It really is that bad a plan. Also, it’s not a plan.

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

The Digital Strategy Advisory Panel’s Preliminary Commentary and Questions on Sidewalk Labs’ Draft Master Innovation and Development Plan (MIDP)  is a significant document. Given that Waterfront Toronto itself is directly tied to Sidewalk Labs and the MIDP through the Plan Development Agreement, protestations of Waterfront Toronto Chair Stephen Diamond notwithstanding, it is likely to be the only official and independent analysis of the MIDP that we’ll see before the new October 31 deadline for Sidewalk Labs to address some key Waterfront Toronto concerns.

And, well, judge for yourself what they thought of Sidewalk Labs’ efforts. The summary:

Panelists have raised questions or concerns about the MIDP in general (including the inaccessibility of the document and the lack of detail around many digital elements) and made specific comments around various digital innovation and digital governance-related proposals. These include, but are not limited to:

• Overall: In many areas, the MIDP is not sufficiently specific about critical areas of its digital innovation proposals, and it does not provide a clear path for individuals, civic society, or small/startup businesses to participate from design, implementation, operations, and sustainability perspectives.

• Digital Innovations: Further information is required to show how digital innovations – including infrastructure and launch services – will support Waterfront Toronto’s goals for Quayside. This should include a shift from “what” is proposed to “how” the proposal will accomplish the objective, and why the proposal is superior to alternatives.

• Data Governance / Privacy: The development of overarching data governance mechanisms should be shifted to Waterfront Toronto and its government partners, while Sidewalk Labs should focus on elaborating on how it will make its own proposals for data collection, processing and use more transparent, accountable and amenable to a robust privacy protection regime.

• Intellectual Property / Economic Development: While welcome, the current value sharing proposals are insufficient. As well, additional specific commitments should be made about enabling the growth of the local urban innovation industry. (pp. 2-3)

To which I can only add, precisely so.

In the 99-page document (two-page summary, 20-page main document, and a well-organized 73-page compendium of panelists’ comments on specific parts of the MIDP; it’s all worth reading), several themes arise continually, echoing my own reading of the report: a lack of detail in key areas, with basic issues left unconsidered; a lack of justification of several proposed technologies; a lack of consideration of the Canadian legal and policy landscape; and plenty of concern with the concept of “urban data” and the related and nebulous “Urban Data Trust.”

The DSAP’s analysis backs up my own reading of the report, that this is a seriously underbaked, poorly thought-out document. It is basically a poorly constructed reiteration of Sidewalk Labs’ original project vision. To call it a plan is to grant it a degree of thoroughness it does not possess. As I remind my students, quantity does not equal quality.

What’s more, the sense of frustration that one experiences when reading this report really comes across in the appendix’s unfiltered comments (164 in total, helpfully numbered – and with a hyperlinked table of contents! Be still my heart. It’s almost as if this report were meant to be read and understood).

Comment 8:

The MIDP gives the strong impression that it was developed with little direct involvement with the range of relevant Toronto community actors or with attention to inter-operability with existing (digital) infrastructures. …

Comment 13:

Frustrated by how over-sold this proposal on digital innovation is at times. …

Comment 14:

Volume 3 states that without the proposed Digital Network ‘standard broadband services available in Toronto’ would be the Business as Usual result. This is both incorrect and seriously misleading. …

Comment 15:

The lack of discussion of the evolution of mobile network technologies to support IOT is surprising. …

I could go on, but I have to prepare to teach in a few hours and you get the point. There are, however, two other things worth saying.

Preliminary commentary

First, the DSAP’s ability to review the MIDP was limited by both the pointless 1,500-page size of the report and the short timeline available to them. Beyond reviewing and commenting on a draft version of the Digital Innovation chapter (which doesn’t mean much given how relevant information is spread throughout the report’s 1,500 pages), they got their copy on June 24, same as the rest of us, and filed their analysis on August 18, less than two months later. While the DSAP report itself is commendable, the DSAP itself notes that the short timeline means that “the feedback in this Commentary is by necessity preliminary” (p. 6). This type of time pressure – driven by artificial deadlines – is not conducive to sound policymaking.

Whither Sidewalk Labs’ reputation?

Second, I’m not sure that Sidewalk Labs has fully grasped how badly it is screwing up, not just this job, but its future business prospects. It has been working on the Quayside project in one way or another for over two years. It obviously sees Quayside not only as a place to develop specific technologies and policies, but as its calling card for future projects. It has spent, or budgeted, $US 50 million to produce a plan for Quayside.

Two years and $US 50 million later, and this was the best it could do? A “plan” that independent analyses (mine and the DSAP’s) confirm doesn’t even include basic and obvious needed details? That suggests an almost wilful ignorance of local politics and laws? A community engagement process that has relied on paid consultants and a thinly disguised influencer campaign to build support? An inability to maintain a healthy relationship with its government partner?

Forget about Toronto and Quayside for the moment. If I’m the mayor of any city in the world, I’m looking at Sidewalk Labs – which, remember, isn’t the only company selling these types of products – and thinking, what is there in their Quayside proposal and actions that suggest that they can either deliver the goods or play well with others?

Sidewalk Labs’ fundamental problem is that, as I’ve said previously, the MIDP isn’t just a mess; it’s an obvious mess, as the DSAP report confirms. It’s right there in the writing. It is not a quality product. Its problems are fundamental, of the type that never should have seen the light of day. No matter what happens going forward, these facts are set in stone.

Knowing this, and seeing everything that’s happened, under what conditions would it make sense for any city to go into business with Sidewalk Labs?