All that builds is not development, PM

All that builds is not development, PM

High-density, high-rise housing in low-density, residential communities

Thursday, September 12, 2019

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This is an open letter to Prime Minister Andrew Holness from the undersigned citizens' associations to bring to his attention and that of the wider public the very negative impacts being experienced in the wake of the National Environment and Planning Agency (NEPA) provisional development order which was made public in 2017.

As you know, Prime Minister, the provisional development order of 2017 allows for radically increased housing densities and building heights throughout most of Kingston and St Andrew. Densities that were formerly restricted to 30 habitable rooms per Acre (HRA) and two storeys in height were increased to 100 HRA and six storeys in height in long-established residential areas such as Seymour Lands (known as Golden Triangle), Barbican, Meadowbrook/Havendale, Elizabeth Avenue, and other similar areas that were predominantly comprised of single family homes, with some townhouse developments.

Before the ink had even dried on this published provisional development order, NEPA has allowed for residential building heights of up to eight and 10 storeys in these areas, and allows developers to get away with flagrantly increasing the allowable densities by falsely submitting one-bedroom units as studio units, one- and two-bedroom units as one-bedroom units, thereby approximately doubling the already significantly increased allowable densities.

Additionally, unscrupulous developers flout restrictive covenants, building outside of these important limitations that were established decades ago so as to preserve the character of a neighbourhood. They build as quickly as they can, in order to limit the legal recourse of neighbours who are beneficiaries of these covenants. Sadly, the NEPA and Kingston and St Andrew Municpal Corporation (KSAMC), which are empowered to halt such unlawful construction do not do so.

We, the undersigned, are not against increasing densities. We think that, in planning terms, increasing housing densities in cities such as Kingston is generally a good thing, as it can help to curtail the rate at which the country's most arable agricultural lands and water sources are destroyed due to a housing “sprawl”, and helps to reduce the volume of commuting by car which is largely responsible for the ever-increasing traffic congestion in the city.

However, we believe strongly that the positive results can only be achieved if the policy for increased density is properly thought through and is supported by several other planning considerations. A policy of arbitrarily and radically increasing housing densities and building heights and facilitating indiscriminate construction of high-rise buildings will not, by itself, serve to improve the city, and instead will cause, and already has resulted in, severe negative consequences for affected neighbourhoods.

Negative consequences for neighbourhoods

The affected neighbourhoods are now facing vastly increased vehicular traffic, with air and noise pollution, and a radical negative change in the scale and character in the areas. There is a direct, negative impact for residents whose property adjoins these high-rise buildings as they suffer from a loss of privacy in their homes and blockage of natural air flow as well as sunlight, loss of mature trees, among other concerns. The experience is one that leaves many feeling under siege.

While construction of high-density apartment developments is proceeding at a rapid rate the public services to provide for potable water, storm water drainage, and sewage disposal are presently totally inadequate to serve the city, and plans to improve these services are only now being looked at.

A further impact which we bring to your attention, Prime Minister, is the impact on land values and property taxes. The value of a lot that has a single-family house will now be assessed as a lot on which apartments can be built out at a density of 100 habitable rooms per acre, for example. For retired people, and owners with a fixed income who cannot afford these increases, they will now be hard-pressed to continue to live in and enjoy the neighbourhood that they had chosen to live in decades ago.

We, the undersigned, intend submitting to NEPA formal objections to the provisional development order and use the medium of this open letter to call on other affected community associations to do the same. We believe that the matters outlined above need urgent remedy to mitigate the continued and accelerating destruction of the built environment of the city and the quality of life of the citizens in whose interests the Government is expected to act.

Our call

In other jurisdictions around the world, in properly planned cities, neighbourhoods of low and medium densities are preserved, while high-density, high-rise residential developments are normally clustered along or adjacent to downtown areas or areas of existing, high urban concentration of commercial and mixed-use developments. This allows for the residents who live in these high-rise buildings to have options to get to workplaces and shops, etc, without having to get into their cars and drive, and is a major factor in reducing traffic congestion.

We urgently call on the Government and NEPA to pursue this approach.

Further, Prime Minister, we are calling for:

1. a moratorium on the approval of high-rise, high-density projects located in the heart of established low-density residential neighbourhoods; and

2. urgent consultations with the concerned citizens groups which are being adversely affected.

We believe it is possible for the Government and stakeholders to agree to an approach that will result in liveable communities for all.


Golden Triangle Neighbourhood Association

Acadia Citizens' Association

Barbican Citizens' Association

New Kingston Citizens' Association

Trafalgar Park Citizens' Association

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