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The Newfoundland Historic Trust commends the City in its efforts to partner with the Downtown Development Commission to review development issues affecting the City’s downtown core. On behalf of the board of the Trust, we wish to provide comment on the parking study currently being considered by Council and, in particular, comment on aspects of the study about which we have particular objections.

The City of St. John's has a legally enacted Municipal Plan and Development Regulations to guide developments in the City, brought into effect on the basis of a thorough public consultation process. The Trust maintains its strong objection to any proposed amendments to the Plan and Regulations that weaken the protection of the designated Heritage Area, namely provision of additional building height as recommended. IBI Group’s parking study, Section 3.5 (Guiding Principals) states:  

Downtown Building Control provided by the St. John’s Development Regulations will continue to provide opportunities for the sensitive placement of surface, below-grade and above-grade parking facilities in the Downtown, either as stand-alone or mixed use developments.

In order to encourage the design of structures in the Downtown which include structured parking, the Bulk Control provisions of the Development Regulations will be expanded to provide additional opportunities to locate structures with a FAR of greater than 3.0 and a building height exceeding 4 storey, while at the same time preserving the prominent heritage structures and views within the Downtown.

Additional building height above the existing 4 storey limit may be approved by the City as a bonus for the provision of required on-site parking as determined by the City, subject to the protection and preservation of heritage features and prominent views in the Downtown.

The Trust believes that the existing four storey limit in the Heritage Area retains the scale and proportion of development that characterizes downtown St. John’s to locals as well as visitors. We feel that allowing selective developments to exceed the height limit of four storeys threatens the scale as well as the views in the entire Heritage Area. We prefer that Council guide taller higher density development to the areas in the downtown business district that are zoned to accommodate it. It is Trust’s opinion that allowing developments to exceed the regulations in selective cases would have far broader implications on the Downtown and Heritage Area. Height restrictions and bonuses were not understood to be part of the mandate of a parking study. If Council wishes to consider relaxing building height restrictions or any other development standards, it should do so with meaningful engagement of its stakeholders in a transparent process, not by endorsing a parking study with hidden recommendations having broad development implications. 

At the public meeting regarding the parking study on November 10, 2009, a number of concerned citizens expressed their opposition to the possibility of allowing taller developments to be built in the downtown area. We were disappointed to discover that the consultants had not approached any downtown residential property owners for this study, thus ignoring the concerns of the local population. A number of alternatives to the parking problem were suggested at the meeting, most notably the idea of putting resources towards a more effective and efficient public transit system. Less parking would support transit.

In the effort to find balance in guiding appropriate redevelopment and infill development in the historic core of the city, there have been many successes and some noteworthy failures as the urban environment of St. John’s has modernized. Most of the notable failures have created a barrier disconnecting the historic core of downtown from the harbour. In some cases, Council has been criticised for its ad hoc approach to amending guidelines to suit developers' needs, as demonstrated by the recent approval of a hotel at 123 Water Street, where exception was granted to spot zone and accommodate a development in excess of the height limits. In the past, the Trust has argued that site specific zoning creates a “slippery slope” and a catalyst for many other developers to try to push the limits on developments for other sites. The City’s Plan and Regulations articulate a vision by Council and the public for how development should be guided into the future. We have argued against proposals that set a dangerous precedent, encourage additional proposals contrary to policy or regulations, and threaten the stability of the overall development climate.

The Trust does not believe that historic buildings that long pre-existed modern parking standards should be jeopardized to remedy parking shortages in the downtown that were arguably caused or exacerbated by modern developments, including public buildings such as Mile One Stadium and the Convention Centre. We should not allow the issue of inadequate parking to detract from the importance of preserving our built heritage; we must encourage appropriate developments that fit into our beautiful, historic downtown.

The City of St. John's has a long and storied history that is widely promoted as a tourism asset for visitors as much as it is appreciated by locals. Heritage advocates with the Trust and other local heritage organizations have worked diligently for more than four decades to increase awareness and promote the importance of preserving the historic fabric of downtown St. John’s. In that timeframe, City leaders have increasingly provided support for these efforts, and have acknowledged and demonstrated to the public a level of commitment to preserving its built heritage through many means, such as undertaking comprehensive studies pertaining to the preservation of built heritage as well as protection of key public views, and expanding the Heritage Area originally designated in the 1970s. We urge Council to retain recognition of such important issues as it considers this parking study.  

In conclusion, the Newfoundland Historic Trust strongly objects to the recommendation within the parking study to relax building height restrictions. We urge the Council not to approve any amendments to the Municipal Plan and Development Regulations that weaken the protection provided to the City’s Heritage Area. Furthermore, we believe that if the City consults the public on proposed changes to the planning framework guiding urban design, it must be clear in articulating its intentions. A study of parking is not an appropriate mechanism within which Council should be consulting its electorate about relaxing established building height restrictions in this key area of the City. There are creative ways to address growth and development in the city without jeopardizing the framework that is intended to protect the downtown core and designated Heritage Area.