FHC Letter to Centre Plan Team Re Package B (Feb. 24 2021)

Centre Plan Team:
The Friends of the Halifax Common (FHC) wish to re-confirm our belief that while Package B of the Centre Plan is notable in many respects, the current draft does not adequately address the need for green public recreational space within an increasingly densified Regional Centre. The need for public open space in urban areas is widely recognized and documented, particularly by the W.H.O. in their study, “Urban Green Spaces and Health: A Review of Evidence.” Public parks provide a balance to the built environment; in fact development and open space are opposite sides of the same coin.

We believe that the need for green public space must be detailed at every level of Centre Plan Package B from Core Concepts to Implementation. Without this level of detail, the achievement of a balanced urban environment will not be achieved, it will be outpaced by rapid development. Opportunities to enrich our environment with public spaces both large and small will be lost. We disagree with comments made by staff that stronger language concerning the need for green public space will bind or burden HRM Regional Council. Rather, this is the time to identify and clarify the need and provide policies and procedures for Council to consider through which this need can be met.

We understand that this submittal is coming well after the formal close of the public consultation period for Package B, and we appreciate the consideration given to us, but we are convinced that it is essential that this need be raised, even at this late date. We therefore offer the following recommendations:

  1. More fully understand existing public green space within the Regional Centre.
    A statement in promotional material for Package B states: “Over 90% of residents in the Regional Centre live within 500 meters of a park.” We question this statement in multiple ways. First, does the definition of the term “park” used in this statement align with the common understanding of a park, which is a public green space for leisure and recreational use, or does it also include a school, a cemetery, a library, a parking structure, and other similar uses, all of which are included in the proposed PCF (Public Community Facility) Zone and all of which are public uses, but does this match our common understanding of a park? We don’t believe so. Second, how do the areas of proposed higher densification in Package B, the “nodes”, such as the far north end of the peninsula or along the Corridors, rate regarding this 500 meter benchmark. Third, how well are many of the “parks” included in this statement developed, equipped, and serviced as parks?

    We feel it is vitally important that we fully understand the existing public green space in our community, particularly in areas of proposed higher density, before we undertake a substantial densification of the Regional Centre. We are concerned that Package B is proceeding with the implicit assumption that the Regional Centre is currently well-served by parks. We at the FHC believe that while it does have many trees in many areas and a number of large and small parks, it is not generally well-served by parks in types, locations, development and servicing, again, particularly in areas of proposed higher density.

  2. Provide a strong statement in Vision and Core Concepts regarding the need for green space.
    The most appropriate place for a statement regarding the need for green space is as a fifth Core Concept such as “Public Green Space”. Alternatively, this statement could be included as a separate concluding paragraph to Core Concept 2.1: Complete Communities, which currently references the many ways in which development can strengthen a community, but which does not significantly reference the need to enhance the densified environment with an equally intensified green environment, nor does it reference the responsibility of municipal government, including staff, in the creation of this space.

  3. Employ much stronger language regarding the need for public green space.
    Staff has the responsibility to highlight and clarify this need for a successful community in the blueprint for our future. To not include it runs the strong risk of either falling short of required goals or the goals not being met at all. It is not enough to assume that the needs of our urban park system will be met by others in the future. They well may not. For example, under 3.2: Parks and Community Facility Designation, the statement is made that “as the Regional Centre increases, parks, open spaces, and recreational facilities will require further investment and possible (our emphasis) expansion. The term “possible” leaves this important need ambiguous and should simply be deleted. Section 3.2 continues with eight Objectives which are all good but which need to go further to identify and clarify steps through which they will be achieved. Overall parameters need to be identified to achieve a balance of good development and public green space, as well as to enhance and protect the space we currently have.

    Repeatedly through the draft document references are made regarding green space in terms such as “may,” “possible,” “consider,” etc. If this need is fully understood, the language of Package B should reflect that. This need not bind Council; proper language can be found but the need and the means must at least be clarified and outlined for Council’s consideration.

  4. Expand and clarify green space policies.
    The Policies identified in Section 9, particularly 9.4: Parks and Open Space Network, are good but again, need to go further to identify specific goals and timetables for the multiple studies and plans that are called for (e.g., Parks and Open Space, Green Network, etc.). Also, policies need to be developed outlining areas in which the Municipality could expand green space within the Regional Centre such as the reuse of current “surplus” municipal properties, particularly those of current public use such as Centennial Pool, to remain in public use. Another policy could address the ear-marking of funds from new development for the purchase, where required, of properties by the Municipality to become parks.

    Another policy could require that when public green space is taken away for another use that it be added elsewhere within that area. Certain of these policies could be enacted immediately by Council, others will require more consultation and planning, but the overall desired goals need to be clarified along with specific timetables for studies and plans, leading to enactment of desired outcomes. Greater specificity regarding the needs and means to expand and support green space needs to be given in Package B.

  5. Add a third Zone to the current Regional Park Zone and Parks and Community Facility Zones.
    There are currently two zones for parks within the Urban Structure designations, the Regional Park Zone (RPK) and the Parks and Community Facility Zone (PCF). Each of these zones allow uses which include a wide variety of public uses: schools, libraries, cemeteries, major and minor spectator venues, parking structures, transportation facilities, etc. These are certainly all necessary public uses, but as pointed out above, many of these uses do not align with our understanding of a park. Including parks within these designations allows the risk of losing valuable public green space to other uses, as we have seen repeatedly, particularly on the Halifax Common. A separate park zone with very limited additional uses, perhaps called a PGS (Public Green Space) Zone, needs to be added to these designations.

  6. Draw a line around all current green public recreational space within the Regional Centre.
    Just as our larger urban environment needs a Green Network to focus development within a manageable area and reduce sprawl, our urban parks and green spaces need protection from incursion by other uses, however important. We cannot simply keep chipping away at our green spaces to accommodate ancillary uses. The diminution of the Halifax Common has been going on generation after generation since its inception over 200 years ago. It continues today and no doubt, without protection, it will continue into the future, as more “needs” and “good uses” are identified. The Halifax Common requires more than a Master Plan, it requires protection through policies which need to be identified within Package B including efforts such as amending the Municipal Charter, providing greater clarity and expansion of the Cultural Landscapes designation, and additional policies such as those outlined above which will further enhance and protect our green space.

  7. Diversify the means to provide green space beyond reliance on private amenity space within new development.
    We agree that amenity space is an important aspect of development at all scales. However, we are concerned that stressing this requirement for new development, while not outlining policies and procedures for public green space will lead to a restrictive and limited urban environment in terms of the range of available activities, developing a sense of community, and providing a diversity of experiences. A corresponding focus needs to be given to the provision of public green space at all scales, particularly in areas of heightened density. One simple measure would be to require all developments above a certain size, which need not be particularly large, to dedicate space within the development for public use, much as new subdivisions are currently required to do. However, the responsibility of the Municipality through staff to develop and maintain public green recreation space remains.

    As discussed above, additional policies need to be identified and incorporated into the Centre Plan, which expand, improve and protect our public green space. Fundamentally, Package B needs to recognize and bring form to the process through which public green space at large scales accommodating large recreational parks, and small scales accommodating playgrounds and benches, and all scales accommodating nature in all forms, is necessary for a healthy urban environment.

    Again, we on Friends of Halifax Common Executive thank you for your consideration of these concerns at this late date in the development of Package B. As suggested by Staff, we will communicate these concerns to the CDAC, as well as to our membership, the public, and at an appropriate date to Regional Council.

With appreciation and best regards,
Friends of Halifax Common Executive

David Garrett, Peggy Cameron, Howard Epstein,
Beverly Miller, Judith Fingard, Alan Ruffman