Good Planning Needs Adequate Notification & Time to Reflect – – A letter from Howard Epstein, FHC to Jacob Ritchie, HRM

FHC Board Member, Howard Epstein, has written to HRM’s Jacob Ritchie following a recent meeting to relate points of common understanding and to reiterate FHC concerns with about the Halifax Common and the proposed Centre Plan.

In summary:

The Halifax Common is a special place distinct from normal parks. The 1994 Halifax Common Plan could be integrated into the Centre plan. Intensive development on Spring Garden Road at Robie is not compatible with the 1994 plan.

The Proposed Centre Plan should:

  • favour medium-height buildings
  • distribute density
  • delay consideration of any new proposals until Plan is final and density bonusing is in place
  • respect public input such as in the case of the proposed Willow Tree developments
  • include a mix of affordable housing; prioritize in-fill of vacant lands
  • justify the case, if there is one, for towers and place more emphasis on sustainability with real targets for GHG emissions reductions, timelines and measures.

The letter follows here:
September 26, 2016
Dear Jacob:

Thank you for the opportunity to meet on August 31 to discuss the Centre Plan, and, as part of that, our concerns over the Halifax Common. As per our discussion we had written in May and August with detailed comments about the Common and the Centre Plan more generally.

We understand that you will issue sections of a draft Centre Plan shortly, continuing for about a month. The timetable you suggested would have a final Plan ready for consideration by Council perhaps in January. We appreciate your intention to keep us updated on this.

We agree that good planning needs adequate notification and that time to reflect is important. For instance we see the Friday Sept 2 release of the staff report on the Willow Tree developments before the Labour Day weekend and the Tuesday Sept 6 afternoon vote by council as problematic for both the public and the Mayor and Council. Did anyone have time to read the staff report or was that the hope?

There were several points made by you that are encouraging. Regarding the Halifax Common, you seemed to recognize that it is a special place, distinct from normal parks. You indicated that thought is being given to how the 1994 Common Plan may be integrated into the Centre Plan. On the other hand, you seem quite committed to seeing intense development on Spring Garden Road at Robie Street, made no commitment to proposing adoption of the 1994 Common Plan as part of the MPS, and were not yet familiar with the history of the municipality’s dealings with the VG Hospital parking lot area. On this last point, we will write to you separately to set out details.

We note that the south west Spring Garden Road area on the Halifax Common is the most constrained for capacity for water and sewage of any of the Centre Plan’s proposed targeted growth areas. We therefore ask given the abundance of approved land on the Peninsula and land that could be used as in-fill, why city staff are motivated to endorse intensive projects rather than respect the goals and objectives of the 1994 Halifax Common Plan?

Likewise, for the Centre Plan, we were encouraged to hear that the trend of your thinking is towards medium-height buildings along the corridor streets in most instances. We were also pleased to hear that you view HRM as having a power (under the Charter as it exists now, apart from any statute amendments that have been requested) to place a hold on revisions to the MPS and/or re-zoning during planning exercises.

It was good to hear your expressed support for existing local area plans, many of which were developed with extensive community input, have produced stable neighbourhoods, and have stood the test of time. Likewise, we appreciated your frankness about some planning mistakes and the over-use of Schedule Q.

Nonetheless, you made a number of points that we see as problematic, and we encourage you to re-think them:

  • Building re-purposing and renovation: Re-purposing of existing buildings is energy- efficient, and, as a practical matter, is entirely feasible in most instances. Favouring this should not be based on narrow parameters such as the aesthetics, age or character of particular properties. Rather, as per previous FHC asks, we believe specific policy and guidelines should be developed by HRM and enshrined in its Charter so as to ensure better, overall governance as to the issuance of demolition permits.
  • Distributed density: Favouring development in designated corridors continues to promote land speculation. Alternatives are available, including making it easier to add secondary suites in R-1 and R-2 areas, providing for garden suites, and similar measures that would add density in the Centre Plan area without significantly altering the look and feel of stable neighbourhoods. Such measures should go ahead as part of the Centre Plan, and not be delayed. At a minimum, such proposals should accompany any proposals for corridors. If you remain committed to corridors, we understood you to be favouring mid-rise, but if there are to be exceptions some specific mechanism needs to be identified so as to predict and control such exceptions. And we object to secondary growth corridors in the perimeter of the Halifax Common at Robie, South and Cunard Streets as per our discussion.
  • Moratorium on Development Agreement Application: We also favour delay in consideration of any new proposals until the Centre Plan process is finished. We ask staff to advise Council not to allow initiation of any applications that require amendments to the MPS or re-zoning while this process continues. We are particularly disappointed to learn that the staff report to HRM Council on Tuesday September 6th supported a 20-storey development by George Armoyan at the corner of the Willow Tree. As discussed in our meeting, there is any number of problems with this height of building at the site. It is of concern that the Mayor and Council as well as HRM staff has ignored the overwhelming fact-based evidence that various volunteer members of the public have submitted against buildings of such height in this area. We continue to be concerned that private conversations and badly worded HRM on-line surveys supplant the wisdom and research of citizens who take the time to submit input for the public record.
  • Density Bonusing: In addition, no development agreement or density bonusing proposal should be considered until Council has settled on the form of payment to be made for the ‘lift’ in value associated with such proposals.
  • Affordable Housing: Directing development so as to produce a suitable mix of affordable housing, including housing for families with children, is essential.
  • Vacant Lands: We emphasize that the Centre Plan area has abundant empty and/or underutilized sites, and that development should be directed to those in preference to such projects as that at Robie Street and Doyle Street, which is basically incompatible with its neighbourhood, and was unnecessary.
  • Towers: What is the case for towers?</strong> It cannot be jobs, since, as an example, a 20-storey tower could be replaced by four five-storey buildings that have the same capacity, and would provide at least the same number of construction jobs. It cannot be tax revenue since in the same scenario just outlined tax revenues would be as great (and indeed there is some indication that towers are historically under-assesses, whereas smaller buildings may well be easier to accurately assess). It cannot be municipal services, since again servicing is going to be the same. There seems to be no pro-tower case except the desire of the individual landowners to build them. If you can explain the case for towers we would be interested in hearing it.
  • Sustainability: Finally we ask that the Centre Plan have a greater focus on sustainability as for any real or projected potential population growth in the region our future depends on setting real targets for ghg emissions reduction with defined measures and timelines for ensuring success.

In conclusion you asked if FHC would be prepared to participate in some form of public panel discussion of drafts of the Centre Plan. Indeed we are. Please just contact us as you ready the next step in the process.


Howard Epstein

Friends of Halifax Common