“We see the draft Centre Plan as making a bad situation worse. We urge a complete re-thinking of the draft Plan.”  Howard Epstein, Board Member, Friends of Halifax Common

Below are FHC Board Member Howard Epstein’s comments on HRM’s June 27th draft Centre Plan Growth Scenarios submitted to HRM Community Advisory Committee. His letter addresses concerns about the Plan’s general approach and the failure to protect the Halifax Common. Click Here to read previous FHC submissions to HRM’s Centre Plan (PDF) and here (previous post).

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August 5, 2016

I am writing on behalf of the membership of the Friends of the Halifax Common to offer comments on the draft Centre Plan.

While the main focus of the FHC is on those aspects of the draft Plan that have immediate impact on the Common, we see those matters as arising in an overall context. That is, the general approach of the draft Plan is also reflected in those portions that are directly related to the Common. These comments, therefore, start with the overall approach of the draft Plan, and then move to specific focus on the Common.

General Approach of the Draft Centre Plan

We see the draft Plan as making a bad situation worse. We urge a complete re-thinking of the draft Plan.

In part the main failing is with respect to the height of allowable built form. In part it is the absence of a high priority for building community. In part the contemplated system seems to be structured around developer-driven priorities rather than a communal set of priorities. In part so many individual lots have been approved, usually by way of development agreement, that there is little room for protection of what remains in the way of stable neighbourhoods, or of development that builds appropriately and compatibly with what remains.

All of this can be illustrated by looking at actual development around two of the proposed corridors, Robie St and Young St. That area was approved in 2014 for two development agreements to allow for apartment buildings of heights of approximately 17-19 storeys, both now under construction. However, in the area there is a great deal of empty or underutilized land.

As an example, it would have been possible at that time for HRM to designate the area for development of another Hydrostone. The Hydrostone neighbourhood has been a great success. It is dense. It is serviced by both small and large local shops. It has green space. It is attractive. It works as a vital part of the overall Halifax Peninsula. It achieves all of the aims of long-range planning. Expanding it by directing development in the Robie/Young area was possible. But no such steps were taken. The municipality passively responded to particular proposals from individual landowners to build intensively on their land, rather than to set the standard for something that could have been a major benefit to HRM.

We wish to remind Council and staff of the observations of Christopher Alexander, one of the leading architecture thinkers of the Twentieth Century, and author of A Pattern Language (Oxford University Press, 1977).
He writes:

“High buildings have no genuine advantages, except in speculative gains for banks and landowners. They are not cheaper, they do not help create open space, they destroy the townscape, they destroy social life, they promote crime, they make life difficult for children, they are expensive to maintain, they wreck the open spaces near them, and they damage light and air and view. But quite apart from this…empirical evidence shows that they can actually damage people’s minds and feelings.” (p.115).

Alexander recommends an overall four-storey limit on buildings, and emphasizes that all decisions about buildings must reflect a sense of connectedness in a community.

In addition to the comments of Christopher Alexander about height limits, we note that Dalhousie University Professor of Engineering Larry Hughes, an expert on energy matters, has written that tall buildings are energy-inefficient. He suggests building of between 4-7 storeys have the potential to meet all of their space and water heating through solar.
(https://lh.ece.dal.ca/enen/2007/ERG200702.pdf.)

The drive to resist sprawl and achieve density in the Centre Plan area could have been achieved and can still be achieved through strict low to medium-height limits (ie nothing above six storeys). The way to do it is through use of empty or underutilized sites, of which there is an abundance in the Centre Plan area. All of the residential and commercial space that has been built in recent decades could have been accommodated this way.

All too often the decisions made in HRM have failed to recognize connectedness, and have been focused on individual proposals, despite language in the existing Plan the attempts to promote ‘neighbourhood stability’ and ‘compatibility’. It is too late to do anything about the errors of the past, but we should not repeat or compound them. In the Centre Plan we have the opportunity to take strong steps to protect and preserve what we have left. The draft Plan does not do that.

A priority of the Plan should be to recognize that a balance has shifted in the Centre area, and that it is time to put a halt to overbuilding, and to shift the land use planning focus to serious preservation of stable neighbourhoods, of heritage districts and individual structures, and of the quality of open space, and also to expand all of these. A recommendation to achieve this is that a focus of the Centre Plan be to create connections between established neighbourhoods by creating a green network between these by adding to existing public open space. In any case existing public open space should not be targeted as a growth area.

We are concerned that the Centre Plan has provided no inventory of already approved units within the urban core and that the inflated growth scenarios do not take these into account. As you may recall HRM’s 2013 Stantec Report suggests there is enough capacity within the Regional Centre for 35,000 additional units under the existing plan. Also, as a matter of homeowner economics, overbuilding will threaten the value of individual homes. This has potential to affect the HRM tax-base, and also will negatively affect homeowners, so much of whose investments are placed in their homes. The real estate analytics firm Turner Drake has been warning about this.

We suggest that HRM seek various amendments to its Charter so as to facilitate organized land use planning. An unfortunate series of amendments to the Charter have been sought from the Province, reflective of a set of priorities that has not been of best use for the community as a whole (to create a particular form of density bonusing; to build on the Common; to set municipal election contribution rules). Council could request : demolition controls tied to preservation of housing; the ability to impose a freeze on development while MPS rules are revisited; the specific power to require affordable housing in development agreements; a prohibition on changes to the MPS except upon regularly scheduled formal review except with a three-quarters majority vote).

On this last point, the essence is to resist spot-rezoning, as has so frequently occurred, for example through use of the Schedule Q mechanism.

We also suggest that sequential controls be adopted. In light of the extent to which the Halifax Peninsula has been built up, further development should go as a priority to the Dartmouth area of the Centre Plan area. Further, that no additional development agreements of density bonusing agreements should be entered into until all existing as-of-right lots are developed.

To be clear, we do favour what has been termed ‘infill’ or ‘invisible density’ if carefully integrated with existing neighbourhoods as to form. We favour this not as an adjunct to intense development of the draft Plan’s Primary and Secondary corridors and areas, but as an alternative to them. We are convinced that all residential needs for the long foreseeable future can be accommodated this way.

We also strongly favour an emphasis on affordable housing, especially aimed at families with children. (Our use of the term ‘affordable housing’ means more than any unit offered at any sum below full market rates, but means housing aimed at those in the greatest housing need, ie spending 30% or more of gross income on housing.) And such housing should be integrated into existing neighbourhoods. The existing MPS has a policy (City-wide policy 2.8) calling on HRM to foster the provision of housing for people with different income levels in all neighbourhoods. Instead, affordable housing has been clustered in Dartmouth north and the Gottingen St area. This tends to amount to a ghettoization, contrary to the stated policy. We urge a change.

We support further public consultations over the Centre Plan. We have been profoundly disappointed in the nature of the public consultation that HRM has undertaken. Although it had to do with another aspect of planning in HRM, the recent example of ‘consultation’ for the Birch Cove-Blue Mountain area in which no public comment was allowed was completely scandalous, and could have only emerged from a planning culture that does not hold the public in much regard.

Public participation is essential for good land use planning, and it should be conducted so the participation may be meaningful. We therefore request that all submissions made by individual citizens or NGO’s such as FHC at the various PAC meetings for development agreements such as the highrises at the Willow Tree area as well as the special process for St Pat’s be included as comments on the Centre Plan. The public was unanimous in their disapproval of highrises and yet the Centre Plan continues to consider these as targeted growth areas of 7 or more storeys.

To sum up this section:

• Limit height to less than or no more than six storeys

• Prioritize development off the Halifax Peninsula, though still in the Centre Plan area

• Seek legislative amendments to widen land use planning powers

• Protect and preserve stable neighbourhoods

• Create a green network to connect residential areas by increasing public open space

• Do not adopt a system of corridors or primary growth areas

• Include citizens comments from development agreements and St Pat’s process as part of Centre Plan

The Halifax Common

The draft Centre Plan does not adequately protect the Halifax Common.
It is always to be remembered that the Halifax Common was granted to the citizens of Halifax forever. The land is held by HRM in trust. Its use should be oriented towards general public benefit.

I was a member of Halifax City Council when the Halifax Common Plan was worked out in 1994. This was the outcome of a democratic public engagement that respected the valued in-put of citizens who worked well with Halifax planning staff. Unfortunately, the full plan was not formally adopted as a part of the MPS. It should be. This remains outstanding business for Council. On page 3 that document proposes the appropriate boundary for planning purposes for the Halifax Common as illustrated by Map 2. This commitment should be the beginning place for all planning by HRM.

Consistent with the 1994 Plan and our May comments submitted on the draft Centre Plan, the specific proposals for the Willow Tree intersection and Spring Garden Road at Robie St area as well as the targeted growth area along the perimeter of the Halifax Common are completely incompatible with how HRM should evolve, and inconsistent with protection of the Common.
We ask that you review FHC’s detailed concerns and consider these are part of this FHC letter comment on the draft Centre Plan Growth Scenarios. Of particular note is that the land from the former School for the Blind, now in use for parking at the Victoria General Hospital is a part of the Common for which a specific promise was made at the time it was developed. That is, the original promise was a fully landscaped “Park within a Park” 200 trees and 200 parking places. A new commitment in 2008 was for a portion of the parking lot to be landscaped public open space as part of a Grand Allee connecting the Citadel to Point Pleasant Park. This also remains outstanding business for Council.

We remind you that the 1994 Halifax Common Plan’s commits the City (now HRM) to the following:
Section 2.1:  The amount of public open space in the Halifax Common will not be decreased.
Section 3.1:  The amount of land owned by the City of Halifax will not be decreased.
Section 3.2:  The city will seek to increase the amount of land under city ownership through recapture of lands.

We respectfully request that you take this important opportunity to honour HRM’s commitment to the citizens of Halifax and revise the draft Centre Plan so as to better reflect it.

Yours truly,

Howard Epstein
Friends of Halifax Common