, where such development is in the public interest and is consistent with the Precinct Plan. (p. 65)

I’d always been taught that a law has to be passed and go into effect before it can be enforced. Yet here Sidewalk Labs is suggesting that they do not have to wait for bylaws to be passed before getting down to work.

So much for Sidewalk Labs’ claim that it would follow the law of the land.

For this whole section, I’m sure the devil is in the details, and I’m not much qualified to discuss bylaw-setting processes. Municipal government experts would do well to pay close attention to this section to assess exactly what Sidewalk Labs is asking for, and the extent to which it does or doesn’t follow normal procedures.

Back to the list of “planning deliverables”…

• Infrastructure and Transportation Master Plan (pp. 65-66).

Now it’s a list of Administrator (WMOMNBWT) implementation responsibilities:

• Development call and land disposition management, following City guidelines and those of the (Sidewalk Labs co-created) Innovation Design Standards and Guidelines. Unclear: Would this power involve giving a public administrator (WMOMNBWT) control over land that Waterfront Toronto does not currently possess?
• Certification of development and building permit applications, following Innovation Design Standards and Guidelines. And presumably bylaws that have been rewritten to allow for super-tiny “liveable” studio apartments.
• Management of municipal infrastructure development: “Working closely with the City of Toronto, the public administrator [WMOMNBWT] would manage the design, construction, and turnover of all required municipal infrastructure, including site preparation, domestic water, sanitary sewer, storm drain conveyance, shoreline improvements, bridges, and public realm (such as parks, plazas, promenades, and streetscape areas), except where noted in Chapter 2, on Page 114. (p. 66)

That’s a lot of responsibility.

• Management of further light rail transit (LRT) development, with corridor design reviewed and approved by the TTC. The public administrator (WMOMNBWT) would procure and oversee contractors, “again with the TTC itself managing certain elements, such as electrical wiring and special track work, as appropriate.” (p. 66)

So now the public administrator (WMOMNB…) will also have to pay transit experts and run procurement for something where local expertise presumably rests elsewhere in the city. I can’t imagine what could go wrong.

This is going to get pricey, and is going to lead to amateur mistakes. For all of Sidewalk Labs’ talk of scale, they’ve paid precious little attention to the fact that these administrative capabilities make no sense at the scale of a neighbourhood.

My prediction: The IDEA District, if it comes to pass, wwould end up being characterized by less responsive governance (due to the extra layer of unaccountable bureaucracy), more expensive services (due to the huge number of new service fees), and shoddier service deliver (due to the number of disparate tasks that would be foisted upon a new agency that, if it is Waterfront Toronto, has no track record in delivering). The disparity between the IDEA District and the City of Toronto would be obvious and problematic for the area’s elected representatives.

Back to the list…

• Management of advanced systems. There are a lot of them: “a thermal grid, an advanced power grid, an advanced stormwater management system, a pneumatic waste system, dynamic streets, a digital communications networks, a freight management system, a mobility subscription package, and district parking management” (p. 66).

Sidewalk Labs would deliver them in its two tiny parcels of land (Quayside and Villiers West). The administrator (WMOMN…) would be responsible for developing and managing them everywhere else. And for managing them in Quayside and Villiers West, too.

This is getting expensive, and expansive.

• Oversight of (many, many) new management entities.
• Annual public reports on the IDEA District’s progress.
• Public engagement. Let’s see what they mean by public engagement:

This would include online content, social media, public workshops, charrettes, and meetings with working groups, agencies, and other stakeholders (p. 67).

Which presumably would include elected representatives.

On the Capabilities and capacities of the public administrator [WMOM…]. Basically, it has to do everything:

• a sophisticated understanding of land-use planning and the management and implementation of large-scale construction, infrastructure, and transportation projects. sufficient knowledge of technology to oversee the work of third-party consultants
• adequate staffing and institutional resources.
• developing and managing the performance of advanced systems in later years will require the administrator to develop specialized expertise.
• appropriate institutional mechanisms to monitor compliance by parties participating in eco- nomic development activities across the IDEA District, including Sidewalk Labs, developers, technology firms, and others.

And it will all be “self-financed,” which is a fancy way of saying taxes and user fees.

Saying that these skills and institutional capacities would be needed, and that they will be “self-financed” is easy. But notice that there is no estimate of how much it would cost to assemble all this skill, especially since they would be asking municipal workers to do complex work that is not being done anywhere in Canada. There is no estimate of how many people would be needed to staff these offices, or of anything resembling serious thought as to whether getting a single agency to do the work of an entire city government is actually workable.

Also, I’ll eat my Sydney Swans toque if self-financing of such a small district is actually feasible. More likely, services would be reduced to the level of available self-financing, which may or may not be enough to deliver the incredibly complex goodies Sidewalk Labs is promising.

This is not a plan; it’s a notion.

Governance and management of advanced systems and solutions (pp. 68-71)

I’m getting tired of repeating myself here, so I’ll try to be brief and just note some points that catch my eye and that I haven’t previously covered about the five new agencies/bureaucracies that Sidewalk Labs is proposing. Those interested in more details can note which pages cover which proposed agencies.

The organizations that Sidewalk Labs suggests here are reported without suggesting budgets or human resources that would allow us to determine whether they could deliver the services that Sidewalk Labs wants them to, or what level of “self-financing” (which is still taxes and user fees in some form – nobody rides for free) would be necessary to sustain them.

They assume that the talent needed to run these agencies and implement these services would be easily available, even though they would be asked to implement complex digital systems beyond what municipalities currently deliver.

The proposed Open Space Alliance (p. 68) would require resources diverted from the City of Toronto (Parks, Forestry and Toronto). Sidewalk Labs also sees non-profits taking up the slack for the management of many of its green spaces.

I’ve already talked a lot about the proposed “Urban Data Trust” (p. 69). Ditto the Waterfront Housing Trust (p. 69). The Waterfront Sustainability Association (p. 69) would be responsible for “Administer[ing] and enforce[ing] all operational service contracts for sustainability-related systems within the district, and Report[ing] on performance relative to sustainability objectives within the IDEA District.”

Not sure how this would work, or if it’s referring to policies that go beyond current regulations:

The proposal seeks to establish a mechanism to hold operators accountable and to fairly represent the interests of users in the district for systems that are not currently subject to public regulation. (Where they are, those regulations would prevail and not be replaced by any requirements of the WSA.) (p. 69)

And I’ve already discussed exactly what I think about the Waterfront Transportation Management Association (p. 70). It was a poorly thought out idea several hundred pages ago; it remains one now.