(Feb 24, 2025) FHC’s submission to HRM on the Nova Scotia Government’s proposed changes to Minimal Planning Requirements* asks that they be rejected. The changes are without adequate public information, understanding or engagement. Where, what form and how development occurs should be integrated with plans for infrastructure, societal needs (including all ages and abilities) and commercial services, not haphazard. Planning is about more than buildings. If the Centre Plan is inadequate, when is the formal review period? There are areas that need to be strengthened. Details below the image…

Whats the best urban form? Decoupling density from tallness in analysing the life cycle greenhouse gas emissions of cities https://www.nature.com/articles/s42949-021-00034-w

Undemocratic: There has been no legitimate democratic process for public information, understanding or engagement. An on-line survey does not a city plan make. Residents of HRM have engaged for years to help regulate planning undertaken in the Centre Plan. Everyone may not agree but the outcome sought is a balance between public and private interests. These quick and reckless changes to HRM planning in addition to the recent HAF Centre Plan amendments are meant to further shut communication between residents and government, in this case with the majority of the public being totally unaware.

Planning Must be Strategic: Where and how development occurs should be integrated with infrastructure needs (roads, sewage, water); social needs (public transportation, schools, hospitals, fire & police, libraries, community centres, public open space, recreational centres) and commercial needs (food, services and other necessities). Complete communities also need thoughtful planning for inclusivity, all ages, all abilities. The proposed changes are haphazard and only about buildings, not how these mesh or integrate within what exists or who lives there. They dismantle present agreed upon rules, checks and balances. HRM plans must continue to regulate requirements for the number of bedrooms, amount of commercial space, number of parking spaces and seek a balance between housing requirements and other municipal needs. Any changes should be fully deliberated upon by citizens.

So, if the Centre Plan is inadequate, when is the formal review period? There are areas that need to be strengthened. Here are a few examples:

Climate Crisis: All planning must place the climate crisis front and centre. We know we need to stop emissions. Therefore we must stop emissions now, not at some future imaginary time. Buildings are responsible for approximately 40% of our greenhouse gas emissions. We are at a point in economic, social, cultural precarity where we cannot waste what we have and where we must take greater care with what we have. When will HRM’s Centre Plan require a carbon budget for all buildings? Why isn’t this already an aim to have all new buildings be carbon negative (removing carbon from the atmosphere) or carbon positive (storing and producing more energy on site that the building requires and feeding it into the grid)? When will HRM’s Centre Plan examine the relationship between building height and embodied carbon

Halifax Common, Public Open Space and Urban Forest: As HRM densifies the urban core there is ever greater use of existing public open space and need for more. Working with nature is an imperative for dealing with extreme weather. It is also vital to the physical and mental health of citizens. How and where does HRM plan new public green space-especially on the Peninsula? Why is HRM secretly planning for a stadium for a private corporation on the Wanderers Block outside of the planning process for the Halifax Common Master Plan, without any public consultation or financial analysis? 



Cumulatively the development of towers around the Halifax Common impacts the available space not just by increased use but also from more shadow and wind. On private lands, mature hardwood trees are regularly cut for developments that once built have no public open space or landscaping requirements. This is especially true of streetscapes surrounding the Halifax Common where hardedge is the urban fashion but an eco-enemy: increasing heat island effect, reducing soil porosity; eradicating habitat.

Public land is as vulnerable. The city’s plans for Robie Street widening and bike lanes on the Halifax Common’s University Avenue Boulevard regard trees as obstacles to be removed. Where is the protection for existing urban green space and trees?


Demolitions, Vacant and Public Land: Leading up to and post Centre Plan HRM has issued demolition permits to destroy thousands of affordable residential units. This is unnecessary as according to HRM staff there are 12,000 vacant lots within HRM. Demolitions also impact the climate as unnecessarily replace existing floor area unnecessarily uses materials and the energy along with the emitted GHGs to produce, transport and install these.

How does HRM intend to regulate demolitions, protect existing housing, and require affordable housing (with a definition for what is ‘affordable’) in new buildings? How does HRM intend that empty land must be prioritized for development over any new demolitions? What is the lesson from the loss of Bloomfield, St Pat’s Alexandra and St Pat’s High Schools that HRM will take? Each sale is a betrayal of public trust and community interest. Will HRM plan for public land such as Cogswell and Shannon Park to be used for public purpose- family, social and affordable housing?

Building Scale: A scientific research paper I wrote “Buildings for the Climate Crisis – A Halifax Case Study” -uses preliminary assessments of GHGs associated with the demolition of existing low rise buildings and compares these to mid-rise and to high-rise for the Carlton Block development. It determined that the taller the building, the disproportionately greater the upfront/embodied carbon per square measure. That’s from energy used for materials and products used in their construction such as concrete, steel, glass, aluminum. Taller buildings also use more operational energy per square measure (heating, lighting, cooling).

Other published papers by other authors underscore these findings. 
Decoupling density from tallness in analysing the life cycle greenhouse gas emissions of cities, from a team led by Frances Pomponi, examines four basic urban typologies with a Life Cycle Emissions and Population Summary. It finds, High Density Low Rise (HDLR) has less than half the Life Cycle GHG Emissions (LCGE) per capita of High Density High Rise (HDHR) buildings.

High-Rise Buildings: Energy and Density by Professor Philip Steadman of UCL sets out existing evidence on density and energy use on built form and density. It describes mathematically how Courtyards are the best, Crosses next, and Towers are only the THIRD best form for density.

My report has many examples of smaller scale infill, add-ons to existing buildings. Why does the Centre Plan not regulate the built form so as to maximizes density but minimizes greenhouse gas emissions? Many cities are successful adding density in 4-6 storeys that compliments existing architectural style with examples from Paris to Hamilton to Vancouver, and  including affordable units. Meantime until there is a formal, fully informed and public review process for the Centre Plan to determine what is working and what needs to be changed, none of the proposed changes should be approved.