Are Community Improvement Plans inclusive to all areas of the city? An analysis of CIPs in Toronto.

By Derek Nawrot PLG 810 Plan and Admin Implementation Student Number: 500 201 951 Ryerson University School of Urban and Regional Planning March 29, 2010

Table of Contents

Section 1.0 Introduction. 2.0 CIPs A Virtually Untested Phenomenon. 3.0 CIPs An Overview... 4.0 The Legislative Context...................................... 5.0 CIPs in Toronto................................................... 6.0 CIP at Scarborough Village Not Likely ........... 7.0 St. Joseph CIP Ottawas application of the CIP in targeting a struggling neighbourhood.............. 8.0 Discussion, Recommendations, and Conclusion. Appendix A: References............................................. Appendix B: Business Improvement Areas in Toronto Appendix C: Distribution of Neighbourhood-centric CIPs in Toronto...................................... Appendix D: Area of Scarborough Village Revitalization Study.............................. List of Figures Table 1: Programs that can be included as part of a CIP Table 2: Key legislative clauses in implementing a CIP Table 3: Summary of grants available in Toronto to help in neighbourhood development..........................

Page 1 2 2 3 5 8 10 11 15 17 18 19

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1.0 Introduction: Community Improvement Plans (CIPs) are the main funding incentive of the Ontario government to allow municipalities to address issues of redevelopment. As one of the sustainable tools found in the Planning Act, a CIP provides a means of guiding and financing development activities that use, reuse, and restore lands, buildings, and infrastructure (Province of Ontario Ministry of Municipal Affairs and Housing (MMAH, 2008). Overseen by the MMAH, CIPs were born out of community planning incentives in the 1970s and 1980s that evolved to the redevelopment of Brownfield properties in the 1990s. The program was consolidated with the publication of the Community Improvement Handbook (2006), Section 28 of the Planning Act and legislative changes to land-use planning in Ontario which came into effect in January 2007 (2008). Although the redevelopment of Brownfield lands remains one of the key purposes, municipalities have effectively looked beyond this and have used CIPs as a mechanism for growth management challenges, intensification, energy efficiency, mixed-use and transit/bicycle oriented development, accessibility, and the emerging needs of an aging babyboom generation. However CIPs are essentially inclusive to specific areas of the city that the municipal government pre-determines. As part of the requirement for Ryerson Universitys School of Urban and Regional Planning PLG 720 studio course, my group analyzed opportunities for the implementation of a CIP in Scarborough Village (main intersection: Eglinton Ave. E. and Markham Rd), one of Torontos 13 priority neighbourhoods. Although strong recommendations were made to improve the community with funding via scattered grant programs, it seemed unlikely that a CIP would be feasible because the area lacked two of the main City of Toronto necessities for CIP funding: a) Suitable Brownfield land that could be redeveloped; and b) Strong neighbourhood commercial cohesion, most notably in the form of a Business Improvement Area (BIA), that could benefit from programs such as the Faade Improvement Program. In contrast, Toronto neighbourhoods that have benefited from CIPs are arguably more stable and affluent, mostly centred around the downtown core, or sizable pieces of land that are scheduled for large commercial redevelopment plans. One of the main objectives of a CIP is to target areas in a municipality that are in need of repair and rehabilitation yet in Toronto, these priority areas, including Scarborough Village, that are most in need of municipal intervention and a proper redevelopment scheme are being left out. This report will seek to provide recommendations to the City of Toronto in order to make 1

their CIPs more inclusive, especially for areas that lack strong funding triggers. It will begin by introducing the concept of CIPs and exploring existing literature and their legislative context. Second, CIPs within Toronto will be examined as well as municipal funding mechanisms. Third will be a revisitation of the Scarborough Village studio project to understand the difficulties of implementing a CIP. Finally, the report will analyze Ottawas St. Joseph CIP, which has introduced unique grant programs, and finally, best practice recommendations will be offered for the City of Toronto.

2.0 CIPs A Virtually Untested Phenomenon: As CIPs are a creation of the province and administered by the MMAH and municipalities, existing literature falls under the categories of a) Instructional guides such as the Community Improvement Handbook; and) the actual CIPs themselves and all components, including background studies, which are typically found in the Planning section of municipal websites. On February 28, 2011, the first 29 hits on Google for Community Improvement Plan belong to websites for the province of Ontario or Ontario municipalities. Although CIPs, or some rendition of, do exist in other provinces and countries, the CIP name has been adopted as part of provincial legislature which explains the high usage count on the internet. This study will only concern itself with Ontario cases in Toronto and Ottawa. There has been very little academic literature on CIPs. Causes for this are likely because they are limited to Ontario, they are most likely viewed as inherently good for the community and possibly because they are a relatively new phenomenon in which implemented plans have not had enough time to mature (although in fact they have been around in some form since the 1970s). Hayek, Arku, & Gilliland (2010) look at the effects of Brownfield revitalization in the context of a CIP in London, Ontario, but the article mostly concerns itself with private sector participation and not locational context. The authors also note that to date, no intensive study has focused on a mid-size Canadian citys experience with Brownfield incentives, and no study has attempted to gauge the extent to which policy objectives are being implemented in a typical midsized Canadian city.

3.0 CIPs An Overview: The guiding document for Ontario municipalities is the MMAHs Community Improvement Planning Handbook, hereon known as the Book. The Book defines 2

the four main objectives of a CIP as: 1) Focus public attention on local priorities and municipal initiatives; 2) Target areas in transition or in need of repair, rehabilitation, and redevelopment; 3) Facilitate and encourage community change in a co-ordinated manner; and 4) Stimulate private sector investment through municipal incentive-based programs (MMAH, 2008). Table 1 displays the types of programs that can be included in a CIP:

Table 1: Programs that can be included as part of a CIP Program

Municipally-driven

Infrastructure works Municipal property acquisition, land assembly and sale of lands Municipal facilities construction and rehabilitation Public space, parks and recreation works Signage, streetscape and landscaping improvements

Incentive-based (grant, loan and property tax assistance) Brownfields environmental assessment, remediation, and redevelopment Commercial building faade improvements Downtown/core area and waterfront revitalization Preservation and adaptive reuse of heritage and industrial buildings Provision of affordable housing Property tax assistance for remediation purposes Project feasibility studies Space conversion for residential and commercial uses Structural improvements to buildings (e.g., Building Code upgrades) Improvement of community energy efficiency Accessibility enhancements

Incentive-based (Private sector)

Grants, loans and land under section 28 of the Planning Act Tax assistance under section 365.1 of the Municipal Act, 2001 and section 333 of the City of Toronto Act, 2006

Adapted from Community Improvement Planning Handbook, MMAH, (2008)

Prior to January 1, 2007, the MMAH was responsible for the approval of CIPs however this power has now been decentralized to municipalities with councils being able to adopt the plans with no need for formal approval by the Minister. It is important to note however that The Planning Act still requires that a municipality consult with the MMAH on the preparation of a community improvement plan (s. 28(5.1)). 4.0 The Legislative Context: The primary legislative framework for CIPs is provided through three key pieces of legislation: Section 28 of the Planning Act, sections 106 and 365.1 of the 3

Municipal Act, 2001 and sections 82 and 333 of the City of Toronto Act, 2006 (with regards to CIPs in Toronto). Furthermore, there are also other development related programs that can also be included. Table 2 displays the key clauses in each that relate to the implementation of CIPs:

Table 2: Key legislative clauses in implementing a CIP Legislative contexts

Section 28 of the Planning Act

Key clauses

Designating by bylaw a specific property, area or entire community as a community improvement project area where the municipalitys official plan contains community improvement provisions (s. 28(2)) Acquiring, holding, clearing, grading or otherwise preparing land for community improvement (s. 28(3)) Constructing, repairing, rehabilitating or improving buildings on municipal land (s. 28(6)(a)) Selling, leasing or otherwise disposing of municipal land (s. (28(6)(b)) Providing grants or loans to owners, tenants and their assignees within the community improvement area to pay the whole or any part of identified eligible costs (ss. 28(7) and (7.1)) Providing property tax assistance for environmental remediation purposes (s. 28(7.3) by reference to s. 365.1 of the Municipal Act, 2001 and s. 333 of the City of Toronto Act, 2006)

Section 28 of the Planning Act, Section 106 of the Municipal Act, 2001 and Section 82 of the City of Toronto Act, 2006 Rule Against Bonusing

Under the rule of bonusing, municipalities are prohibited from directly or indirectly assisting businesses through the granting of financial incentives. However there are exceptions that allow municipalities to provide assistance under the guise of a CIP:

Making improvements to buildings on municipal land and selling or leasing the land to businesses (see s. 28(6) of the Planning Act) Making grants or loans to businesses (see ss. 28(7) to (7.3) of the Planning Act) Providing property tax cancellations to businesses (see s. 365.1 of the Municipal Act, 2001 and s. 333 of the City of Toronto Act, 2006).

Adapted from Community Improvement Planning Handbook, MMAH, (2008)

Two of the other key development related incentives are the Brownfield Financial Tax Incentive Program (BFTIP) and the Heritage Property Tax Relief (HPTR). The BFTIP is a financing tool established under section 365.1 of the Municipal Act, 2001 and section 333 of the 4

City of Toronto Act, 2006. It allows municipalities to provide municipal property tax assistance to landowners trying to bring brownfields back into productive use. In addition, municipalities offering property tax assistance can apply to the province for matching education property tax assistance. The HPTR is established under section 365.2 of the Municipal Act, 2001, and section 334 of the City of Toronto Act, 2006. Municipalities may pass a bylaw to establish a local HPTR program to provide tax relief (10 to 40 per cent) to owners of eligible heritage properties, subject to agreement to protect the heritage features of their property. The Province shares in the cost of the program by funding the education portion of the property tax relief. Further information on CIPs, including the preparation and implementation processes and the plan structure, can be found at the MMAH website at: http://www.mah.gov.on.ca/Page1297.aspx.

5.0 CIPs in Toronto The implementation of CIPs in Toronto can be categorized in two phases. In a personal correspondence from Peter Moore (2011), a Project Manager in the Policy and Research section of the Toronto City Planning Division, Moore states there were probably many CIPs adopted by the former City of Toronto in the 1970s and 80s, however there is no circulating list of them. As CIPs have a time limit of 5 years, it is sufficient to believe that none of them are currently active and there is no historic information via the internet. It is beyond the scope of this report to further research this area, however it is highly recommended for future projects. These can be described as the first stage of CIPs, or a loose collection of neighbourhood-focused plans. Most likely there would have very few of the characteristics or funding incentives that are available today nor would there been large provincial government intervention or guidance. Certainly they would not involve the revitalization of brownfields. The second phase is the modern CIP which originated in the 2000s. The initial guiding documents were the provincial government publications 2000 Brownfields Showcase I, Municipal Readiness for Economic Development and Municipal Financial Tools for Planning and Development. The publication of the Book in 2006 consolidated the movement and legalized the name. The characteristics are discussed in the previous section. There are two types of CIPs in Toronto. The first are broad-based, city-wide programs such as The Commercial Faade Improvement Program and The Toronto CIP for Brownfield 5

Remediation and Development of Prescribed Employment Uses. These CIPs concentrate on the promotion of one funding mechanism as opposed to various methods, which characterize the second type, which will be called Neighbourhood-centric CIPs. The Commercial Faade Improvement Program is a grant from the City offered to eligible commercial property owners to improve their building faades through a variety of upgrades including the replacement or repair of windows, doors, lighting, awnings, brickwork, signage, or the addition of wheelchair accessible entrances. However they are only available to Business Improvement Areas (BIAs) that have been in existence for a minimum of 5 years (City of Toronto, 2010). Appendix B is a map of the citys current BIA areas. In analyzing this map, one will note that the majority of BIAs are located in the core of Toronto. There are virtually none located in the Scarborough or North York, two large areas of the city that contain the majority of the citys priority neighbourhoods. Therefore, commercial businesses, of which there are many independent and ethnically owned, in these areas are unable to take advantage of this particular CIP. More on this will be discussed in the section on the Scarborough Village project. The Toronto CIP for Brownfield Remediation encourages the intensification of employment areas, but not retail, through the redevelopment of brownfield sites. It allows the City to cancel all or a portion of municipal taxes for contaminated properties where the Plan is in effect. Although the CIP is said to apply throughout the City (with the exception of the Waterfront and South of Eastern area, which are the beneficiaries of neighbourhood-centric plans), it clearly shows concentration in the Etobicoke, North York, and Scarborough Centre areas (City of Toronto, 2008). One of the many conditions of qualifying is A Phase II Environmental Site Assessment which means that it is likely financially unfeasible for any applicant that does not have large redevelopment funds supporting it. There are currently six neighbourhood-centric CIPs in Toronto however this can be misleading. St. Lawrence and King-Parliament are the only two that truly concentrate on benefiting residential neighbourhoods. The other four (Waterfront, South of Eastern, New Toronto, and Woodbine) are mostly concerned with economic development and the lands are mostly light industrial. Appendix C shows the distribution of CIPs. With the exception of Woodbine and New Toronto, the majority are concentrated around the core. Again, North York and Scarborough have not yet benefited from a CIP nor does it seem like there are any in the foreseeable future. What these areas have benefited from are secondary and revitalization plans 6

such as the Downsview Area Secondary Plan Review and Lawrence Allen Revitalization project in North York and the Finch-Warden and Markham-Ellesmere Revitalization studies in Scarborough. As supportive and progressive as these documents may be, they are often more concerned with the task-at-hand as opposed to funding mechanisms and fail to qualify for monies available for consolidated CIPs. That four of Torontos CIPs are solely on industrial land, with the exception of Woodbine, shows that the City is more concerned with using CIPs as an economic trigger for redevelopment and the installation of future employment areas. The Woodbine CIP (2008) is an example of this with the whole plan centred around the Woodbine Live! initiative which is the establishment of an entertainment and lifestyle district containing a mix of entertainment, hotel, and retail uses. Likewise, the South of Eastern CIP encourages growth in offices, research and development, film, media, and communication. All of these CIPs benefit from funding mechanisms based on the Citys brownfield tax incentive programs and development grants for eligible owners who develop buildings and facilities for employment used in targeted sections such as biomedical, creative industries, manufacturing, software development, and tourism. Most relevant to this report are the CIPs for King-Parliament (2002) and New Toronto (2003) because they are concerned with the betterment of neighbourhoods, especially those that include high amounts of residential land. Although this neighbourhood has seen a rise in highdensity residential, most notably through the construction of new condominiums, it includes a particularly vulnerable population as well. Unfortunately the CIP is severely limited in providing an actual social benefit to the area as it only really incorporates the Faade Improvement Program. In fact, it can be argued that this is not even truly a CIP as opposed to a plan that only assists area businesses. Lost are any opportunities for the provision of affordable housing or space conversion for residential use. Likewise the St. Lawrence CIP missed out on the opportunity to incorporate the mixed-income residential land east of Jarvis St. instead choosing to focus on land that includes hundreds of new condominium units between Yonge St. and Jarvis St., and King St. and the Gardiner Expressway. Representatives of the St. Lawrence Neighbourhood Association expressed concern that the CIP initiative does not encompass the entire St. Lawrence neighbourhood, which they define as extending from Yonge St. to Parliament St. and from Queen St. E. to the rail corridor (2007). Again the main finding mechanism is the Faade Improvement Program. Unlike other CIPs however, planners defined 7

eight specific programs (ranging from Streetscape Design and Street Furniture to Heritage Grant to Bicycle Lanes) and thirteen key physical project areas. They further go onto define each City division responsible for leading the program/projects. One aspect of CIPs that becomes clear is that it is not simply one division implanting the CIP and it involves the coordination of a number of municipal divisions ranging from Economic Development to Parks, Forestry, and Recreation, to Transportation.

6.0 CIP at Scarborough Village Not Likely As mentioned previously, our studio group was charged with the development of a CIP for the Scarborough Village area (Eglinton St. E. & Markham Rd.) from the months of September to December, 2010. The area is designated as one of the thirteen priority neighbourhoods by the City of Toronto. Comparatively, the area would be considered as part of City#3 in Hulchanskis (2010) The Three Cities Within Toronto report. The report defines a City#3 area as generally low-income area of Toronto, in which neighbourhood incomes have fallen substantially over the past few decades compared to the CMA average; these neighbourhoods are found mostly in the northeastern and northwestern parts of Toronto (2010; p. 1). Appendix D shows the area defined by the study and suggested for a possible CIP. Among the challenges faced, which are similar across all of the priority neighbourhoods, includes an area core that is aging and shows visible signs of deterioration, high-density apartment blocks (most notably in the Cougar Crt. area) that present specific rehabilitation challenges, and a lack of rapid transit connectivity with other locations in the city. Although recommendations were made in five key categories (Beautification/Streetscapes, Capital Works, Private Property Improvements, Connections and Community Initiatives), because the area lacked a consolidation of businesses that could form a BIA nor was there large plots of brownfield land to be potentially redeveloped, the area could not benefit from two of Torontos main CIP funding incentives: the Faade Improvement Program and brownfield redevelopment incentives. Table 3 is a summary of the grants available for the area, the funding agency, whether the area is eligible, and the reason why. It is especially important because this Table is representative of the majority of funding available to priority neighbourhoods.

Table 3: Summary of grants available in Toronto to help in neighbourhood development

Grant Commercial Faade Improvement Program Mural Program Streetscape Improvement Program Various Grants for Community Arts, Dance, Literacy, Music, Theatre and Visual and Media Arts Competitiveness, Creativity, and Collaboration Investment Program (CCCIP) Community Safety Investment Program Agency City of Toronto City of Toronto City of Toronto Toronto Arts Council (TAC) Eligibility No No No Maybe Reason Scarborough Village does not have a BIA Scarborough Village does not have a BIA Scarborough Village does not have a BIA The TAC provides funding to non-profit organizations and individuals for ongoing artistic activities The CCCIP awards this grant to a non-profit organization that helps stimulate the local economy Scarborough Village is a priority neighbourhood that is constantly looking to improve safety in the area This could be used for the YWCA, ANC, or any other organization that works to improve social conditions This fund is awarded to youth led initiatives that provide valuable contributions to their community This grant is given to nonprofit groups partnered with a sponsoring organization that have innovative environmental projects This grant could be used to assist in the beautification of the neighbourhood through programs like B.U.L.B.S. Scarborough Village would need to provide a rationale as to what type of beautification project they would use the funding for

City of Toronto

Maybe

City of Toronto

Yes

Community Service Partnership

City of Toronto

Yes

Identify NImpact Investment Program

City of Toronto

Maybe

Live Green Community Investment Program

Livegreen Toronto

No

Community Grants Program

Toronto Parks and Trees Foundation Community

Yes

Beautiful Streets Program

City of Toronto

Yes

Source: Nawrot et al., 2011

Funding available to priority neighbourhoods in Toronto is very limited. Although one might suggest for neighbourhood businesses to form a BIA, this can be very difficult given the high number of immigrant-owned businesses, who would have to be convinced of the advantages 9

and that they would have to provide the initial costs for the BIA start-up. As well, BIAs are not common outside of developed nations. So far, this has proven quite a difficult sell in priority neighbourhoods. Without a BIA, the only options available are a smattering of arts grants, small monies for community safety, and other grants that need a non-profit agency to take ownership of the project. Furthermore, grant monies have to be applied for individually as opposed to having the influence of a consolidated CIP. Although the Mayors Tower Renewal initiative has been identified as an option for neighbourhood renewal, the program is still in the premature stages and the realistic aspect is being debated. Municipal-backed funding has still not been identified and the true benefits of the program will have to be proven to property owners who may have to spend millions to bring their properties up to the programs standards. Another flaw is that they are only really concerned with the building itself and the immediate surrounding private space, which does not necessarily benefit the community as a whole.

7.0 St. Joseph CIP Ottawas application of the CIP in targeting a struggling neighbourhood The St. Joseph Boulevard CIP has been the only CIP implanted by the City of Ottawa. Located in the neighbourhood of Orleans, the area is comprised of a mix of commercial, residential, office, and institutional and vacant parcels of land with St. Josephs Blvd. being the key arterial spine. Although in recent years development has been slow due to prime locations in other areas of Orleans, the area offers a strong population base and accessible public transit. There is potential of the development of vacant properties and it is possible for the redevelopment of existing buildings both individually and as part of land assemblies. Although like Toronto CIPs, the main goal is to bolster the economic viability of the area however unlike Toronto, there are strong sub-goals in order to bolster the liveability of the area for the average resident. For example, the CIPs goals include to encourage a range of higherdensity housing types including affordable housing units, to provide employment opportunities through intensification of commercial and office uses, and to strengthen the area as a live/work/play destination (City of Ottawa, 2009). To accomplish this, Ottawa offers three unique grant incentives that encourage not only grants for development, but in the stages leading up to development. They key is the increase in grant money for the provision of affordable housing. First, the Project Feasibility Study Grant 10

Program offers a grant equivalent to 25% of the cost of an eligible project feasibility study. This can be applied to studies, tests or designs required by the City and in support of an application under the Planning Act and/or for building permit approval (i.e. architectural, engineering, site design, transportation). The total combined maximum grant amount is $2,500 with it increased to up to 50%/$5,000 maximum if three or more new affordable housing units are constructed. Second is the Planning Fee Grant Program which includes a grant equivalent to 25% of the City fees for initial applications made under the Planning Act (after applicable multi-application reductions) including for example Official Plan amendments, Zoning By-law amendments, Site Plan approval, Plans of Condominium and Committee of Adjustment applications. The total combined maximum grant amount is $5,000 with an increase to 50%/$10,000 maximum if three or more new affordable housing units are constructed. Finally the last is the Building Permit Fee Grant Program which is a grant equivalent to 30% of the building permit fee - included as an eligible cost within a Development Incentive Grant. The grant maximum percentage is increased to 40% if three or more new affordable housing units are constructed.

8.0 Discussion, Recommendations, and Conclusion CIPs are a unique tool in providing the framework to guide the redevelopment and improvement of selected lands with the provision of financial assistance by the municipality. They are a political document they are approved by council and act as a mandate for municipal divisions. Most importantly however, they are flexible in that each is defined by the municipalitys local needs, priorities, and circumstances. It is understandable that the majority will have an economic focus however, especially in Toronto, this seems to be the limit of their intentions. Any provision for affordable housing is not evident in any of the citys existing CIPs. By limiting funding for many of the grants to the establishment of a BIA, a great majority of neighbourhoods are missing out. Furthermore, there is evidence that they are concentrated in strategic areas, mostly close to the downtown core. The example of the St. Joseph CIP shows that grant monies should be available to support all stages of the development process, and be increased for the provision of affordable housing. But even this isnt enough. CIPs must evolve to be more expansive and obtainable to poorer neighbourhoods, especially those without the resources as some of the more attractive and affluent areas. The following are a number of recommendations in helping CIPs, especially in Toronto, achieve this goal. 11

1. Use Secondary/Revitalization Plans as a foundation for CIPs. The initial process of completing a CIP and Secondary/Revitalization Plans are quite similar. Both types involve a public benefit rationale, there has to be a process of public consultation, both are wrapped in legislative authority and have a policy basis, and they involve mapping exercises. As more Secondary/Revitalization Plans have been completed than CIPs, why not use the foundational proceedings and information to expand them into CIPs. One of the only elements that would have to be added is the funding information. Furthermore, this would increase the scope of CIPs to include priority neighbourhoods that especially need reinvestment. 2. Toronto should use the St. Joseph CIP as an example and provide grants for CIP development in the initial stages. Toronto currently offers development grants that are payable over a 10-year period following rehabilitation and reassessment. But where are the monies in the initial stages of the program? The grants do not have to be large. In the example of Ottawa, up to $2,500 is provided just for initial feasibility tests. Likewise is a grant equivalent to 30% to cover the building permit fee. It is these small incremental grants that at least encourage the process of identifying the possibility of redevelopment. It is suggested the Toronto Planning and Finance Divisions work together to explore the feasibility of these additional grants. 3. Affordable housing has to be embedded in CIP policy. Affordable housing incentives have to be embedded in policy and incorporated into the CIPs. They must go beyond simply being clauses in grants, such as in the Ottawa case, and start to be their own grants. There is no reason why there cannot be a city-wide CIP for Affordable Housing that outlines tax assistance, grants, and defines initial project areas. The Toronto Official Plan states that a full-range of housing must be provided across the city. It also states that investment in new rental housing, particularly affordable rental housing, is encouraged by a co-ordinated effort from all levels of government through implementation of a range of strategies, including effective taxation, regulatory, administrative policies and incentives. A CIP is a natural extension of the Official Plan. 4. Affordable Housing should be encouraged in more Mixed-Use Projects and grant incentives should be provided as such. Perhaps one reason why affordable housing does not figure in any of Torontos CIPs is because there is no incentive nor assistance for developers. With the success of the Regent Park project and Toronto Community Housing likely facing major reforms, it is time to look beyond the construction of apartment complexes solely for

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affordable housing units. There has to be incentive for developers and one way to do this is also to allow a number of market-value units. 5. The condition of having a BIA to receive grants has to be removed. It is understandable why the City imposes the rule of having a BIA in order to receive CIP grants, especially for faade and streetscape improvements. BIAs typically mean a stronger-knit consolidated area of businesses which is easy to manage and work with on economic strategies. Many times, they are one of the key stakeholders in the CIP process. For example, the St. Joseph CIP is marketed primarily through the Heart of Orleans BIA. However in the Scarborough Village example, the area could not obtain funding for three major municipal grants because no BIA was in place. This goes for many other locations in North York and Scarborough. There should be other grants provided that allow individual businesses to apply if they will match funds for faade or streetscape improvement. Although The Three Cities Within Toronto report does not address the fact of commercial infrastructure disparities, one can wager that in moving forward, there will be a great difference in the streetscapes and faades of those areas that have BIAs and those that dont, further expanding the disparities between City#1s and City#3s. 6. CIPs should not be concentrated in the core. Recommendation 5 leads into 6. Even if the City maintains a BIA must be in existence for funding, they should recognize that this is not a possibility for some areas and look at other mechanisms to get CIPs into areas that truly need to benefit from community improvement. 7. Tower Renewal should be incorporated into CIPs. Although it was argued earlier about the potential effectiveness of the Tower Renewal program, it is still one of the only funding mechanisms available to private apartment owners who want to upgrade their properties. As many of these apartment blocks are located in priority neighbourhoods, the redevelopment of them should be integrated with a community strategy like the CIP. This way, funding is available to repair the private realm, and also in repairing the public realm- the two have to be integrated. 8. All future neighbourhood-centric CIPs should use the template of the St. Lawrence CIP. Instead of competing the CIP in generic terms and identifying the project area as a whole, as the majority of CIPs in Toronto do, the St. Lawrence CIP format should be standardized in that specific programs and area targets are included in the plan. Furthermore they identify which City division is responsible for its part in implementing the CIP. This way the process remains transparent and each stakeholder knows what they are responsible for. 13

9. Monitoring system has to be built into CIP from the beginning. How does a municipality know if a CIP is achieving its goals? How can one know what has worked and what hasnt to improve future CIPs? In the majority of CIPs, a monitoring system is a rarity. The St. Joseph CIP has a monitoring component built into the implementation stage with a number of variables to determine if each grant program is successful. This is a start but the process should also include qualitative methods such as focus groups to measure if people are seeing changes in their neighbourhood after a CIP has been implemented. This is the only way CIPs can evolve and be efficient. 10. Academic/Think-tanks need to start studying CIPs. There is a general mentality that any CIP must be good for the community. What program would not be good that is providing funding? However this may not necessarily be true. The second phase of CIPs have been implemented long enough that there is enough data to start measuring the effects. Academics and Think-tanks have been slow to this process however it is only through critique that change will come. Furthermore, this initial analysis should be expanded on to determine how to best make CIPs inclusive for the entire city.

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Appendix A - References City of Ottawa. (2009). St. Joseph Boulevard Community Improvement Plan. Retrieved from: http://www.ottawa.ca/residents/planning/community_plans/completed/cip/index_en.html City of Toronto. (2010). Community Improvement Plan to extend the Commercial Faade Improvement Program. Retrieved electronically from: http://www.toronto.ca/legdocs/mmis/2010/pg/bgrd/backgroundfile-28931.pdf City of Toronto. (2010). Map of Toronto BIAs. Retrieved electronically from: http://www.toronto.ca/bia/toronto_bia.htm City of Toronto. (2008). The Toronto Community Improvement Plan for Brownfield Remediation and Development of Prescribed Employment Uses. Retrieved electronicall from: http://www.toronto.ca/business/pdf/city-wide-CIP-notice.pdf City of Toronto. (2008). The Woodbine Community Improvement Plan for the Development of a Transformation Project. Received via e-mail from P. Moore City of Toronto. City of Toronto. (2008). The South of Eastern Community Improvement Plan. Retrieved electronically from: http://www.toronto.ca/planning/pdf/waterfront_cip_draftplan_eastern.pdf City of Toronto. (2007). St. Lawrence Neighbourhood Community Improvement Plan. Retrieved electronically from: http://www.toronto.ca/legdocs/mmis/2008/te/bgrd/backgroundfile-9479.pdf City of Toronto. (2003). New Toronto Community Improvement Plan. Retrieved electronically from: http://www.toronto.ca/planning/pdf/planfornewto_fulldoc.pdf City of Toronto. (2002). King-Parliament Community Improvement Plan. Retrieved electronically from: http://www.toronto.ca/legdocs/bylaws/2002/law0383.pdf Government of Ontario Ministry of Municipal Affairs & Housing (MMAH). (2008). Community Improvement Planning Handbook. Toronto, ON: MMAH Hayek, M., Arju, G., & Gilliland, J. (2010). Assessing London, Ontarios brownfield redevelopment effort to promote urban intensification. Local Environment, 15(4), 389402. Hulchanski, D. (2010). The Three Cities Within Toronto Income Polarization Among Torontos Neighbourhoods, 1970-2005. Toronto, ON: University of Toronto. Moore, P. (2011). Personal e-mail correspondence received March 21, 2011. 15

Nawrot, D., Binneti, M., Brillinger, C., Kennedy, T., Khan, S., Kuzniar, M., Macleod, J., Nguyen, M., Simone, V., Suppa, N., & Tranter, J. (2010). Scarborough Village Revitalization Study Opportunities for a Community Improvement Plan. Prepared as part of the requirement for Ryerson School of Urban and Regional Planning, PLG 720.

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Appendix B Business Improvement Areas in Toronto

Source: City of Toronto

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Appendix C Distribution of Neighbourhood-centric CIPs in Toronto

1. King-Parliament 2. Waterfront 3. South of Eastern 4. Woodbine Live! 5. New Toronto 6. St. Lawrence

Source: City of Toronto

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Appendix D Area of Scarborough Village Revitalization Study

Source: Nawrot et al.

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