The Regional Plan’s 15-year population increase for this area was “at least 25%.” That works out to 16,712, based on the following calculation:
The draft Centre Plan doubles that target to 33,000 (pp. 3, 19, 25). This target is presented as a given, without explaining why the original target has been doubled. It is described in the passive voice, as if someone else were making this decision: “The Regional Centre is expected to accommodate up to 33,000 new residents” (p. 25). Because population increase is the primary reason for the urban growth that is being anticipated, this discrepancy questions the rationale for many other items in the document.
Population vs. Building Volume
The draft Centre Plan does not show how building development (in volume) is related to population (in numbers). The Regional Plan specifies population growth, but the draft Centre Plan proposes locations and heights for buildings. That’s apples and oranges. Without an equation to link these two quantities, there’s no way to tell if all of the “centres,” “corridors,” and “future growth nodes” make sense. The document’s analysis should begin with population, then use that to generate maps and diagrams. It shouldn’t begin with preconceived ideas about where to add urban massing to the city centre. To consider growth, the basic questions to ask (in the right order) are:
- To add 16,712 people to the Regional Centre over 15 years, how much building volume is needed each year?
- Where should this new development be located?
As a related exercise, one could start with the building volume assumptions (centres, corridors, and future growth nodes) and then calculate their population. How many more people would occupy the Regional Centre if all of these zones were filled?
Phasing and Need
If all of HRM’s currently proposed, approved, and under-construction developments are built during the next five years, how many people would they accommodate? How much more than the city’s annual 1% increase would that be? Would there be any additional need from 2021 to 2031? If the demand is filled quickly, would the Centre Plan have anything left to do? These basic statistics need to be included when the next draft Centre Plan is prepared.
Why does the draft Centre Plan not refer to the earlier “Halifax Housing Needs Assessment” document, which considered supply and demand over the next decade? What would happen if supply exceeds demand? Would older buildings be vacated? Who would gain and who would lose?
Finite Market Demand
A statement on page 17 is important: “This limited amount of development should be guided to areas that will provide the most positive impact to the Regional Centre as a whole.” Unfortunately, the draft Centre Plan does not indicate where those areas are located. It simply identifies seven “centres” and various “corridors” (followed by “future growth nodes”). It’s likely that developers would cherry-pick the most profitable sites to absorb the finite market demand. This would leave the rest of the areas undeveloped. How – and by whom – should development be “guided”? How would “the most positive impact” be determined?
In the Quinpool district, most of us want to see mid-rise (4–6-storey) development along the street (p. 91), but developers are liable to focus on high-rise buildings and leave the rest of the street undeveloped. The whole of Quinpool Road between Robie and Oxford should be zoned for no more than 6 storeys, to avoid high-rise cherry-picking and to spread out the development activity. Development along Quinpool Road should frame the street for pedestrians; high-rise buildings (even with podiums) are socially internalized and don’t do this.
Downtown Halifax is the centre of the city. Other areas on the peninsula and in central Dartmouth that are being targeted for more development should not be called “centres,” as this distorts their meaning. They are merely susceptible properties in various locations that developers have assembled, hoping to build denser and higher (and more profitably) than the land use by-law permits. To the developers, these locations are centres of attention, but the Centre Plan needn’t reinforce this distorted perception.
As a city matures, it’s expected that certain parts will grow and change gradually. The map on page 81, however, shows isolated patches of sudden growth that don’t contribute to a sensible urban pattern for Halifax. They seem like a short-term, expedient response to add population and generate profit. This is not a respectable plan for the centre of a city. Rapid growths in unexpected places are tumours, not centres.
By definition, a “corridor” (p. 96) is internalized and one-sided; it is focused on the main street. The adjacent neighbourhoods and the larger street grain need to be considered more carefully in the “corridors” and their maps. In the Quinpool district, for example, Yale Street and Pepperell Street are prime examples of problems that can arise when adjacent streets are parallel to the main street. Deeper commercial buildings along Quinpool treat these adjacent parallel streets as rear service lanes, eroding the front-facing neighbourhood fabric. Perpendicular streets have a different urban potential.
The draft Centre Plan mentions a general relation between building height and lot depth (p. 99) but doesn’t include the later news that a 100-foot-deep lot would permit a six-storey building rather than a four-storey building. To show the public what this would mean, the corridor map should illustrate the height limits for particular lots.
The Centre Plan also should include section drawings that illustrate four-storey buildings on shallower lots and six-storey buildings on deeper lots, along with the required setbacks. This would enable the public to understand the implications on adjacent neighbourhoods and whether this departs from the intended policy on “transition” (pp. 85, 92, 99).
Page 82 encourages a range of different housing types. That’s good. In Halifax there seems to be plenty of desire for options between the usual poles: detached houses and high-rise apartments. Unfortunately, developers can make more profit from high-rise apartment buildings, so that’s what we’ve been getting. How would the Centre Plan steer developers away from high-rise apartment buildings and toward intermediate housing types?
Pages 35 and 125 acknowledge that developments on large sites (larger than 1 hectare, 100m x 100m) can disrupt the surrounding city pattern. (The Nova Centre and its Grafton Street Tunnel are one obvious example.) The proposed Young Street district (46 hectares, p. 89) consists entirely of megablocks and risks becoming a detached high-rise enclave, like St. Jamestown in Toronto. Only a few streets continue through it. Why is the finer grain of the surrounding area not being extended through this district? Does this not contradict the pedestrian-friendly policy about establishing short blocks (p. 22)?
The draft Centre Plan raises many questions about height. Here are a few:
- The plan remains vague about height limits. Its maps provide ranges: 7–10, 11–15, and 16–20 storeys. Do the lower and upper ends of each range indicate pre-bonus and post-bonus heights (p. 83)?
- The largest number of storeys mentioned in the draft Centre Plan is 20, but this appears only in the map legends. If the Centre Plan intends that no future buildings be higher than 20 storeys, this should be stated explicitly.
- Page 85 says that the final Centre Plan will include maximum height limits. Until then, we don’t know the maximum heights. Will there be an opportunity to dispute these maximum height limits, or is this draft Centre Plan the last stage of public involvement?
- Page 85 also says that one of the factors for establishing height limits is “market interest and development activity in these areas.” Why should developers decide where tall buildings are located?
- On the Quinpool district map (p. 93), some of the height colours seem incorrect. The south side of Quinpool, between Robie and Vernon, is designated 11–15 storeys, but the properties are shallow. They are also adjacent to a 4–6 storey zone on Pepperell Street, so the intended transition (pp. 85, 92) is not possible. At the northwest corner of Robie and Quinpool (the Armco property), a 16–20-storey zone is located right next to a 4–6 storey zone; again, the intended transition is not possible.
- The most extreme disregard for the height transition policy is in the Spring Garden Road district (p. 91), where the 2–3-storey houses on Carlton Street would be surrounded by 16–20-storey buildings.
To enable city hall, its committees, and the public to understand a proposed development (p. 124), it’s not enough to show drawings of the proposed building, which is all that’s currently required in an application. Everyone also needs to understand how the building would fit into its surroundings. Therefore, an application should include (as a minimum) plan and elevation drawings that include the neighbouring buildings on all sides and in all directions. Conversely, elaborately rendered and misleading perspectives of the proposed building should be discouraged.
Centre Plan, Land Use By-laws, and Design Manual
The draft Centre Plan on its own is like a wish list, as illustrated in the “guiding principles” (p. 5). That’s fine as a start, but it provides few priorities or degrees of importance. When two initiatives conflict at a particular location, which one would take precedence?
Because we’re currently seeing only the plan (which is largely qualitative, equivalent to the four current Municipal Planning Strategies), without the accompanying land use by-laws (which would add quantitative items and limits) or the design manual, this draft Centre Plan seems quite “motherhoody.” Those two other documents are supposed to be prepared concurrently with the Centre Plan (pp. 121, 125). It would be useful to review all of them together, so that we know more about what is really intended, rather than seeking quick approval for the Centre Plan.
The Development Agreement process during the past five years has been a major loophole for disregarding by-laws. The draft Centre Plan specifies three “special circumstances” for a development agreement (p. 125), but there is no limit on additional circumstances. To prevent the continuing abuse of the development agreement process, this section needs to be tightened up.
When a development agreement application is submitted, it should include a substantial rationale that describes how circumstances have changed to warrant disregarding the land use by-law. This rationale is currently required but is not being enforced by city hall. Instead, this duty is being passed along to the public. This isn’t a job we asked for.
When a development agreement application is presented to the public, it should include a calculation of the immediate multi-million-dollar profit that the city would be giving to the developer by awarding development rights beyond what the land use by-law permits. This calculation would help to determine a fair compensation for this bonus density.
The draft Centre Plan includes a refreshing statement about incongruent buildings not providing a precedent for more of the same (p. 126). If this principle is to be taken seriously, it would be useful to identify incongruent buildings in the Centre Plan area, so that they are not used as crutches for new developments. Around Robie and Quinpool, for example, this would apply to Quingate Apartments (12 storeys on Quinpool) and Welsford Apartments (18 storeys on Robie). By recognizing them as incongruent buildings, the nearby proposals by APL (29 storeys), Westwood (25 storeys), and the Planning department’s scheme for Quinpool 6067 (12–18 storeys) surely would not be permitted.
The statements about views and view planes (pp. 5, 126) are important principles. The draft Centre Plan should say whether “view planes” refers only to the existing view planes from Citadel Hill or whether new view planes (e.g., from the top of the Library to Citadel Hill) are possible. City hall’s recent record on this second option has been dismal.
Digital Model of the City
To enable everyone to understand the relation between a proposed development and its surrounding context (p. 124), city hall should commission a digital model of the topography and building masses in the entire Centre Plan area. Other cities such as London and Chicago have done this. It should enable proposed developments to be added digitally, then viewed from all sides by everyone. This factual evidence would help reduce the frustration that developers, committees, and the public have been experiencing when a developer’s drawings don’t enable the required criteria – especially neighbourhood compatibility – to be assessed properly.
Miscellaneous Corrections, Questions, and Criticisms
- p. 6: The Cogswell Interchange lands are mentioned only once, under “Business Parks.” Are any residential buildings anticipated there? How much of the anticipated population growth would it absorb?
- p. 14: There are five, not four, universities in the Centre Plan area. Did you forget the Atlantic School of Theology?
- p. 21, 38: These references to human scale promote a common urban design fallacy: that a podium will mask the presence of a setback tower above. This works only if you’re standing right next to the podium (and ignoring wind and shadow).
- p. 25: The sidebar on density bonusing suggests that the “public benefits” were a successful trade for what the developers got in return. As members of the public, we would be interested to see a comparison that shows what we received (worth $1.4 million?) and what we gave away. This would be a useful reference for future discussions of density bonusing.
- p. 37: It’s not clear why taller buildings should be encouraged on corner sites. They are liable to be ordinary apartment blocks, not significant institutions, so there’s no symbolic function. Is this based on an outdated image of city gates? Taller buildings increase vehicular traffic and wind, which are already problems at intersections. This contradicts the pedestrian-friendly policy about “creating pleasant micro-climates” (p. 37).
- p. 37: This section on wind promotes a common fallacy that adding a podium below a tower will avoid wind problems at ground level and downwind. Applications for buildings above a certain height should include a digital wind model by an independent professional. Criteria and standards for assessing wind impacts are needed; perhaps they will be included in the land use by-law (as suggested on p. 124). They should be applied when a proposal is first being considered, not after it has been approved, as is currently the practice.
- p. 37: Shadows cast by a building on March 21 and September 21 are the same, so I assume that the word “between” should be “on.” Due to Halifax’s low sun angles during fall and winter, an additional date between September and March should be included. Criteria and standards for assessing shadows also are needed; perhaps they will be included in the land use by-law.
- 37: The reference to “incongruent buildings” not changing the context of an area is puzzling. It seems to mask some other idea. Is it intended to cancel the “neighbourhood compatibility” principle in the previous Municipal Planning Strategy?
- p. 38: The note about encouraging the use of design competitions for public works is a step forward, so long as the terms of reference are set up properly. Cities in Europe have much more experience with this, so city hall should consult with them on how to do this well. Encouraging design competitions for private developments also would be a step forward. The low level of design (urban design, site design, building design, etc.) by local developers and their consultants has been appalling.
- p. 56: The proposal to relax the national standard for new construction on or near heritage properties is puzzling. Developers would gain and the public would lose. Does the Centre Plan really want to take this position?
- p. 73: In the section on shipping and the Port of Halifax, how would the Centre Plan deal with transport trucks moving containers through the city? Would certain streets be designated as truck routes and be widened?
- p. 81: Tall buildings are to be placed at “strategic locations.” What is this “strategy” and what is it intended to accomplish?
- p. 82: Active, pedestrian-oriented uses at ground level indeed are important on commercial and main streets, but this wish needs to be considered more fully, so that the new ground-level vacuum along Brunswick Street between Duke and Cogswell is not repeated elsewhere.
- p. 83: Calculating density by Floor Area Ratio (an area or massing ratio) instead of persons per acre (a population ratio) is easier, but would population still be considered for other criteria such as outdoor amenity space and parking? In the glossary (p. 124) the definition of “density” still refers to people and housing units, not FAR; will this be changed? Will the land use by-law specify FAR limits? How would the current population density limits (e.g., 125 persons/acre) be translated into FAR?
- pp. 83–4: When a height or density bonus is negotiated, the developer should not be the one to choose the public benefit. Recent “public benefits” have benefited the developer more than the public (e.g., sculptures at the front entrance to The Trillium). A substantial cash transaction would enable the money to be spent where it’s needed most in the city. The public benefit should be large enough to serve as a disincentive for the developer; otherwise, the developer will choose the post-bonus height every time. Why have the recommendations in the commissioned “Density Bonusing Study” been largely ignored in the draft Centre Plan?
- p. 92: Summer Street is east of Robie. Do you mean Oxford Street?
- p. 99: Would the maximum density for each corridor be specified in the Land Use By-law?
- pp. 108, 112: The term “higher order residential” is odd and unclear. Is this adjective intended to refer to density (either population density or FAR), height, or transcendence? As a term, its contrast with “established residential” is also unclear.
- p. 112: Private outdoor amenity space doesn’t make sense for high-rise buildings. Private balconies typically are unused, except for storage. Communal outdoor amenity space should be provided instead.
- p. 132: The plan to prepare an inventory of “significant scenic resources, landmarks, natural features, historic and cultural resources” is important. Recognizing what we already have (and what we want to retain) should come first. The current approach – developers proposing something, then the public going on the defensive to try to protect what is threatened – is not fair to anyone.
- p. 139: The plan to consult with local universities on “community character studies” is a step forward, for two reasons: Universities have certain knowledge and expertise that city hall and developers don’t have. Local communities do have a certain character but it’s currently hard to argue against proposed developments that are oblivious to that character. We need to develop concepts and language that enable this character to be recognized and analyzed in some depth, so that character is not associated merely with the picturesque.
- pp. 141–4: Although this section claims to provide “indicators” and “metrics” to monitor the progress of the Centre Plan, it mentions criteria but no standards. When (and in which document) will the standards be provided?
- p. 145: In the glossary, the definition of “bonus density” indicates that the bonus would be applied to the neighbourhood that is being affected. This approach is too self-centred. Because developers target wealthier parts of the city, where profits would be higher, these bonuses would not reach other parts of the city that need more investment.
- p. 148: The “Secondary Municipal Planning Strategy” section mentions “Neighbourhood Planning Strategies.” Will they be incorporated into the next draft of the Centre Plan and adjusted accordingly?
I hope these comments are useful as you continue to develop the Centre Plan, Land Use By-law, and Design Manual.
Steve Parcell / 28 Nov. 2016