August, 2020-Letter to HRM Auditor General
Re- Review of HRM Planning’s public consultative process as a Charter matter
This letter (accompanied by 10 brief case studies) is to request that HRM Auditor General conduct a review of HRM Planning Department’s public engagement process and outcomes with respect to HRM planning and council votes. In writing to you we wish to note that we are aware of your July 2018 report to HRM Council on the operation of the Planning Department with respect to development agreements. We are prompted to write regarding a crucial aspect of the operations of that Department not addressed in the report, namely public participation.
The HRM Charter, Part VIII, s.208 states: “The purpose of this Part is to …(c) establish a consultative process to ensure the right of the public…to participate in the formulation of planning strategies…”
The establishment of a consultative process is indicative of a crucial aspect of how land-use planning is to be undertaken. It is not exclusively for the Council and its planners or for the developers and their architects.
The right of the public to participate should be understood to mean effective participation, not something for show only. This implies that public participation
• Must engage citizens and make them aware of issues that are directly affecting their neighbourhood/city and encourage them to express their views directly to staff. This is especially true of the Centre Plan because many residents are unaware and uninformed. Information should be shared in meaningful ways with minimal use of world cafes, pop-ups, cumbersome or biased on-line surveys, use of private on-line platforms such as Facebook or twitter.
• Dissent must be understood and acknowledged.
• Interchanges with the public must be professionally designed to ensure a clear objective and minimize problems with formatting, cumbersome downloading, unclear language, and limited response options
• Priority must be given to real, measurable outcomes: did the plan respond to the participants’ concerns/needs? If not, why not? How is public participation acknowledged? Were staff and the plan flexible, responsive and adaptive? As the attached submissions from community groups illustrate so graphically, HRM planning staff has too often not followed an ideology that is fluid, flexible, responsive and adaptive or open to alternative proposals. Often the sessions are to inform, not to get and respond to input. This is particularly obvious in the planning for the Centre Plan in HRM.
• Densification: Focus has been on creating more housing units and on supporting developers who want to build high-rises, often at the expense of existing neighbourhoods which are demolished or completely altered, without consultation with the residents. There is a huge body of research on the negative effects of high-rise development: increased need for embodied energy, harmful shadows, adverse sociological and physical effects on the city and the inhabitants, as well as on the better outcomes for diverse, affordable, connected communities provided by lower rise buildings. https://www.evergreen.ca/downloads/pdfs/2018/What_is_the_Missing_Mid dle_Evergreen_CUI_s2.pdf
• Corridors: the focus on intensification of residential development along transportation corridors is purposefully locating citizens in high pollution zones where human health, especially of walkers, cyclists, children and seniors may be negatively affected. Scientists recommend residences should be located no closer than 150 m to corridors and that corridors not be located next to greenspace or public parks. https://www.cbc.ca/news/technology/air-pollution-study-1.5339472
• Affordability: The intensification of housing units along corridors is occurring in locations where affordable rental units already exist. With no tangible plan for the provision of affordable housing, corridors are likely to displace much housing presently available to low-income families and individuals.
• Demolition and Climate Change: Building and construction are responsible for 39% of energy related to CO2 emissions. This is understood to the extent that globally, thousands of architectural firms and individual architects and the construction industry acknowledge their role in the climate change and biodiversity extinction crises. i.e. architectsdeclare.com Their declaration has made it a principal goal to upgrade existing buildings for extended use as a more carbon efficient alternative to demolition and new build. Unfortunately, thus far HRM planning has ignored the relationship between development and demolition as a climate change issue and continues to facilitate demolition in individual developments or promote it in larger planning processes such as the Centre Plan.
In summary, HRM planning staff expend millions of HRM tax dollars each year to create policy and regulations and to engage in public consultation processes. Too often these plans and regulations appear to reflect the wishes of staff and are therefore not respected because they do not reflect the wishes or interests of the public, or the results give every appearance of being pre-ordained.
Please find attached ten brief case studies and websites written by individuals on behalf of group efforts by volunteer citizens to engage in public consultation but where the outcome does not balance the public interest with those of private developers. The list could include many other groups such as Imagine Bloomfield; Wellington Street Neighbourhood; St Pat’s-Alexandra —Native Friendship Centre, Cornwallis Church, North End Health Clinic; Prince Albert Road/Glenwood Avenue etc.
We believe HRM Council and planning staff have been abdicating their duties under the Charter to provide, respond and incorporate meaningful public participation in planning matters. We believe going forward both staff and city council more generally must, in accordance with the directive in the Charter, be more prudent and respectful of the input of citizens in regard to existing and proposed planning policies and regulations. We would ask that you investigate this matter.
Directors, Friends of Halifax Common
Friends of Halifax Common was founded as a society in 2007 with the intent to ensure HRM followed the direction of the 1994 Halifax Common Plan. The society has made countless efforts to engage in planning processes via meetings, written submissions, public hearings, reviewed plan/masterplan/report reviews etc. Many of these are documented and found at www.halifaxcommon.ca. Reading these would provide further evidence of the disconnect between citizens desires for their city and the outcomes of planning processes.