“But the plans were on display…”
“On display? I eventually had to go down to the cellar to find them.”
“That’s the display department.”
“With a flashlight.”
“Ah, well, the lights had probably gone.”
“So had the stairs.”
“But look, you found the notice, didn’t you?”
“Yes,” said Arthur, “yes I did. It was on display in the bottom of a locked filing cabinet stuck in a disused lavatory with a sign on the door saying ‘Beware of the Leopard’.”
Douglas Adams, “The Hitchhiker’s Guide to the Galaxy”
As I was touching up my introductory post yesterday, it occurred to me that readers and the remaining Toronto royalty who have not yet made up their minds about a 1,500-page report that was released only a few weeks ago might want to know how to participate in the fulsome consultations Waterfront Toronto has promised the city.
Finding out how to participate ended up being much more difficult than I expected. Waterfront Toronto and Sidewalk Labs might be planning the innovative, accessible smart city of the future, but there is nothing innovative or smart about their consultation process. To be blunt, they are not making it easy to participate, and the poorly designed process that Waterfront Toronto has put in place raises questions about how useful results will actually be.
Neither does Waterfront Toronto’s actions in the first public consultation (July 15) provide much confidence in their commitment to full transparency and maximum public engagement, as they did not make any audio or video recordings of the meeting. According to the Toronto Star, “Waterfront Toronto officials told The Star that they expect to record and make publicly available all subsequent meetings, with written summaries to be posted online.”
Waterfront Toronto has been on this file for three years now, and providing a written and video record of one of Toronto’s most important urban development projects in a generation would seem to be a no-brainer. That they didn’t do this for the first meeting, followed by a reassurance that they will start recording in the next one has the strong feel of an organization that’s reactively improvising.
An advisory consultation
There’s also the reality that at the end of the day this is all very much an advisory consultation. If Waterfront Toronto wants to go ahead with this project, all the negative feedback in the world can’t stop them. As the Auditor General of Ontario’s report points out, our elected officials “can only influence Waterfront Toronto through their appointees to its Board of Directors” (p. 694).
The Auditor General also notes that, as of December 2018, Waterfront Toronto’s “protocol” for soliciting governments’ review and comments on the MIDP:
only requires Waterfront Toronto to provide to each of the three governments the key agreement and any supplementary agreements for comment. The protocol does not clarify whether Waterfront Toronto would approve the MIDP if Sidewalk Labs does not make changes to the draft that the governments may request. (p. 694)
The long and short of all this is, if you want to influence the outcome of this project, don’t just focus on these consultations. Contact your local councillor and your federal Member of Parliament. The federal election is just around the corner, and it looks like the Liberals will need to hold Toronto to stay in power. Ask your candidates where they stand on Waterfront Toronto, Sidewalk Labs and the MIDP.
Still, being responsible citizens, let’s try to offer our opinion, shall we?
“Down to the cellar”
Our journey begins early on the morning of July 15. It’s a digital world, and Waterfront Toronto is offering us the city of the future, with everything conveniently at our fingertips. So it’s off to their main project site, quayside.to, which prominently features a link to the MIDP proposal, but no obvious link for feedback.
The misleadingly labelled “Contact Us” button brings us to a page whose most prominent offering is the opportunity to “Sign up for Waterfront Toronto’s Monthly Newsletter,” so no help here. (In fairness, it also includes their general email address, firstname.lastname@example.org, on which more later.) And no “How can I make my voice heard?” in the FAQ, either.
Success! Clicking on the menu button – the digital equivalent of opening the door to the cellar – brings us to something labelled “Get Involved”.
“Stuck in a disused lavatory”
One’s initial read of Waterfront Toronto’s “Get Involved” page does not inspire confidence in the ability to conduct a thorough public consultation. The page first informs us that “The next public consultation will be announced following the submission of the MIDP to Waterfront Toronto. From there it is on to another invitation to subscribe to their newsletter, an invitation to interact with them on Facebook and Twitter (where reasoned discourse thrives), and a suggestion that one check “back here for details later in the Spring.”
Beyond just getting “involved,” and also stretching the meaning of the phrase “get involved,” Waterfront Toronto wants to share with us their “Engagement history” (option 1) and their document library (option 4). They also take this opportunity, at the bottom of the page, to pitch their newsletter one more time, which makes me wonder if someone’s performance bonus is linked to hitting a newsletter-subscriber target. #bigdata
We’re also given the chance to participate in a “Civic Lab” (option 3), where people can “discuss thoughts, feedback, and questions pertaining to the Quayside Project.” Unfortunately, this link only takes us to reports on three previous Civic Labs and offers us the chance to visit their document library. Waterfront Toronto here passes up a golden opportunity to goose their Newsletter numbers, as the page features no invitation to subscribe to their newsletter.
Much more relevant to actually getting involved is Option 2, Participate in a public consultation. Why, yes, I would like to “Check for upcoming events.” Let’s do that!
“The lights had probably gone.”
Three levels down from the main page. It opens with the by-now-inevitable invitation to subscribe to their monthly newsletter or to contact them on Facebook or Twitter.
But we also see, for the first time, how Waterfront Toronto plans to consult with the public. They have planned a series of meetings, which will include “a main presentation and multiple breakout sessions.” Four presentations are planned across the city, starting … yesterday (July 15) and ending … in eight days (July 23).
They will also be hosting a series of “Quayside Dialogue Boxes,” to be held at various Toronto libraries, at which “staff from Waterfront Toronto will share information about the proposal, answer questions, and listen to your feedback.” Five of them are already passed; two are upcoming, on July 18 and 25.
If you’re keeping track of these timelines, Sidewalk Labs released its one-thousand-five-hundred-page report on June 24. Waterfront Toronto, on its consultations page, offers Torontonians four public consultations spread over eight days, held in the depths of summer three weeks after this mammoth report was released, a report that Waterfront Toronto itself had only recently seen for the first time in its entirety. And some library-based info sessions, most of which have already finished.
Perhaps reflecting the digital spirit of the multi-billion-dollar project, starting on July 15 Waterfront Toronto also began offering residents the opportunity to participate online via not one, but two, surveys. The shorter survey, “to share quick responses about how receptive you are to the proposals in Sidewalk Labs’ MIDP,” is almost comically superficial. It asks “How receptive are you to Sidewalk Lab’s proposals about” the one-thousand-five-hundred-page MIDP’s various sections, with choices of: Receptive; Receptive to some; Not receptive; and Need more information.
The longer “Detailed Survey” is actually quite good. It provides background information and asks pointed but open questions about each section that seem to allow for people to raise a wide variety of concerns and opinions. A section for general comments would’ve been helpful, but otherwise it’s exactly the type of online engagement that a project like this needs.
But there’s a rather short time limit. According to the “Participate in a public consultation” page also says “The deadline for Round One Online Consultation feedback is July 31, 2019.”
Which brings us to the main problem. The Detailed Survey is appropriate for this project precisely because it is so detailed. It has to be, because the MIDP covers so much ground. However, what this means is that it would take someone well-versed in the MIDP (itself of daunting length) the better part of a day to fill out. And Waterfront Toronto is seeking (presumably informed) comments for its Round One within the next 15 days.
(An aside: the reference to a “Round One” only appeared on July 15, and only in passing. Previously, there was nothing on this page to indicate that public consultations would last beyond late July.)
This is madness. Most governments hold longer, more in-depth hearings on less-complicated legislation than this. Each part of Sidewalk Labs’ proposal has so many moving parts that it requires not one two-week survey (followed by… what?), but separate hearings into each aspect. Any less and the responses to even the Detailed Survey are likely to be as superficial as the short survey.
“In the bottom of a locked filing cabinet”
All of this would normally lead me to become frustrated at the inadequacy of Waterfront Toronto’s consultation process, but my problem was that I hadn’t descended deeply enough into the cellar. Thankfully, Natasha Tusikov, who is also working her way through all of these documents for a SSHRC-funded project on smart-city data governance, points out that, in fact, Waterfront Toronto clearly lays out their extensive public consultation process.
In its Note to Reader.
On pages 46 and 47 of a 66-page document.
Which is only available as a pdf.
In this easily accessible document, the public is informed that the aforementioned public meetings are only round one of a two-round process. The first round will end on July 31, 2019, and feedback received up to then “will be summarized and shared publicly by the end of August 2019.”
Waterfront Toronto also helpfully suggests that “Given the volume of material in the proposal (1,500+ pages in total), members of the public may choose to attend more than one of the public meetings.”
Round Two, which is only hinted at on Waterfront Toronto’s webpage, is planned for the Fall, “exact timing to be determined,”
once the Waterfront Toronto team and the public have had more time to work through and consider the Draft MIDP. Round Two will include a report on the public feedback during Round One and will take the public conversation further to focus on particular areas of the Draft MIDP where the Waterfront Toronto team would benefit from additional public feedback and advice.
Take a moment to unpack this remarkable paragraph.
Waterfront Toronto is holding a second round of consultations in the Fall (but didn’t think to mention this on their “Get Involved” page) because it’s beyond unreasonable to ask anyone, even the people at Waterfront Toronto who are professionally invested in this scheme, to come up with a reasoned opinion on this mastodonic proposal in just over a month.
And they plan to give a report on the feedback from Round One in Round Two. Round One’s unreasonably tight timeline means that the discussion in Round Two will be shaped by two types of people: those who have can and have devoted several working days to plowing through this report (howdy), and those who don’t mind weighing in on a complicated subject without first doing their due diligence.
But most importantly: Waterfront Toronto is asking the public to comment on a report that it admits it has not yet fully analyzed.
Also, why the arbitrary July 31 deadline?
This is, in short, not a great consultation plan. It smacks of improvisation, which is not something one would necessarily desire from an organization trying to convince the public it can manage a multi-billion-dollar tech development and effectively supervise a subsidiary of one of the world’s most powerful companies.
“Beware of the Leopard”
Page 46 of Waterfront Toronto’s Note to Reader offers one final hard-won tidbit of information, in which we are informed that the Smart Consultation may be alive and well beyond the aforementioned surveys:
For those unable to join us in-person, the http://www.QuaysideTO.ca website includes more information about the project and an online portal to submit written comments.
Submitting written comments to Waterfront Toronto using their online portal is complicated somewhat by the fact that the portal does not seem to exist. There is the survey (which just went live on July 15), but a survey is not a portal, and the survey itself did not even exist when the Note to Reader (a genteel-sounding title that seems more suited to a Jane Austen novel than a development agency) was released.
Ever the intrepid researcher, Dr. Tusikov sent Waterfront Toronto an email to email@example.com asking to be directed to their portal.
Their response (form-letter, of course):
Thank you for taking the time to write to us about the Quayside project. We will be retaining feedback related to Quayside and Sidewalk Labs’ proposal for consideration throughout our engagement and evaluation process.
We are working to address to your individual inquiries as best we can. You can anticipate a more detailed response within a few weeks of this message.
For more information about Waterfront Toronto’s evaluation and consultation process, details on upcoming events, and to read an electronic version of Sidewalk Labs’ proposal head to quaysideto.ca.
We hope to see you at an upcoming consultation.
Waterfront Toronto team
A few weeks likely being after the July 31 Round One deadline.
The effects of difficult-to-find and incomplete consultation information, the tight timelines and the oddly structured consultation rounds are significant. As currently set up, this process will minimize informed comment and citizen participation. For an organization that has stepped on one rake after another over the past several years, having to go through so many hoops just to figure out how to participate in a public consultation is not a great look.
A positive first step would be to scrap the arbitrary deadlines, especially for the Detailed Survey, nix the idea of Rounds, and start extensive, focused, detailed consultations in September, once Waterfront Toronto has had a chance to read and understand the report it commissioned. Used the summer to help inform people, and for Waterfront Toronto to analyze fully the report they’re supposed to be evaluating. There’s no need to rush this, and true public consultation involves more than information provision and reading a newsletter.
But please, do sign up for Waterfront Toronto’s monthly newsletter. I fear someone’s livelihood hangs in the balance.