May 2, 2011

Richard Harvey, Senior Planner

Planning Services, Western Region

Telephone: 490-5637

Fax: 490-4406

Re: Case 16655: Amendments to Increase the Height Allowances on the YMCA/CBC Radio Site

Dear Mr. Harvey,

I attended the Public Information meeting on Wednesday April 21, 2011 regarding the proposed development for the YMCA/CBC Radio site on the corner of South Park and Sackville Street in Halifax. I was disappointed that the meeting did not address the question of whether the buildings, especially the CBC building, could be creatively reused rather than demolished. The Ecology Action Centre’s Built Environment Committee would rather see the energy already embedded in the building cause the facility to be reused rather than simply destroyed. The cost to refurbish the buildings, even adding a few stories onto the existing frame, would be much less than if the development began totally anew. Does HRM demand the owners and project developers explore this alternative?

At the meeting, I pointedly asked the question of why the developer is requesting the height variance from the 23 metre limit imposed by HRMbyDesign, the Secondary Planning Strategy for downtown Halifax. I thought that the reason is economics but I feel like this needs to be made abundantly clear. Other developers are able to make a profit with buildings under the height limit, such as demonstrated with the addition of stories above Pete's Frootique undertaken by Dexel or by the building that Danny Chedrawe is erecting on the corner of Spring Garden and Birmingham Street. So why can't the developer make a profit staying within the height restriction at the corner of South Park and Sackville Street, one of the most desirable sites in the city?

From the comments made at the meeting it was clear that YMCA has abundant goodwill. The public does not want any development at the corner of South Park and Sackville to fail. It was also clear that the public believes the height restrictions in the municipal plans are there for good reason—the public wants to preserve an ambiance on South Park Street that does not challenge the Citadel and has a scale suitable for a neighbour of the Public Gardens. The question is how do we make this site profitable for the YMCA? Is it through development? Is it through reuse of the existing structures…Is it by changing the manner in which taxes are determined? It is these questions that the planning department and Council should be investigating, not whether a specific site development plan should alter the existing rules.

The municipality sets property taxes and area rates. This means that HRM has the power to set taxes, tax exemptions or area rates that could offset development costs. Rather than using additional height to make a development economically viable, which the developer at this particular site seems to think is necessary, changes to the urban tax structure may be able to achieve the same end. In this manner, HRM would not need to sacrifice its height restrictions in the name of economic viability.

A number of cities across Canada and the United States have used alternative taxation and financing schemes to achieve growth and revitalize their downtowns. Revitalization Tax Exemptions are used in British Columbia, Manitoba and most American states. They provide a tax-free status for a number of years in order to encourage development. Development will go ahead in some form on the prime location of South Park and Sackville Street, but a tax exemption could deflect a call for additional height. While this encourages density, the height restriction that already exists could remain in place without challenge.

The Ecology Action Centre was disappointed that at the Public Information meeting no specific provision was outlined to qualify the development for additional height under the bonus zoning option outlined in HRMbyDesign. The fact that it is the YMCA, an organization immersed in capacity building, which is moving the proposal ahead seems to be the only justification for the additional height. A discussion of whether this is “enough” public good did not form part of the meeting. The Ecology Action Centre believes that this discussion must occur before the amendment is considered.

Please do not hesitate to contact me if you would like to discuss this issue further. I can be reached at

902-429-0924 or .

Thank you,

Jen Powley
Our HRM Project Coordinator

RESPECTING & PROTECTING OUR ENVIRONMENT SINCE 1971