My comments below are in two parts. The first section is new, addressed to you. The second section is a copy of my comments on the Centre Plan growth scenarios that were sent earlier to email@example.com. (I don’t know if the Planning department forwards a copy of the comments they receive to you.)
1. Comments for CDAC
I’ve read Howard Epstein’s letter to CDAC. I agree with him that the Centre Plan is headed in the wrong direction.
As a member of the Willow Tree Group (which has been monitoring proposals around Robie and Quinpool for several years), I’ve been struck by the significant mismatch between the implicit urban vision of the Planning department and responses by the public. This predates the Centre Plan discussions. It has been evident in the many skirmishes over the spot-rezoning of individual properties via development agreement throughout HRM. This led to the formation of the Coalition for Responsible Development in HRM, with its open letter to the mayor and HRM councillors.
Unfortunately, the Planning department has not been upfront with its vision for the city. The Centre Plan growth scenarios skip over basic issues and simply return to the 2012 corridor scheme. All we’re given is options for urban massing in various parts of the regional centre. This is the wrong question to ask.
It’s evident that the Planning department does have a vision for the regional centre, but it remains implicit. It can be detected in various actions: its routine acceptance of development agreement applications; its presentations at public meetings; its proposal for Quinpool 6067; the buildings going up in the north half of the peninsula; and now the Centre Plan growth scenarios. Unfortunately, this vision is not described explicitly, so it’s hard for the public to challenge its preconceptions. Perhaps the Planning department considers this vision universal, so it doesn’t need to be described (like water for a fish). Its premises seem to include:
- tall buildings dotted throughout the city, as visible signs of “modernity” and “action being taken”
- emphasis on generic apartment blocks with underground parking garages, elevators, and internal corridors
- emphasis on singles and couples with substantial incomes
- little attention to children, families, or seniors
- little attention to increasing affordable housing
- little attention to uses other than residential or retail
- little attention to public life, streets, or neighbourhoods
- little attention to environmental factors
- little attention to long-term economics
- little attention to identifying strengths or weaknesses in local areas as a basis for development
- little attention to the economic or social impact of adding density to particular areas
- quick response to adding population to the city
- maximum profit for a few developers
- reliance on developers’ language and concepts
- more allegiance to developers than to the public
This vision belongs to the mid-twentieth century, before New Urbanism and other urban theorists went back to basics and asked deeper questions about urban development and its values. If the Planning department is not willing to present such alternatives to the rest of city hall and the public – or, even worse, isn’t aware of them, can’t imagine how they might be applied to Halifax, or thinks that the public prefers suburban expansion as the only alternative – perhaps it’s time to make some changes in the Planning department. If the Centre Plan’s narrow, outdated vision continues to roll forward, it would be not only damaging to the regional centre for decades but also an enormous missed opportunity to add population and develop the regional centre in smarter ways.
2. Comments on Growth Scenarios, sent to firstname.lastname@example.org
Here are some general comments on your Growth Scenarios document (27 June 2016, uploaded 6 July 2016). I learned of the August 5 deadline for comments only indirectly. As far as I can tell, August 5 is not mentioned anywhere on the Centre Plan website. That omission, in addition to the summer vacation season, is bound to affect the number of responses you receive.
As others will probably mention, the calculations in the population forecast are incorrect. Here is a spreadsheet that shows the discrepancy.
The projected 15-year increase in the Regional Centre would be 16,712, not 33,000 as reported in the Centre Plan document (pp. 3, 20). This questions the rationale for everything else in the document, as population increase is supposed to be the reason for all of this growth. Why not include a chart that shows your population calculations?
Building volume vs. population
The Centre Plan document does not show how building development (in volume) is related to population (in numbers). The Regional Plan specifies population growth, but the Centre Plan document 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 the map and the Growth Scenarios chart 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?
It’s interesting how the Primary Growth areas include so many properties that are currently constrained by Land Use By-laws and are owned by big developers with big plans that disregard those by-laws. Cynics might suggest that the Planning department has been advising those developers not to worry about the Development Agreement process [dead HRM link] or public opposition, as the Centre Plan eventually would give a green light to their developments. Is it a coincidence that the yellow lines on the Centre Plan map encompass many of these sites, including Armco’s proposal at Robie and Quinpool, Westwood’s proposal on Robie north of Quinpool, HRM’s proposal for Quinpool 6067, Dexel’s proposal at Robie and Pepperell, Westwood’s proposal on Quinpool at Preston, Dexel’s proposal at Spring Garden and Robie, Fares’s proposal at Windsor and Young, and Westwood’s proposal at Almon and Robie?
Phasing and need
If all of HRM’s currently proposed developments were built during the next five years, how many people would they accommodate? How much more than the annual 1% increase would that be? Would there be any additional need from 2021 to 2031?
If supply exceeds demand, would the newness of these buildings cause older buildings to be vacated? Who would gain and who would lose?
Does the Growth Scenarios document draw anything from the earlier “Halifax Housing Needs Assessment” document that considered supply and demand over the next decade? It’s not mentioned anywhere. How about the “Density Bonusing Study“?
“Built Form Transitioning”
I cringed when I read the statement “Architects often use a 45-degree angle drawn from the neighbouring property to define the building’s maximum height” (p. 5). Unattributed hearsay shouldn’t guide municipal policy, especially when it would have such a major impact on adjacent neighbourhoods. Where does this come from? Even Wikipedia cites its sources, so that they can be examined.
Whole vs. parts
These comments are all general; they pertain to the document as a whole. I don’t wish to discuss detailed issues, such as the proposed conversion of Parker Street, Pepperell Street, and Yale Street into service lanes. The whole document needs attention to its basic premises and logical connections before we can sensibly consider detailed parts such as yellow and orange lines on maps. Please don’t take this silence on the details as implicit approval.
Steve Parcell / 20 Aug. 2016