Category Archives: OPINION

Friends of the Halifax Common send letters to the media and to public officials regarding protection of and development of the Halifax Common.

FHC Letter to Centre Plan Team Re Package B (Feb. 24 2021)

Centre Plan Team:
The Friends of the Halifax Common (FHC) wish to re-confirm our belief that while Package B of the Centre Plan is notable in many respects, the current draft does not adequately address the need for green public recreational space within an increasingly densified Regional Centre. The need for public open space in urban areas is widely recognized and documented, particularly by the W.H.O. in their study, “Urban Green Spaces and Health: A Review of Evidence.” Public parks provide a balance to the built environment; in fact development and open space are opposite sides of the same coin.

We believe that the need for green public space must be detailed at every level of Centre Plan Package B from Core Concepts to Implementation. Without this level of detail, the achievement of a balanced urban environment will not be achieved, it will be outpaced by rapid development. Opportunities to enrich our environment with public spaces both large and small will be lost. We disagree with comments made by staff that stronger language concerning the need for green public space will bind or burden HRM Regional Council. Rather, this is the time to identify and clarify the need and provide policies and procedures for Council to consider through which this need can be met.

We understand that this submittal is coming well after the formal close of the public consultation period for Package B, and we appreciate the consideration given to us, but we are convinced that it is essential that this need be raised, even at this late date. We therefore offer the following recommendations:

  1. More fully understand existing public green space within the Regional Centre.
    A statement in promotional material for Package B states: “Over 90% of residents in the Regional Centre live within 500 meters of a park.” We question this statement in multiple ways. First, does the definition of the term “park” used in this statement align with the common understanding of a park, which is a public green space for leisure and recreational use, or does it also include a school, a cemetery, a library, a parking structure, and other similar uses, all of which are included in the proposed PCF (Public Community Facility) Zone and all of which are public uses, but does this match our common understanding of a park? We don’t believe so. Second, how do the areas of proposed higher densification in Package B, the “nodes”, such as the far north end of the peninsula or along the Corridors, rate regarding this 500 meter benchmark. Third, how well are many of the “parks” included in this statement developed, equipped, and serviced as parks?

    We feel it is vitally important that we fully understand the existing public green space in our community, particularly in areas of proposed higher density, before we undertake a substantial densification of the Regional Centre. We are concerned that Package B is proceeding with the implicit assumption that the Regional Centre is currently well-served by parks. We at the FHC believe that while it does have many trees in many areas and a number of large and small parks, it is not generally well-served by parks in types, locations, development and servicing, again, particularly in areas of proposed higher density.

  2. Provide a strong statement in Vision and Core Concepts regarding the need for green space.
    The most appropriate place for a statement regarding the need for green space is as a fifth Core Concept such as “Public Green Space”. Alternatively, this statement could be included as a separate concluding paragraph to Core Concept 2.1: Complete Communities, which currently references the many ways in which development can strengthen a community, but which does not significantly reference the need to enhance the densified environment with an equally intensified green environment, nor does it reference the responsibility of municipal government, including staff, in the creation of this space.

  3. Employ much stronger language regarding the need for public green space.
    Staff has the responsibility to highlight and clarify this need for a successful community in the blueprint for our future. To not include it runs the strong risk of either falling short of required goals or the goals not being met at all. It is not enough to assume that the needs of our urban park system will be met by others in the future. They well may not. For example, under 3.2: Parks and Community Facility Designation, the statement is made that “as the Regional Centre increases, parks, open spaces, and recreational facilities will require further investment and possible (our emphasis) expansion. The term “possible” leaves this important need ambiguous and should simply be deleted. Section 3.2 continues with eight Objectives which are all good but which need to go further to identify and clarify steps through which they will be achieved. Overall parameters need to be identified to achieve a balance of good development and public green space, as well as to enhance and protect the space we currently have.

    Repeatedly through the draft document references are made regarding green space in terms such as “may,” “possible,” “consider,” etc. If this need is fully understood, the language of Package B should reflect that. This need not bind Council; proper language can be found but the need and the means must at least be clarified and outlined for Council’s consideration.

  4. Expand and clarify green space policies.
    The Policies identified in Section 9, particularly 9.4: Parks and Open Space Network, are good but again, need to go further to identify specific goals and timetables for the multiple studies and plans that are called for (e.g., Parks and Open Space, Green Network, etc.). Also, policies need to be developed outlining areas in which the Municipality could expand green space within the Regional Centre such as the reuse of current “surplus” municipal properties, particularly those of current public use such as Centennial Pool, to remain in public use. Another policy could address the ear-marking of funds from new development for the purchase, where required, of properties by the Municipality to become parks.

    Another policy could require that when public green space is taken away for another use that it be added elsewhere within that area. Certain of these policies could be enacted immediately by Council, others will require more consultation and planning, but the overall desired goals need to be clarified along with specific timetables for studies and plans, leading to enactment of desired outcomes. Greater specificity regarding the needs and means to expand and support green space needs to be given in Package B.

  5. Add a third Zone to the current Regional Park Zone and Parks and Community Facility Zones.
    There are currently two zones for parks within the Urban Structure designations, the Regional Park Zone (RPK) and the Parks and Community Facility Zone (PCF). Each of these zones allow uses which include a wide variety of public uses: schools, libraries, cemeteries, major and minor spectator venues, parking structures, transportation facilities, etc. These are certainly all necessary public uses, but as pointed out above, many of these uses do not align with our understanding of a park. Including parks within these designations allows the risk of losing valuable public green space to other uses, as we have seen repeatedly, particularly on the Halifax Common. A separate park zone with very limited additional uses, perhaps called a PGS (Public Green Space) Zone, needs to be added to these designations.

  6. Draw a line around all current green public recreational space within the Regional Centre.
    Just as our larger urban environment needs a Green Network to focus development within a manageable area and reduce sprawl, our urban parks and green spaces need protection from incursion by other uses, however important. We cannot simply keep chipping away at our green spaces to accommodate ancillary uses. The diminution of the Halifax Common has been going on generation after generation since its inception over 200 years ago. It continues today and no doubt, without protection, it will continue into the future, as more “needs” and “good uses” are identified. The Halifax Common requires more than a Master Plan, it requires protection through policies which need to be identified within Package B including efforts such as amending the Municipal Charter, providing greater clarity and expansion of the Cultural Landscapes designation, and additional policies such as those outlined above which will further enhance and protect our green space.

  7. Diversify the means to provide green space beyond reliance on private amenity space within new development.
    We agree that amenity space is an important aspect of development at all scales. However, we are concerned that stressing this requirement for new development, while not outlining policies and procedures for public green space will lead to a restrictive and limited urban environment in terms of the range of available activities, developing a sense of community, and providing a diversity of experiences. A corresponding focus needs to be given to the provision of public green space at all scales, particularly in areas of heightened density. One simple measure would be to require all developments above a certain size, which need not be particularly large, to dedicate space within the development for public use, much as new subdivisions are currently required to do. However, the responsibility of the Municipality through staff to develop and maintain public green recreation space remains.

    As discussed above, additional policies need to be identified and incorporated into the Centre Plan, which expand, improve and protect our public green space. Fundamentally, Package B needs to recognize and bring form to the process through which public green space at large scales accommodating large recreational parks, and small scales accommodating playgrounds and benches, and all scales accommodating nature in all forms, is necessary for a healthy urban environment.

    Again, we on Friends of Halifax Common Executive thank you for your consideration of these concerns at this late date in the development of Package B. As suggested by Staff, we will communicate these concerns to the CDAC, as well as to our membership, the public, and at an appropriate date to Regional Council.

With appreciation and best regards,
Friends of Halifax Common Executive

David Garrett, Peggy Cameron, Howard Epstein,
Beverly Miller, Judith Fingard, Alan Ruffman

2020 – FHC Centre Plan Submission

A Park within a Park was promised In return for the School for the Blind lands  with 200 trees, 200 parking places, a scented garden & a landcaped path along a block of Tower Road that was de-listed. The public reluctantly agreed to the plan but the promises weren’t fulfilled.

Dear Centre Plan Staff,

Please find included in this email two previous submissions from Friends of Halifax Common (2018 & 2016) . Our suggestions seem even more relevant in this time so we ask that you will please take the time to re-read these.

Green Space: As the Centre Plan intends to add 15-30,000 new residents to the area it is imperative that there be greater attention given to protecting existing green space and to increase it. This is for all the benefits known — human mental and physical health, safe social distancing, improved walkability and active transportation, habitat, gardening, coping with climate change etc.

Health Benefits: A 2016 World Health Organization[i] report suggests sizes of and distance from green space. ie 5 minutes from 1ha is one standard. It also emphasizes connectivity as well as buffer zones for green space – these should be adopted as goals of the Centre Plan. Why not envision a network of green space from Point Pleasant Park to Africville and from the North West Arm to the Halifax Harbour that traverses the Halifax Common? Why not daylight Freshwater Brook as a landscaped route through the city[ii]? This is happening around the world[iii] and has been considered for Freshwater since 2006[iv]. The Centre Plan should create these opportunities.

Also attached is a landscape design of the proposed Park within the Park (see illustration) that Peter Klynstra created and which the province and the city used to convince very reluctant citizens that the grounds of former School for the Blind should be converted to a parking lot for 200 cars with 200 trees. The block of Tower Road that was closed was supposed to be a landscaped path. None of this was ever fulfilled. This is an example of where the Centre Plan needs to be planning for recapturing public open space on the Halifax Common as per the 1994 Halifax Common plan. This should be scheduled on a timeframe to be accomplished within three years.

Approximately 20% of the Common is used for parking-that is about to increase with two new parking garages planned as part of the QEII re-development.

Contrast that with Paris, where the Mayor was recently re-elected with a promise to remove 60,000 parking spots. The goal has recently been increased to 70,000. All with the intention to create a city with clean air where citizens walk, bike or use public transportation to move about. How can the Centre Plan propose to be reducing reliance on cars when it has no targets or timelines for doing so?

Corridors, Emissions and Health: It is a major concern that the Centre Plan is premised on Corridors which concentrates people living next to major transportation routes. One outcome is the very serious health concern that the Halifax Common is surrounded by major driving routes and that the new developments on and next to it have large parking capacity for cars. Electrification is not coming any time soon-Halifax has just ordered 150 new diesel buses. The health of people walking or playing on the Common is at risk.

Vehicle pollution is deadly.[i] Dr. Michael Brauer, a Canadian expert on air quality recommends that people live at least 150m from major transportation routes-this is not news. Traffic pollution was recently noted for the first time as the cause of death of a 9-year old girl.[ii] Canada traffic emissions are a principal source of air pollution and the leading cause for us having one of the world’s highest rates of new childhood asthma. It is also linked to other lung diseases, higher risk of dementia, Parkinson’s, Alzheimer’s and MS. And of course traffic also leads to motor vehicle and pedestrian collisions.

Protect the Halifax Common: It is also a major disappointment that the Centre Plan has not protected the Halifax Common by focusing on a built form that would minimize the impact of development on the Common. The fixation with high rises is unnecessary, costly to neighbourhoods due to demolitions, superblockers that lack of porosity, wind and shade, loss of privacy and unaffordability. This is not promoting the scale of development that the city needs-the missing middle in distributed density. It is not a sustainable plan for moving forward. The attached illustration demonstrates different ways to achieve capacity for 300 units. The exact glass, steel and concrete building developers in Halifax are constructing are what New York city is banning[i].

Common Writ Large: Some final questions about the public common writ large:

  • Solar Rights: How does the Centre Plan intend to protect solar rights for existing or future installations?
  • Rights of Way: Will there be a process to identify public rights of ways that should be retained? -for example the former Garrick Street that transects O’Regan’s was promised to retain a public right of way by Mayor Walter Fitzgerald when it was traded to O’Regan’s for frontage on Robie Street. Another example is the steps in front of St David’s Church that lead between Grafton and Queen Street. Another is access through St Pat’s and St Pat’s Alexandra.
  • Lighting Design: Is there a detailed lighting design guide that minimizes light trespass, pollution and night blindness[ii]? And that reduces impact on birds?
  • Trees, canopy, pervious surfaces: Is there a plan to protect trees from development and to ensure that the tree canopy remains and that impervious surfaces are not increased?

FHC executive would be pleased to meet with you to discuss these ideas and sincerely hope that you can take them in the spirit that they are offered.


Peggy Cameron,
for Friends of Halifax Common

[i] Urban green spaces and health— A review of evidence

[v] health-deadly-

CBC-Maritime Noon-Why Old Buildings Matter

In 1960s the Cogswell “slum clearances” demolished 3,000 buildings with affordable housing, small scale businesses and diversity. Building & construction is responsible for 39% of greenhouse gas emissions. photo-Stephen Archibald-Brunswick Street, Halifax 1965/66

Listen to CBC’s Bob Murphy and guests Tom Urbaniak, professor at Cape Breton University and Tom Morrison, engineer at Heritage Standing Inc. discuss the multiple advantages of keeping old buildings-economic, social, cultural and very important – environment and climate change.

Cancel the Proposed WSP 23-storey high-rise

The Westwood high-rise tower at 2032-2050 Robie Street has already been turned down by HRM Mayor and Council. Height for this location was to be restricted to 6-storeys. The Development Agreement is discretionary-Mayor and Council should cancel the project.

Dear HRM Planners, Mayor and Council
Re: Cancel the Proposed WSP high-rise- Case 22927

The proposed Westwood high-rise tower at 2032-2050 Robie Street has already been turned down by HRM Mayor and Council. Height for this location was to be restricted to 6-storeys. Council’s decision to allow a Development Agreement is discretionary and should be cancelled. It is effectively raising the dead. This Development Agreement not only denies the earlier council decision and staff recommendations to limit the height to 6 storeys, it makes a mockery of public participation by voiding the historic and more recent input of citizens. 

Values reflected by statements such as Councillor Smith’s June 2019 motion “In recognition of the substantial investment made in the preparation of a planning applications for the site located at 2032- 2050 Robie Street, Halifax” beg the question whose interest are Mayor, Council and staff representing?  The owner’s investment of money in thinking about what to do with their land is not a legitimate basis for approving a project.

Are residents of the area being given recognition for their substantial investment in their homes, livelihoods, neighbourhoods, community services and time to participate in HRM planning consultations and processes?

Regulations and policies put in place under the Regional Plan through the efforts of Councillor Nick Meagher in the early 1990s were intended and did restrict high-rise developments so as to protect the Halifax Common and the Quinpool Road Business district. These had the full support of the area residents and merchants. This development is not necessary and will cause harm.

Necessity- The Willow Tree Group found that mid-rise (five-storey) development along Quinpool Road would allow for 2,500–2,800 new bachelor, 1-, 2- and 3-bedroom residential units. Distributed density with multiple developers is a form of gentle/hidden density and in-fill that is now the preferred form for getting densification done right as determined in a 2020 report by Ryerson University’s City Building Institute—”Density Done Right”—distributed density with mid-rise, townhouses and has multiple advantages over high-rises which in fact contribute to “tall and sprawl”. (See attachment.)

Harm-Objections from staff and council against the original proposal included: property is located mid-block; backs on the existing low-density buildings on Parker Street; frontage only on a single street; shallow property depth; shadows on the adjacent Commons to the east; contextual fit of the proposed building heights; massing of the buildings; setbacks; spacing between towers; density.

To these could be added: parking, traffic, congestion, pedestrian safety and air pollution associated with vehicular emissions; neighbourhood stability; wind and shade; noise and privacy; property values and housing affordability; concentration of rental market to the exclusion of smaller developers; greenhouse gas emissions associated with demolition, construction and operation; over concentration of development in a single area rather than distributed; disrespect for meaningful public participation and public process; mismatch between populations density and provision of services (water, waste water etc)

Cumulative Impact- These aforementioned problems are not all single issues about the one development but many should be considered cumulatively along with the two other towers on this block, the Atlantica Hotel and Dexel building south of Quinpool, the unknown QEII Redevelopment and the unrevealed St Pat’s High School site.

That is how do these all work together? What is the desired density? What is the cumulative effect of shadow and wind on the Halifax Common, Cogswell Park and the neighbourhood? What is the cumulative impact of the vehicles associated with all of these developments within close proximity of one Halifax’s busiest intersections and hospital emergency entrance and exit? What is the impact on affordable housing in the area-especially Parker Street where 12-14 buildings seem to be now zoned as a future service lane? Where is the 3-D model?

Citizen Opposition- We remind you that at the public hearing for APL’s 20-storeys there were ~1039 submissions in opposition and dozens of members of the public who spoke against that development. And just prior to the public hearing an independent Corporate Research Associate poll indicated that the majority of HRM residents (52%) supported 16-storeys or less with only 1/10 of those surveyed supporting the 25-storey option. Despite this opposition Mayor and Council approved a 25-storey building. Adding this 23-storey Westwood proposal would form a wall of high-rises, standing between the unwanted 25-storey building and next to the Welsford high-rise.

Although urban green space plays a huge role in mitigating the effect of climate change and nature improves mental and physical well-being HRM’s Centre Plan is not creating any new public green space for the Peninsula. It should therefore not consider permitting further degradation of either the Halifax Common or Cogswell Park with more shade, wind, noise, blocked views, traffic, pollution, for a project that does not add anything to the public realm but only takes full advantage of over-taxing the public’s socially provided greenspaces.

Please do not approve this proposal. Please take this as an opportunity to re-think Centre Plan policy for this site.

Thank you,

Peggy Cameron
Co-chair, Friends of Halifax Common

Density Done Right—A 2020 report by Ryerson University’s City Building Institute finds … “distributed density with mid-rise, townhouses and has multiple advantages over high-rises which in fact contribute to “tall and sprawl”.


Rick Howe-Cancel the Parking Garage-There are better solutions.

The fourth version of the 500-stall, 8-storey parking garage planned for the north side of the NS Museum of Natural History is flipped in orientation requiring a larger easement from HRM and chewing up more of the Halifax Common.

Rick Howe interviews FHC’s Peggy Cameron about the group’s letter to Premier McNeil asking that he cancel the plans for parking garages on the Halifax Common. There are other, better solutions.

Letter to Premier – Cancel the Parking Garage

Outgoing Premier McNeil

December 17, 2020
Dear Premier McNeil, 

As you leave your role as Premier, we write to ask that you reconsider the decision to build a $30 million dollar, 8-storey, 500-stall parking garage on one of the last remaining public open green spaces on the Halifax Common. Approximately 20% of the Common is used as parking, almost all for provincial health care facilities.
The 1000-stall parking garage planned for the former CBC building site will certainly provide enough parking for years – build it first and the parkade on the Museum of Natural History grounds becomes unnecessary. The decision for the Museum property parking garage taken by Minister Lloyd Hines, requires careful second sober thought.

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